• Do not reflect realities on the ground;
  • Are tragically not uniformly implemented or enforced, resulting in tremendous suffering, abuse, and death;
  • Are not realistically audited for compliance to determine if they are effective, or need to be modified;
  • Are not published on a centralized database available to the public via the internet. Policies must be requested via Public Records Act request (responses take weeks/months);
  • Underground regulations (most have not been adopted through the Government Office of Administrative Law, OAL, subject to public comment, input, objection, and legal challenge);
  • Grants/Denies, Privileges/Rights, equally/or unequally, to one group or another, in a reckless manner creating hardship or unconstitutional disparities between patients similarly situated.
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