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Messages - MedicalWhistleblower

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16
Persons associated with DFAF:

Andrea G. Barthwell, M.D., F.A.S.A.M.
Founder and CEO
EMGlobal LLC
Global Public Health Policy
1010 Lake Street
Suite 422
Oak Park, IL 60301

Betty S. Sembler
Founder and Chair
Save Our Society From Drugs
2600 9th Street North
Suite 200-A
St. Petersburg, FL 33704

Robert B. Charles
Former Assistant Secretary for
International Narcotics and Law
Enforcement Affairs
United States Department of State

The Charles Group
18630 Reliant Dr.
Gaithersburg, MD 20879

Judy Kreamer
President
Educating Voices, Inc.
P.O. Box 6084
Naperville, IL 60567

Calvina L. Fay
Executive Director
Drug Free America Foundation, Inc.
2600 9th Street North
Suite 200-B
St. Petersburg, FL 33704

Robert L. DuPont, M.D.
First Director
National Institute on Drug Abuse
President
Institute for Behavior & Health, Inc.
6191 Executive Boulevard
Rockville, MD 20852

David G. Evans, Esq.
Executive Director
Drug-free Schools Coalition
203 Main St., PMB 327
Flemington, NJ 08822

Eric Voth, M.D., F.A.C.P.
Chair
Institute on Global Drug Policy
901 Garfield
Topeka, KS 66606

David A. Gross, M.D.
Chair
International Scientific and Medical
Forum on Drug Abuse
4800 Linton Blvd.
Bldg. D, #503
Delray Beach, FL 33445

DeForest Rathbone
Chairman
National Institute of Citizen Anti-drug
Policy (NICAP)
Public Drug Policy Advocates
1044 Springvale Rd.
Great Falls, VA 22066

Susie Dugan
Executive Director
PRIDE-Omaha, Inc.
3534 South 108 Street
Omaha, NE 68144

John F. Gilligan, Ph.D.
President Emeritus
Fayette Companies
600 Fayette St.
Peoria, IL 61654

Peter B. Bensinger
President & CEO
Bensinger, DuPont & Associates
20 N. Wacker Drive, Ste. 920
Chicago, IL 60606

Jeanette McDougal, MM, CCDP
Director
National Alliance for Health and Safety
P.O. Box 54893
Jacksonville, FL 32245

Michael C. Barnes, Esq.
Managing Attorney
DCBA Law, PLLC
International Law and Public Policy
P.O. Box 2943
Leesburg, VA 20177

John Pastuovic
Founder and President
John Pastuovic Communications, Inc.
Public Interest Communications
117 Oneida Street
Elmhurst, IL 60126

Anne Meyer
Secretary
Educating Voices, Inc.
P.O. Box 6084
Naperville, IL 60567

Jessica Talbert
Policy Analyst
Just Good Policy
2000 South Eads St.
Arlington, VA 22202

Terrence P. Farley
First Assistant Prosecutor, Director
Ocean County Strike Force
119 Hooper Ave.
Toms River, NJ 08753

Joyce D. Nalepka
Drug-Free Kids: America's Challenge
Nat'l Network of Parents/Grandparents
6213 Executive Boulevard
Rockville, MD 20852

Robert M. Stutman
Former DEA Special Agent in Charge
Member of the Board
Educating Voices, Inc.
P.O. Box 6084
Naperville, IL 60567

Roger Morgan
Founding Chairman
Coronado SAFE Foundation
5771 Sweetwater Rd.
Bonita, CA 91902

Carla Lowe
Co-founder
Californians For Drug-Free Schools
4241 Rio Monte Court
Carmichael, CA 95608

Debbie Lindner, President
New Jersey Federation for Drug Free
Communities
Statewide Non-Profit Prevention
Organization
P.O. Box 702
Livingston, NJ 07039

Geraldine Silverman, Chairman
Millburn Municipal Alliance for Drug
Awareness
Community-Based Prevention
Organization
23 Audubon Court
Short Hills, NJ 07078

William R. Caltrider, Jr.
President
Center for Alcohol and Drug Research
and Education
6200 N. Charles Street
Baltimore, MD 21212-1112

Malcolm "Cap" Beyer
Chairman
Student Drug-Testing Coalition
92 Lighthouse Drive
Jupiter, FL 33469

Elizabeth Edwards
Community Advocate
for Drug-Free Schools, Workplaces and
Communities
5442 E. 6th St.
Tucson, AZ 85711

Theresa Costello
Port Richmond Community Group
c/o 3117 Tulip St.
Philadelphia, PA 19134

Audrey Bumanis
Research Associate
Institute for Behavior & Health, Inc.
6191 Executive Boulevard
Rockville, MD 20852

Judy Dinerstein
Board Member
Educating Voices, Inc.
P.O. Box 6084
Naperville, IL 60567

Sandra Bennett
Director
Northwest Center for Health and Safety
419 E. Cedar Street, Ste. A 209
LaCenter, WA 98629

Linda Ledger, Vice-President
New Jersey Federation for Drug Free
Communities
Statewide Non-Profit Prevention
Organization
P.O. Box 702
Livingston, NJ 07039

Herschel Mills Baker
President
Australian Parents for Drug Free Youth
P.O. Box 73
Maryborough Queensland
Australia 4650

17
Just to let you know Eric Voth is connected in Kansas with Drug Free Workplaces and thus affects drug testing in the workplace and "volunteering" of employees into 12-step run programs.
http://drugfreeamericafoundation.blogsp ... chive.html

A STUDY OF THE INVOLVEMENT OF THE DRUG FREE AMERICA FOUNDATION. INC. (formerly Straight Foundation, Inc.) IN AMERICAN AND INTERNATIONAL DRUG POLICY by Wesley M. Fager, the Oakton Institute (c) 2002
http://thestraights.net/reports/dfaf-an ... policy.htm
http://www.thestraights.com/pickets/dfa ... -short.doc

Drug Watch Drug Testing Position http://www.drugwatch.org/pdf/Position-DrugTesting.pdf

Calvina Fay presentation in Brussels ECAD
http://www.ecad.net/activ/EPFay.html

18
Federally approved Drug Testing Laboratories are listed in the Federal Register

Federal Register, http://www.access.gpo.gov/su_docs/fedreg/a020201c.html

February 1, 2002, and scroll down to "Substance Abuse and Mental Health Services Administration." http://www.access.gpo.gov/su_docs/fedreg/a020201c.html

19
Drug-testing Laboratory Inspections, 1998 to 2001 - Division of Workplace Programs

Check out Drug Proof
Seattle: Drug Proof (Div. of DynaCare/Lab. of Pathology, LLC)
PDF File maint_wa_0032 http://www.samhsa.gov/foia/labs/wkstati ... a_0032.pdf
 
PDF File valid_wa_0032 http://www.samhsa.gov/foia/labs/wkstati ... a_0032.pdf

You can also check for those in your home state.

* These documents represent drug-testing laboratory inspections from 1998 to 2001. They are supplied by the Division of Workplace Programs, Center for Substance Abuse Prevention, SAMHSA. Some of the documents have been redacted or edited to remove confidential information. These portions are identified by a diagonal line.

Names of some of the laboratories have changed over time. For a list of former laboratory names, please got to the Federal Register, February 1, 2002, and scroll down to "Substance Abuse and Mental Health Services Administration."

http://www.samhsa.gov/foia/labs/index.aspx

20
Ambassador Melvyn Levitsky  has co-authored an article on drug policy with Dr. Eric Voth;  Dr. Eric Voth is located in Kansas.  David Evans of The Legal Foundation Against Illicit Drugs and Dr. Eric Voth (Chairman of DFAF's Institute on Global Drug Policy) co-authored an Amicus Curiae brief in support of the US government's effort to remove California's Proposition 215 for medical marijuana. Calvina Fay, Executive Director of DFAF, is a cofounder of Evans' The Legal Foundation Against Illicit Drugs and Voth's Institute on Global Drug Policy  is a subsidiary of DFAF. Today David Evans is also a member of the Institute on Global Drug Policy.

Here are two articles written by Wes Fager that mention Evans' relationship with Straight:

http://thestraights.com/drugpolicy.htm

http://thestraights.com/pickets/dfaf-an ... -short.doc

Also see DFAF and international drug policy here:
http://thestraights.com/articles/dpna.htm

21
http://sitemaker.umich.edu/ambassador.l ... _home_page

In May 2006 Ambassador Levitsky was reelected by a vote of the United Nations Economic and Social Council to a seat on the International Narcotics Control Board (INCB), an independent UN body of experts headquartered in Vienna and responsible for monitoring and promoting standards of drug control established by international treaties.

During his 35-year career as a U.S. diplomat, Ambassador Levitsky was Ambassador to Brazil from 1994-98 and before that held such senior positions as Assistant Secretary of State for International Narcotics Matters, Executive Secretary of the State Department, Ambassador to Bulgaria, Deputy Director of the Voice of America, and Deputy Assistant Secretary of State for Human Rights.

Ambassador Levitsky also served as Director of the State Department’s Office of UN Political Affairs and as Officer-in-Charge of U.S.-Soviet Bilateral Relations. Earlier in his career he was political officer at the U.S. Embassy in Moscow and a Consul at U.S. Consulates in Belem, Brazil and Frankfurt, Germany.

He is  a member of the Board of Directors of the Drug Free America Foundation, and the Institute on Global Drug Policy.

22
Teen Challenge / Perry says alcoholism is like being GAY
« on: August 26, 2011, 04:39:16 AM »
Time magazine reports that Rick Perry compared homosexuality to alcoholism in his 2008 book, On My Honor: “In a little-noticed passage in his first book, ‘On My Honor,’ a encomium on the Boy Scouts published in 2008, Perry also drew a parallel between homosexuality and alcoholism. ‘Even if an alcoholic is powerless over alcohol once it enters his body, he still makes a choice to drink,’ he wrote. ‘And, even if someone is attracted to a person of the same sex, he or she still makes a choice to engage in sexual activity with someone of the same gender.’”  "Rick Perry Compared Homosexuality To Alcoholism, Condemned ‘Radical Gays’ For Promoting ‘Gay Lifestyle’ " by Igor Volsky on Aug 24, 2011 at 1:40 pm  http://www.opednews.com/Quicklink/Rick- ... 4-707.html

Is that why Teen Challenge professes to cure both???

23
What is Charitable Choice?

Religious organizations have long been involved in provision of services to the communities they live in and work in.  Religious organizations working as government subcontractors are not new.   Catholic Charities , Lutheran Social Services, the Salvation Army , and the Jewish Welfare Federation  have long been indispensable sources of social aid.  For almost 40 years there have been collaborative service agreements between the government and sectarian organizations.  Catholic Charities, United Jewish Communities and others who have provided welfare services, maintained proper procedures in accounting to ensure the separation of church and state/federal funding.  These religious organizations put in place safeguards to protect the integrity of the religious organization, as well as the interests of state/federal taxpayers.  These religious organizations did not contract directly with the government; rather, religious institutions created separate entities (usually 501(c)(3) organizations) to handle public funds, and they did not incorporate religion into the publicly-funded program.  For large religious organizations, such as Catholic Charities U.S.A., the government money has been a large or even major portion of their budget.  

The new Faith-based initiatives paved the way for a political system which delegates social welfare responsibilities to newly-affiliated organizations   (some from the religious right) with which it forges privatized partnerships.  The strategy redistributes federal funding for social services from government functions where accountability had been fairly established and allocates funds to newer programs expected to bridge gaps in service/funds by being more cost-effective.  This places a greater burden on the former, established Faith-based community to become competitive bidders for their programs, increasingly subject to changes and cuts in government funding.

There is criticism that the proponents of new public-religious partnerships may be motivated by something other than a desire better to meet the social service needs of the country.   This debate has been partially driven by political and ideological concerns beyond the desire to help the poor. These concerns persist, notwithstanding the fact that improving social service provision is the public justification offered by former President Bush’s for charitable choice partnerships with pervasively sectarian organizations.

Charitable Choice was introduced during the mid-1990s after congressional committees devised alternate ways to address the burdensome welfare system. The Charitable Choice laws applied to four Federal programs: Temporary Assistance to Needy Families (TANF) and the Community Services Block Grant (CSBG) programs (both overseen by the Administration for Children and Families at the United States Department of Health and Human Services (HHS)); programs for substance abuse and mental health (overseen by the Substance Abuse and Mental Health Services Administration (SAMHSA) at HHS); and the Welfare-to-Work program (overseen by the Department of Labor).  

It is viewed with concern by some who fear that it will end public provision of social services and a welfare support system that many Americans in need depend on.  Charitable Choice strategy success requires that non-government social service providers will find the social services demand possible to meet. The increased burden of government regulation and competing demands for a charitable organization’s resources might cause mission displacement and have a negative impact on congregations.  A new dependence on government funds could result in decreased donations given to the charitable organization based on the presumed receipt of public funds.  Public perception is not necessarily in sync with legislative intent.  The premise behind Charitable Choice is that it relies on the market model with an emphasis on customers rather than citizens.  The goals of a democratic government are more than to simply respond to its citizens as customers.  There can be a potential for religious bias or discrimination by particular Faith-based contractors against needy citizen-clients who do not share common beliefs. There could also be bias in the grant of government contracts because effective oversight is difficult given the many different players at various levels of government.  

Many civil rights watchdog organizations warned that Charitable Choice blurred the boundaries between church and state.     Faith-based initiatives were policies based on concepts of fiscal conservatism, decreased size of the federal government, facilitated collaboration and cooperation in forged partnership with the religious community.  Thus, through this new legislative policy, Charitable Choice authorized a change for the way in which the church and state interact.  Conservatives find these Faith-based initiatives appealing because they want to decrease the size of government. They see the initiatives as an inexpensive alternative to government-sponsored social services.  Cuts in government funding result in a greater burden placed on the Faith-based community to take up the slack.    

The Charitable Choice concepts of indirect funding and neutrality principle   appear to promote a “black hole” for federal funds due to little transparency or oversight and little accountability to the taxpayer.  When private contractors are religious institutions they can claim constitutional protection against interference with free exercise of their religion.  The law currently exempts houses of worship from the full financial disclosure that is required from other non-profits when they are given tax-exempt status.  Thus when a church or religious institution receives public money to run welfare-to-work programs, it may legally assert a right to religious liberty and thus resist disclosing its financial records.  This may limit transparency regarding the dispersal of tax money to contracted service program providers and the government’s ability to assure honesty in provision of government contracted services.  A religious provider of job counseling, for example, could demand enough latitude to include prayer or Bible study in its programs, even if the government is directly contracting for the services.  Thus the government might be viewed as endorsing those religious practices, establishing them, or even coercing individuals in dire straits to engage in a particular religious practice.

The Charitable Choice program has been accused of giving preferential advantage to certain faith groups and endorsed them to receive federal grants. Constitutional concerns were raised in 2002 when President Bush issued Executive Order 13279, which facilitated churches and other Faith-based organizations to receive federal money by circumventing anti-discrimination laws.  This opened the door to bias in employment practices and service provision by Faith-based and Community Initiative programs paid for with Charitable Choice funding.  The Coalition Against Religious Discrimination (CARD) warned that possible proselytism when federal funds are used could violate the First Amendment related to church-state relations. Many scholars believe that direct funding would compromise the religious rights of recipients, encourage intense competition among America's religions, create a divisive political and legal battle over whether government funds should ever pay for programs that discriminate in whom they hire, and harm religious entities by restricting their autonomy. Because of the lack of good options of social welfare programs in all areas, publicly funded vouchers may pressure people into religious activities that they would otherwise not choose.    

Privatization of welfare – due process & constitutional concerns

In concert with diminished regulation over programs, the social safety net is vulnerable to exploitation.   Providing the safety net is a core public function which should remain responsive to democratic principles and accountable to elected officials. Although the government can contract out services, it cannot contract out the function of governing.

This privatization of welfare services leads to lack of adequate oversight in many jurisdictions when the organization that obtains the government grant subcontracts services to others, including private businesses. Thus, for-profit companies can be the entities that actually provide the in-field services. There is no provision for financial or service-quality oversight.  In theory, the contractors should police themselves and their subcontractors, but there is little profit incentive to do proper oversight.  

President George W. Bush’s Faith-based initiative intended to reduce the size of government, but not necessarily the amount spent.  His applied method shifted the responsibility for delivery of numerous social services from government agencies to newly-recognized, Faith-based organizations.  Privatization of welfare by delegation to contractors and subcontractors for service provision raises due process and accountability issues. Welfare programs involve provision of adequate food, adequate clothing, adequate shelter, and minimal preventive public health care.  Although the government has been viewed as the most obvious provider of these programs, faith-based programs have also frequently provided services to those in need.    But the government, which is elected and accountable to the citizenry, still accepts responsibility and accountability to see that social justice prevails and a decent chance at a reasonably healthy and active life can be provided for all citizens.

In 1997, the Texas Supreme Court   developed a test to evaluate the efficacy of delegation to private parties.  These guidelines are used to frame decisions about the scope of authority, accountability to the public and to federal authorities.  They identify the requisite expertise that qualifies a private entity to be a contractor.  

There is concern that private entities which contract to provide welfare services are not governed by constitutional constraints.  In other words, if a private contract provider of social services commits a wrongful action, the wronged person cannot invoke constitutional protections.  

The legal doctrine that defines “State Action” determines that a person who is a government actor and commits a wrongful act is subject to constitutional constraints.  State government and federal employees are clearly government actors, but private entities usually are not.  With government privatization contracts, authorization is transferred to private entities, but not “state actor” obligations.  Liability for actions is effectively diminished.  Privatization of contracts for welfare services permits autonomy without supervision or legal accountability.  Although there may be statutes in state or federal law that give the wronged person the opportunity to receive notice and obtain a hearing, these laws are generally not enforceable.  The courts have held that, unless there is a specific provision for enforcement, there will be no enforcement of these procedural rights.   The wronged person can sue under the third-party beneficiary principle - to compel compliance with the terms of the contract between the government and the private entity, but this is rarely successful.  

Contracts are often drawn up with the simple insertion of a provision in the contract that bars third-part lawsuits. Social service recipients are largely at the mercy of the political process to grant legal protection entitlements and due process rights.  They are also at the mercy of contracted parties to define and/or grant them contractual rights.  

Despite these constitutional and due process concerns, an increased number of government services are contracted out to private providers, which leaves clients with little or no recourse if their constitutional rights are violated.  Privatization may, in reality, simply replace a government bureaucracy with a private monopoly.    Most persons who oppose privatization are concerned about the negative outcomes it makes very possible.  

There is a human dimension to quality social services that is difficult to protect in an unregulated contractual arrangement. To relegate sensitive decisions to private organizations and companies that use market-based models is potentially a risk that is under-appreciated for its implications. Critical decisions that affect our society’s most vulnerable citizens can become based on short-term private incentives rather than long-term public interests.     Government authority may be unable to scrutinize the work of private entities adequately because of budgetary restrictions or unfamiliarity with contract management.  The lack of oversight could mean that the public is not assured that tax dollars awarded to government contractors will yield a privatized service that performs adequately.  

The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996   repealed Aid to Families with Dependent Children (AFDC), the federal cash assistance program, and replaced it with Temporary Assistance for Needy Families (TANF), a cash assistance program primarily operated by the individual states.  Prior to PRWORA, determination of which applicants qualified for federal benefits was performed by a public agency staff in civil service. (Title I, Section 104)  Under the new 1996 law,  however, TANF eligibility in Florida and Texas was contracted out to private organizations which were not directly accountable to public authority.

Privatization can be undermined by corruption if lucrative contracts are awarded to political allies, relatives or friends of public officials.  Many of these contractors are not qualified for the work or may cut corners to expand profits, especially when oversight is limited.  Contractors have been found to commit fraudulent and illegal practices, including:

• bid-rigging (arranges bids to be submitted by selected firms to limit real competition);
• low-ball bids (sets bids artificially low to win contracts, then subsequently raises fees excessively through tactics such as change orders);
• over-billing (charge too much, or charge for work not done).

These practices are difficult to prove, to monitor for and to investigate.  

Texas and Florida privatized functions to qualify clients for public benefits.  They closed public offices and set up call centers that use 2-1-1 information lines.  Staff employed by private contractors took initial client applications by telephone and if eligible, sent them to a public agency for final certification.  Private contractors employed by corporations determined whether an application was submitted to a public agency. Access to benefits under this system can be manipulated to maximize profit or can be awarded in a biased way.  The privatization of welfare eligibility determination, including food stamp and Medicaid coverage, represents a fundamental shift in delivery of social support to low-income populations. Large, for-profit corporations may have strong financial incentives to either turn away recipients or provide them with inadequate services.  Freedom of information and open records acts do not apply to private contractors.  This makes it difficult to determine how public funds were spent.

The use of subcontractors or outsourcing has often been used to abdicate social and moral responsibility.  There are significant legal, political and economic advantages to the perpetrator of human rights abuses, of using subcontractors, because it ultimately helps obscure the relationship between the perpetrator and the actual act.  It is a politically valuable device, because even if abuses are exposed, it will frequently look as if someone else (the contractor) was responsible.  This ultimately makes it difficult to hold a violator legally accountable and to be able to apply appropriate sanctions.  Thus the very effective human rights tactic of public shaming, in these circumstances, often becomes ineffective.  Outsourcing to contractors permits the perpetrators to ignore the societal norms and to conceal the perpetrators breach of those norms.  In addition, it legally protects perpetrators from both legal prosecution and embarrassment.  Subcontracting to corporations providing services such as prisons, healthcare and the military are particularly problematic, as in these settings there is reduced transparency to the public and less scrutiny by law enforcement.  Transnational corporations have enormous political and financial influence and power.  Health maintenance organizations and prisons use cost cutting methods which include using insufficiently trained, underpaid and over worked employees.  Rapid employee training and high turnover can lead to inadequate services in residential treatment centers, prisons, and other facilities.  When operated as a for profit business, cost reductions can lead to inadequate care, lack of adequate programming and abuse.  Outsourcing allows the perpetrator to not just abdicate responsibility but also assists the aggressor in maintaining a respectable public persona in the public eye. This often amounts to abuse of state-sanctioned power and authority.  Often outsourcing is presented to the public as necessary to cut costs. The use of subcontractors makes it more difficult to determine who is responsible for abuses and these cases are very complex.
 
References and citations:

  In fact, in the United States, seven of the largest religiously affiliated entities serve more than sixty million people with social services. Religiously affiliated entities tend to provide a wide range of social services comparable to those provided by government social service agencies. Many are professionally accredited through the Council on Accreditation of Services for Families and Children, Inc. Thus, they are held to the same standards as secular organizations.  See John McCarthy & Jim Castelli, “Nonprofit sector research fund, religion- sponsored social service providers: the not-so-independent sector” (Aspen Inst., Working Paper No. WP98-02, 1998); see also Michael W. McConnell, “ Religious Freedom at a Crossroads,” 59 U. CHI. L. REV. 115, 183 (1992); Ronald Thiemann et al., “Responsibilities and Risks for Faith-Based Organizations, in Who will provide? The changing role of religion in American social welfare” 51-70 (Mary Jo Bane et al. eds., 2000).

  Catholic Charities USA, “Who We Are,”  http://www.catholiccharitiesusa.org/who/ index.htm.

  The U.S. Salvation Army received thirteen percent of its fiscal year 200I funds from the government. Salvation Army USA Nat'l Headquarters, Annual Report (200I), available at http://www.salvationarmyusa.org.

  In 200I, United Jewish Communities received a federal grant of $59,868,000. CBBB Wise Giving Alliance, Charity Report United Jewish Communities (2002), available at http://www.give. org/reports/care2_dyn.asp.  “United Jewish Communities, About Us,” at http://www. ujc.org/aboutus_home.html.

  "Catholic Charities USA is the nation's largest, private network of social service organizations with I,400 local agencies and institutions providing essential services to more than 9.5 million people annually, regardless of their religious, racial, ethnic, or economic background." Letter from Catholic Charities USA to Senate and House Budget Committees (Feb. 26, 2000), at http://www.catholiccharities usa.org/programs/Advocacy/letters/Letters2001/budget1.htm.

 Charitable Choice Funds, MissouriNet.com,  http:/ http://www.missourinet.com/2010/12/23/c ... wer-audio/.

  Sager, Rebecca, “Faith, Politics, and Power,” The Politics of Faith-Based Initiatives,  Oxford University Press, 2010, TheDivineConspiracy.org,  http://www.thedivineconspiracy.org/Z5242W.pdf.

  Stevenson, Dru, “Privatized Welfare and the Nondelegation Doctrine,” 35 Clearinghouse Rev. 546 (2001-2002) Jan-Feb 2002. http://heinonline.org/HOL/LandingPage?c ... 4&id=&page.

  Gedicks, Frederick Mark, “A two-track theory of the establishment clause,”
Establishment Clause doctrine has long been informed by two mutually antagonistic values: the separation of church and state, and government neutrality with respect to religion. There are conflicting values of both separation and neutrality which co-exist. The Speech Clause doctrine provides an absolute minimum of constitutional protection for expression against even content-neutral regulation, so also Establishment Clause doctrine provides for an absolute minimum of church-state separation against even religiously neutral government action. The Establishment Clause has long been thought to protect two values, the separation of religion and government from each other, and government neutrality with respect to religion. Separation requires that religion and government each refrain from involving itself in the affairs of the other. (Everson v. Board of Education).  Neutrality has not totally eclipsed separation, which is the more fundamental Establishment Clause value.  Neutrality requires that government regulate its interactions with religious individuals and institutions so that it neither encourages nor discourages religious beliefs or practices. (Epperson v. Arkansas). http://www.bc.edu/bc_org/avp/law/lwsch/ ... 03_FMS.htm.
 
  Minow, Martha, “Public and Private Partnerships: Accounting for the New Religion,” 116 Harvard Law Review. 1229, 1232-33 (2003).

  The Coalition Against Religious Discrimination (CARD) opposes charitable choice as an unconstitutional and dangerous proposal that will harm religion, authorize government-funded discrimination, undermine the accountability of taxpayer dollars, foster litigation against state and local governments, and violate the personal religious rights of Americans seeking help. See Coalition Against Religious Discrimination, What Is "Charitable Choice"?, at http://www.stop religiousdiscrimination.org/what is_charitable_choice.html. CARD includes many religious and nonreligious nonprofit organizations such as American Baptist Churches, USA; American Civil Liberties Union; American Jewish Committee; American Jewish Congress; Americans United for Separation of Church and State; Baptist Joint Committee on Public Affairs; Catholics for a Free Choice; Central Conference of American Rabbis; Friends Committee on National Legislation; Jewish Council for Public Affairs; Jewish Women International; NARAL Pro-Choice America; National Association for the Advancement of Colored People; National Association of Alcoholism and Drug Abuse Counselors; National Association of Social Workers; National Council of Jewish Women; National Education Association; National Gay and Lesbian Task Force; National Organization for Women; National Parent-Teacher Association; National Partnership for Women and Families; National Women's Law Center; People For the American Way; Planned Parenthood Federation of America; Rabbinical Assembly; Service Employees International Union, AFL-CIO; The Interfaith Alliance; Union of American Hebrew Congregations; Unitarian Universalist Association; United Church of Christ (Justice and Witness Ministries); and United Methodist Church (General Board of Church and Society). Coalition Against Religious Discrimination, About C.A.R.D., at http://www.stopreligiousdiscrimination. org/about_CARD.html.  More than 850 religious leaders signed a petition organized by CARD urging President Bush and Congress to reject charitable choice propos- als, explaining that the "flow of government dollars and the accountability for how those funds are used will inevitably undermine the independence and integrity of houses of worship." Coali- tion Against Religious Discrimination, An Open Letter to President Bush and Congress from America's Clergy (June 14, 2001), http://www.stopreligiousdiscrimination. ... rom_clergy. pdf; see also Press Release, Americans United, Religious Leaders Urge Bush, Congress To Reject "Faith-Based" Funding Proposals That Allow Discrimination, Entangle Religion and State” (Apr. 24, 2001), http://www.au.org/cardpressrelease.htm.

  Saperstein, David, “Public Accountability and Faith-Based Organizations: A Problem Best Avoided,” Harvard Law Review, Vol. 116, No. 5, (Mar., 2003), pp. 1353-1396, The Harvard Law Review Association, http://www.jstor.org/stable/1342729.

  Collins, Milton, “The Privatization of Social Service Programs,”
http://www.wlu.edu/documents/shepherd/a ... ollins.pdf.

  Tex. Boll Weevil Eradication Found., Inc. v. Lewellyn, 952 S.W.2d 454, 472 (Tex. 1997).  These  factors affect whether a government function can be delegated:    (1) are the private delegate's actions subject to meaningful review by a state agency or other branch of state government;( 2) are the persons affected by the private delegate's actions adequately represented in the decision process; (3) is the private delegate's power limited to making rules, or does the delegate also apply the law to particular individuals;(4) does the private delegate have a pecuniary or other personal interest that may conflict with his or her public function; (5)is the private delegate empowered to define criminal acts or impose criminal sanctions; (6)is the delegation narrow in duration, extent, and subject matter; (7)does the private delegate possess special qualifications or training for the task delegated to it; and (8) has the Legislature provided sufficient standards to guide the private delegate in its work. Although not all the factors relate to public assistance (notably three and five), the rest can, and are considered very instrumental to determine whether certain authority can have been delegated. http://www.supreme.courts.state.tx.us/e ... 048105.pdf.

  Freeman, Jody, 116 Harv. L. Rev. 1285, 1304-05 (2003).

  Estrin Gilman, Michele, “Legal Accountability in an Era of Privatized Welfare,”  81 Cal. L. Rev. 569, 611-12 (2001).

  Freeman, Jody,  “Extending Public Law Norms Through Privatization,” 116 Harv. L. Rev. 1285, 1300 (2003).

  Jody Freeman, “The Contracting State,” 28 Fla. St. U. L. Rev. 155, 170 (2000).  Persons concerned about the potential negative results associated with privatization are called  “consequentialists.”

  Diller, Matthew, Form and Substance in the Privatization of Poverty Programs, 49 UCLA L. Rev. 1739, 1740 (2002).

  Shue, Henry, Basic Rights: Subsistence, Influence, and U.S. Foreign Policy,p. 23, Princeton University Press (1996).

  Personal Responsibility and Work Opportunity Reconciliation Act of 1996, Pub.L.No. 104-193, 110 Stat. 2105.

  42 U.S.C § 604(a)

  Stevenson, Dru,  “Privatization of Welfare Services: Delegation by Commercial Contract:, 45 Ariz. L. Rev. 83, 88 (2003).

  “Safety Net for Sale: Dangers of Privatizing Social Services,”  American Federation of State, County and Municipal Employees, AFL-CIO,  1625 L Street, N.W., Washington, D.C. 20036-5687, Web site:www.afscme.org,
 Privatization Section, http://www.afscme.org/private/index.html

24
Thank you for the Update -  it is difficult to keep up with all the legal changes of name and place these abusive centers do deliberately to evade investigation and judicial action.

25
Charitable Choice

Religious organizations have long been involved in provision of services to the communities they live in and work in.  Religious organizations working as government subcontractors are not new.   Catholic Charities , Lutheran Social Services, the Salvation Army , and the Jewish Welfare Federation  have long been indispensable sources of social aid.  For almost 40 years there have been collaborative service agreements between the government and sectarian organizations.  Catholic Charities, United Jewish Communities and others who have provided welfare services, maintained proper procedures in accounting to ensure the separation of church and state/federal funding.  These religious organizations put in place safeguards to protect the integrity of the religious organization, as well as the interests of state/federal taxpayers.  These religious organizations did not contract directly with the government; rather, religious institutions created separate entities (usually 501(c)(3) organizations) to handle public funds, and they did not incorporate religion into the publicly-funded program.  For large religious organizations, such as Catholic Charities U.S.A., the government money has been a large or even major portion of their budget.  

The new Faith-based initiatives paved the way for a political system which delegates social welfare responsibilities to newly-affiliated organizations       (some from the religious right) with which it forges privatized partnerships.  The strategy redistributes federal funding for social services from government functions where accountability had been fairly established and allocates funds to newer programs expected to bridge gaps in service/funds by being more cost-effective.  This places a greater burden on the former, established Faith-based community to become competitive bidders for their programs, increasingly subject to changes and cuts in government funding.

There is criticism that the proponents of new public-religious partnerships may be motivated by something other than a desire better to meet the social service needs of the country.   This debate has been partially driven by political and ideological concerns beyond the desire to help the poor. These concerns persist, notwithstanding the fact that improving social service provision is the public justification offered by former President Bush’s for charitable choice partnerships with pervasively sectarian organizations.

Charitable Choice was introduced during the mid-1990s after congressional committees devised alternate ways to address the burdensome welfare system. The Charitable Choice laws applied to four Federal programs: Temporary Assistance to Needy Families (TANF) and the Community Services Block Grant (CSBG) programs (both overseen by the Administration for Children and Families at the United States Department of Health and Human Services (HHS)); programs for substance abuse and mental health (overseen by the Substance Abuse and Mental Health Services Administration (SAMHSA) at HHS); and the Welfare-to-Work program (overseen by the Department of Labor).  

It is viewed with concern by some who fear that it will end public provision of social services and a welfare support system that many Americans in need depend on.  Charitable Choice strategy success requires that non-government social service providers will find the social services demand possible to meet. The increased burden of government regulation and competing demands for a charitable organization’s resources might cause mission displacement and have a negative impact on congregations.  A new dependence on government funds could result in decreased donations given to the charitable organization based on the presumed receipt of public funds.  Public perception is not necessarily in sync with legislative intent.  The premise behind Charitable Choice is that it relies on the market model with an emphasis on customers rather than citizens.  The goals of a democratic government are more than to simply respond to its citizens as customers.  There can be a potential for religious bias or discrimination by particular Faith-based contractors against needy citizen-clients who do not share common beliefs. There could also be bias in the grant of government contracts because effective oversight is difficult given the many different players at various levels of government.  

Many civil rights watchdog organizations warned that Charitable Choice blurred the boundaries between church and state.     Faith-based initiatives were policies based on concepts of fiscal conservatism, decreased size of the federal government, facilitated collaboration and cooperation in forged partnership with the religious community.  Thus, through this new legislative policy, Charitable Choice authorized a change for the way in which the church and state interact.  Conservatives find these Faith-based initiatives appealing because they want to decrease the size of government. They see the initiatives as an inexpensive alternative to government-sponsored social services.  Cuts in government funding result in a greater burden placed on the Faith-based community to take up the slack.    

The Charitable Choice concepts of indirect funding and neutrality principle   appear to promote a “black hole” for federal funds due to little transparency or oversight and little accountability to the taxpayer.  When private contractors are religious institutions they can claim constitutional protection against interference with free exercise of their religion.  The law currently exempts houses of worship from the full financial disclosure that is required from other non-profits when they are given tax-exempt status.  Thus when a church or religious institution receives public money to run welfare-to-work programs, it may legally assert a right to religious liberty and thus resist disclosing its financial records.  This may limit transparency regarding the dispersal of tax money to contracted service program providers and the government’s ability to assure honesty in provision of government contracted services.  A religious provider of job counseling, for example, could demand enough latitude to include prayer or Bible study in its programs, even if the government is directly contracting for the services.  Thus the government might be viewed as endorsing those religious practices, establishing them, or even coercing individuals in dire straits to engage in a particular religious practice.

The Charitable Choice program has been accused of giving preferential advantage to certain faith groups and endorsed them to receive federal grants. Constitutional concerns were raised in 2002 when President Bush issued Executive Order 13279, which facilitated churches and other Faith-based organizations to receive federal money by circumventing anti-discrimination laws.  This opened the door to bias in employment practices and service provision by Faith-based and Community Initiative programs paid for with Charitable Choice funding.  The Coalition Against Religious Discrimination (CARD)    warned that possible proselytism when federal funds are used could violate the First Amendment related to church-state relations. Many scholars believe that direct funding would compromise the religious rights of recipients, encourage intense competition among America's religions, create a divisive political and legal battle over whether government funds should ever pay for programs that discriminate in whom they hire, and harm religious entities by restricting their autonomy. Because of the lack of good options of social welfare programs in all areas, publicly funded vouchers may pressure people into religious activities that they would otherwise not choose.    

Privatization of welfare – due process & constitutional concerns  

In concert with diminished regulation over programs, the social safety net is vulnerable to exploitation.   Providing the safety net is a core public function which should remain responsive to democratic principles and accountable to elected officials. Although the government can contract out services, it cannot contract out the function of governing.

This privatization of welfare services leads to lack of adequate oversight in many jurisdictions when the organization that obtains the government grant subcontracts services to others, including private businesses. Thus, for-profit companies can be the entities that actually provide the in-field services. There is no provision for financial or service-quality oversight.  In theory, the contractors should police themselves and their subcontractors, but there is little profit incentive to do proper oversight.  

President George W. Bush’s Faith-based initiative intended to reduce the size of government, but not necessarily the amount spent.  His applied method shifted the responsibility for delivery of numerous social services from government agencies to newly-recognized, Faith-based organizations.  Privatization of welfare by delegation to contractors and subcontractors for service provision raises due process and accountability issues. Welfare programs involve provision of adequate food, adequate clothing, adequate shelter, and minimal preventive public health care.  Although the government has been viewed as the most obvious provider of these programs, faith-based programs have also frequently provided services to those in need.    But the government, which is elected and accountable to the citizenry, still accepts responsibility and accountability to see that social justice prevails and a decent chance at a reasonably healthy and active life can be provided for all citizens.

In 1997, the Texas Supreme Court   developed a test to evaluate the efficacy of delegation to private parties.  These guidelines are used to frame decisions about the scope of authority, accountability to the public and to federal authorities.  They identify the requisite expertise that qualifies a private entity to be a contractor.  

There is concern that private entities which contract to provide welfare services are not governed by constitutional constraints.  In other words, if a private contract provider of social services commits a wrongful action, the wronged person cannot invoke constitutional protections.  

The legal doctrine that defines “State Action” determines that a person who is a government actor and commits a wrongful act is subject to constitutional constraints.  State government and federal employees are clearly government actors, but private entities usually are not.  With government privatization contracts, authorization is transferred to private entities, but not “state actor” obligations.  Liability for actions is effectively diminished.  Privatization of contracts for welfare services permits autonomy without supervision or legal accountability.  Although there may be statutes in state or federal law that give the wronged person the opportunity to receive notice and obtain a hearing, these laws are generally not enforceable.  The courts have held that, unless there is a specific provision for enforcement, there will be no enforcement of these procedural rights.   The wronged person can sue under the third-party beneficiary principle - to compel compliance with the terms of the contract between the government and the private entity, but this is rarely successful.  

Contracts are often drawn up with the simple insertion of a provision in the contract that bars third-part lawsuits. Social service recipients are largely at the mercy of the political process to grant legal protection entitlements and due process rights.  They are also at the mercy of contracted parties to define and/or grant them contractual rights.  

Despite these constitutional and due process concerns, an increased number of government services are contracted out to private providers, which leaves clients with little or no recourse if their constitutional rights are violated.  Privatization may, in reality, simply replace a government bureaucracy with a private monopoly.    Most persons who oppose privatization are concerned about the negative outcomes it makes very possible.  

There is a human dimension to quality social services that is difficult to protect in an unregulated contractual arrangement. To relegate sensitive decisions to private organizations and companies that use market-based models is potentially a risk that is under-appreciated for its implications. Critical decisions that affect our society’s most vulnerable citizens can become based on short-term private incentives rather than long-term public interests.     Government authority may be unable to scrutinize the work of private entities adequately because of budgetary restrictions or unfamiliarity with contract management.  The lack of oversight could mean that the public is not assured that tax dollars awarded to government contractors will yield a privatized service that performs adequately.  

The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996   repealed Aid to Families with Dependent Children (AFDC), the federal cash assistance program, and replaced it with Temporary Assistance for Needy Families (TANF), a cash assistance program primarily operated by the individual states.  Prior to PRWORA, determination of which applicants qualified for federal benefits was performed by a public agency staff in civil service. (Title I, Section 104)  Under the new 1996 law,  however, TANF eligibility in Florida and Texas was contracted out to private organizations which were not directly accountable to public authority.

Privatization can be undermined by corruption if lucrative contracts are awarded to political allies, relatives or friends of public officials.  Many of these contractors are not qualified for the work or may cut corners to expand profits, especially when oversight is limited.  Contractors have been found to commit fraudulent and illegal practices, including:

• bid-rigging (arranges bids to be submitted by selected firms to limit real competition);
• low-ball bids (sets bids artificially low to win contracts, then subsequently raises fees excessively through tactics such as change orders);
• over-billing (charge too much, or charge for work not done).

These practices are difficult to prove, to monitor for and to investigate.  

Texas and Florida privatized functions to qualify clients for public benefits.  They closed public offices and set up call centers that use 2-1-1 information lines.  Staff employed by private contractors took initial client applications by telephone and if eligible, sent them to a public agency for final certification.  Private contractors employed by corporations determined whether an application was submitted to a public agency. Access to benefits under this system can be manipulated to maximize profit or can be awarded in a biased way.  The privatization of welfare eligibility determination, including food stamp and Medicaid coverage, represents a fundamental shift in delivery of social support to low-income populations. Large, for-profit corporations may have strong financial incentives to either turn away recipients or provide them with inadequate services.  Freedom of information and open records acts do not apply to private contractors.  This makes it difficult to determine how public funds were spent.

The use of subcontractors or outsourcing has often been used to abdicate social and moral responsibility.  There are significant legal, political and economic advantages to the perpetrator of human rights abuses, of using subcontractors, because it ultimately helps obscure the relationship between the perpetrator and the actual act.  It is a politically valuable device, because even if abuses are exposed, it will frequently look as if someone else (the contractor) was responsible.  This ultimately makes it difficult to hold a violator legally accountable and to be able to apply appropriate sanctions.  Thus the very effective human rights tactic of public shaming, in these circumstances, often becomes ineffective.  Outsourcing to contractors permits the perpetrators to ignore the societal norms and to conceal the perpetrators breach of those norms.  In addition, it legally protects perpetrators from both legal prosecution and embarrassment.  Subcontracting to corporations providing services such as prisons, healthcare and the military are particularly problematic, as in these settings there is reduced transparency to the public and less scrutiny by law enforcement.  Transnational corporations have enormous political and financial influence and power.  Health maintenance organizations and prisons use cost cutting methods which include using insufficiently trained, underpaid and over worked employees.  Rapid employee training and high turnover can lead to inadequate services in residential treatment centers, prisons, and other facilities.  When operated as a for profit business, cost reductions can lead to inadequate care, lack of adequate programming and abuse.  Outsourcing allows the perpetrator to not just abdicate responsibility but also assists the aggressor in maintaining a respectable public persona in the public eye. This often amounts to abuse of state-sanctioned power and authority.  Often outsourcing is presented to the public as necessary to cut costs. The use of subcontractors makes it more difficult to determine who is responsible for abuses and these cases are very complex.
 
  In fact, in the United States, seven of the largest religiously affiliated entities serve more than sixty million people with social services. Religiously affiliated entities tend to provide a wide range of social services comparable to those provided by government social service agencies. Many are professionally accredited through the Council on Accreditation of Services for Families and Children, Inc. Thus, they are held to the same standards as secular organizations.  See John McCarthy & Jim Castelli, “Nonprofit sector research fund, religion- sponsored social service providers: the not-so-independent sector” (Aspen Inst., Working Paper No. WP98-02, 1998); see also Michael W. McConnell, “ Religious Freedom at a Crossroads,” 59 U. CHI. L. REV. 115, 183 (1992); Ronald Thiemann et al., “Responsibilities and Risks for Faith-Based Organizations, in Who will provide? The changing role of religion in American social welfare” 51-70 (Mary Jo Bane et al. eds., 2000).

References and citations:

  Catholic Charities USA, “Who We Are,”  http://www.catholiccharitiesusa.org/who/ index.htm.

  The U.S. Salvation Army received thirteen percent of its fiscal year 200I funds from the government. Salvation Army USA Nat'l Headquarters, Annual Report (200I), available at http://www.salvationarmyusa.org.

  In 200I, United Jewish Communities received a federal grant of $59,868,000. CBBB Wise Giving Alliance, Charity Report United Jewish Communities (2002), available at http://www.give. org/reports/care2_dyn.asp.  “United Jewish Communities, About Us,” at http://www. ujc.org/aboutus_home.html.

  "Catholic Charities USA is the nation's largest, private network of social service organizations with I,400 local agencies and institutions providing essential services to more than 9.5 million people annually, regardless of their religious, racial, ethnic, or economic background." Letter from Catholic Charities USA to Senate and House Budget Committees (Feb. 26, 2000), at http://www.catholiccharities usa.org/programs/Advocacy/letters/Letters2001/budget1.htm.
 
Charitable Choice Funds, MissouriNet.com,  http:/ http://www.missourinet.com/2010/12/23/c ... wer-audio/.
 
 Sager, Rebecca, “Faith, Politics, and Power,” The Politics of Faith-Based Initiatives,  Oxford University Press, 2010, TheDivineConspiracy.org,  http://www.thedivineconspiracy.org/Z5242W.pdf.

  Stevenson, Dru, “Privatized Welfare and the Nondelegation Doctrine,” 35 Clearinghouse Rev. 546 (2001-2002) Jan-Feb 2002. http://heinonline.org/HOL/LandingPage?c ... 4&id=&page.

  Gedicks, Frederick Mark, “A two-track theory of the establishment clause,”
Establishment Clause doctrine has long been informed by two mutually antagonistic values: the separation of church and state, and government neutrality with respect to religion. There are conflicting values of both separation and neutrality which co-exist. The Speech Clause doctrine provides an absolute minimum of constitutional protection for expression against even content-neutral regulation, so also Establishment Clause doctrine provides for an absolute minimum of church-state separation against even religiously neutral government action. The Establishment Clause has long been thought to protect two values, the separation of religion and government from each other, and government neutrality with respect to religion. Separation requires that religion and government each refrain from involving itself in the affairs of the other. (Everson v. Board of Education).  Neutrality has not totally eclipsed separation, which is the more fundamental Establishment Clause value.  Neutrality requires that government regulate its interactions with religious individuals and institutions so that it neither encourages nor discourages religious beliefs or practices. (Epperson v. Arkansas). http://www.bc.edu/bc_org/avp/law/lwsch/ ... 03_FMS.htm.
 
  Minow, Martha, “Public and Private Partnerships: Accounting for the New Religion,” 116 Harvard Law Review. 1229, 1232-33 (2003).

  The Coalition Against Religious Discrimination (CARD) opposes charitable choice as an unconstitutional and dangerous proposal that will harm religion, authorize government-funded discrimination, undermine the accountability of taxpayer dollars, foster litigation against state and local governments, and violate the personal religious rights of Americans seeking help. See Coalition Against Religious Discrimination, What Is "Charitable Choice"?, at http://www.stop religiousdiscrimination.org/what is_charitable_choice.html. CARD includes many religious and nonreligious nonprofit organizations such as American Baptist Churches, USA; American Civil Liberties Union; American Jewish Committee; American Jewish Congress; Americans United for Separation of Church and State; Baptist Joint Committee on Public Affairs; Catholics for a Free Choice; Central Conference of American Rabbis; Friends Committee on National Legislation; Jewish Council for Public Affairs; Jewish Women International; NARAL Pro-Choice America; National Association for the Advancement of Colored People; National Association of Alcoholism and Drug Abuse Counselors; National Association of Social Workers; National Council of Jewish Women; National Education Association; National Gay and Lesbian Task Force; National Organization for Women; National Parent-Teacher Association; National Partnership for Women and Families; National Women's Law Center; People For the American Way; Planned Parenthood Federation of America; Rabbinical Assembly; Service Employees International Union, AFL-CIO; The Interfaith Alliance; Union of American Hebrew Congregations; Unitarian Universalist Association; United Church of Christ (Justice and Witness Ministries); and United Methodist Church (General Board of Church and Society). Coalition Against Religious Discrimination, About C.A.R.D., at http://www.stopreligiousdiscrimination. org/about_CARD.html.  More than 850 religious leaders signed a petition organized by CARD urging President Bush and Congress to reject charitable choice propos- als, explaining that the "flow of government dollars and the accountability for how those funds are used will inevitably undermine the independence and integrity of houses of worship." Coali- tion Against Religious Discrimination, An Open Letter to President Bush and Congress from America's Clergy (June 14, 2001), http://www.stopreligiousdiscrimination. ... rom_clergy. pdf; see also Press Release, Americans United, Religious Leaders Urge Bush, Congress To Reject "Faith-Based" Funding Proposals That Allow Discrimination, Entangle Religion and State” (Apr. 24, 2001), http://www.au.org/cardpressrelease.htm.

  Saperstein, David, “Public Accountability and Faith-Based Organizations: A Problem Best Avoided,” Harvard Law Review, Vol. 116, No. 5, (Mar., 2003), pp. 1353-1396, The Harvard Law Review Association, http://www.jstor.org/stable/1342729.

  Collins, Milton, “The Privatization of Social Service Programs,”
http://www.wlu.edu/documents/shepherd/a ... ollins.pdf.

  Tex. Boll Weevil Eradication Found., Inc. v. Lewellyn, 952 S.W.2d 454, 472 (Tex. 1997).  These  factors affect whether a government function can be delegated:    (1) are the private delegate's actions subject to meaningful review by a state agency or other branch of state government;( 2) are the persons affected by the private delegate's actions adequately represented in the decision process; (3) is the private delegate's power limited to making rules, or does the delegate also apply the law to particular individuals;(4) does the private delegate have a pecuniary or other personal interest that may conflict with his or her public function; (5)is the private delegate empowered to define criminal acts or impose criminal sanctions; (6)is the delegation narrow in duration, extent, and subject matter; (7)does the private delegate possess special qualifications or training for the task delegated to it; and (8) has the Legislature provided sufficient standards to guide the private delegate in its work. Although not all the factors relate to public assistance (notably three and five), the rest can, and are considered very instrumental to determine whether certain authority can have been delegated. http://www.supreme.courts.state.tx.us/e ... 048105.pdf.

  Freeman, Jody, 116 Harv. L. Rev. 1285, 1304-05 (2003).

  Estrin Gilman, Michele, “Legal Accountability in an Era of Privatized Welfare,”  81 Cal. L. Rev. 569, 611-12 (2001).

  Freeman, Jody,  “Extending Public Law Norms Through Privatization,” 116 Harv. L. Rev. 1285, 1300 (2003).

  Jody Freeman, “The Contracting State,” 28 Fla. St. U. L. Rev. 155, 170 (2000).  Persons concerned about the potential negative results associated with privatization are called  “consequentialists.”

  Diller, Matthew, Form and Substance in the Privatization of Poverty Programs, 49 UCLA L. Rev. 1739, 1740 (2002).

  Shue, Henry, Basic Rights: Subsistence, Influence, and U.S. Foreign Policy,p. 23, Princeton University Press (1996).

  Personal Responsibility and Work Opportunity Reconciliation Act of 1996, Pub.L.No. 104-193, 110 Stat. 2105.

  42 U.S.C § 604(a)

  Stevenson, Dru,  “Privatization of Welfare Services: Delegation by Commercial Contract:, 45 Ariz. L. Rev. 83, 88 (2003).

  “Safety Net for Sale: Dangers of Privatizing Social Services,”  American Federation of State, County and Municipal Employees, AFL-CIO,  1625 L Street, N.W., Washington, D.C. 20036-5687, Web site:www.afscme.org,
 Privatization Section, http://www.afscme.org/private/index.html

26
Establishment of alternative accreditation to evade inspections

In Florida and Texas, Teen Challenge centers were accredited by the Texas Association of Christian Child Care Agencies (TACCCA)   and the Florida Association of Christian Child Care Agencies (FACCCA).     In Florida, the heads of the Department of Children and Families and Department of Human Services were both former Straight, Inc. leaders.

West Florida Teen Challenge Boys’ Ranch in Bonifay, FL is a rigid program. The contract parents must sign states that the FACCCA intends to "insure the physical and spiritual health, safety, and wellbeing" of children and that the boys’ ranch must meet FACCCA’s "minimum standards." In the contract parents must agree to hold the ranch and its employees harmless from "any and all liability" for injury to the child, “even injury resulting in death.”  Parents must agree “that God desires that they resolve their dispute with one another within the church and that they be reconciled in their relationships in accordance with the principles stated in I Corinthians 6:1-8, Matthew 5:23-24, and Matthew 18:15-20.”  If they cannot resolve their disagreement privately within the church, parents must accept resolution through “biblically-based mediation” by rules of the Association of Christian Conciliation Services.   There is no refund of tuition or deposits if the boy leaves the ranch before 15 months, even if the ranch has expelled him. Many residential treatment centers were run with no insurance liability policies and these legal waivers were used to prevent liability lawsuits. Parents were told that, because they signed the waiver, they had no legal rights even if their child was injured.

Further protections through official State Liaison positions

To further insulate Teen Challenge from government regulation and oversight, Governor George W. Bush’s advisory board made recommendations that legislated creation of official state liaison positions in several key government entities. Texas was also the first state to create a formal Office of Faith-based and Community Initiatives (OFBCI).  These acts were part of larger cultural and structural shifts that redefined the boundaries between church and state in Texas.  An adviser was appointed by Governor Bush to change key agencies to alter their regulatory procedures and protocols to make them more receptive to Faith-based programs.  Appointees chosen were receptive to the new policies and assumed positions of power and authority on state governing boards.

In Texas, Governor Bush was closely allied with leaders of the evangelical community, such as Joe Loconte, Marvin Olasky, Stanley Carlson-Thies, and Carl Esbeck.  The Bush administration created far-reaching changes in state government policy. The state-level implementation of “Charitable Choice” did not create new funding for Faith-based organizations, but consisted of a symbolic alteration in the relationship between church and state that was manifest in laws, policies and procedural practices.

Bush’s policy team in Texas worked with Carlson-Thies and Esbeck, the chief architects of Charitable Choice as it passed through the U.S.A. Congress.  Both men went to Texas to help state agency heads understand the new law and to garner support for it there.  These changes in policy were then presented to the executive directors of the state agencies (TWC-Texas Workforce Commission, DHHS-Department of Health and Human Services, TEA—the Texas Education Agency) and to certain key board members of those agencies.  These pushed principles that Congress enacted in August 1996 as part of federal welfare reform. Texas added a “nondiscrimination” section in 1997 but did not label it as a Charitable Choice provision.  The early political goal was to change the government culture from within, but without use of confrontation of state legislators to embrace legislative changes.  Only ten states enacted 41 laws between 1996 and 2000 related to Faith-based initiatives.  Since then, there has been an increased legislation specifically focused on the initiatives.

In July, 1999, presidential-candidate Bush delivered his first major policy address in Indianapolis. There he unveiled his new pro-faith agenda and painted himself as a “new kind of Republican” politically and fiscally conservative, but supportive of Faith-based nonprofit organizations to deliver help to those in need.

After the 2000 election of President Bush, 230 additional laws on Faith-based initiatives were enacted, and now 31 states have enacted some legislation. Several states of note are New Jersey, Oklahoma and Florida.  In each of these states, G.W. Bush had close ties.  NJ Governor Christie Todd-Whitman was a close friend, as was OK Governor Francis Anthony "Frank" Keating.  Bush’s brother, Jeb Bush, was FL governor.  Jeb Bush sought increased legislation including Faith-based prison wings supported by a new government office. An OFBCI was established in Florida in 2004.

Establishment of funding to Faith-based programs

In January, 2001, President Bush created the White House Office of Faith-Based and Community Initiatives by Executive Order. Later Executive Orders created centers for the Office within the Departments of Justice, Labor, Health and Human Services (HHS), Housing and Urban Development, Education, and Agriculture, as well as at the Agency for International Development. Shortly thereafter, the Compassion Capital Fund (CCF) was established in 2001 through HHS and distributed almost $200 million dollars to various faith- and community-based organizations. Through a series of executive orders and the creation of separate Faith-based centers in 11 agencies and departments within the federal government, President Bush expanded Faith-based initiatives significantly from a political standpoint.  Some executive orders permitted religious organizations to discriminate in their hiring practices by making it possible for them to hire only those who share specific religious beliefs, despite the receipt of federal money.

President Bush actually promised $8 billion, during the campaign trail, but the Compassion Capital Fund fell dramatically short of that goal, leaving many that supported the Charitable Choice with added social responsibilities and no federal funding stream to cover expectations.  These Faith-based initiatives first obtained their support mainly from the evangelical churches, but later support came from various black churches and the Catholic Church.

Many in religious circles saw “Charitable Choice” as a means to allow the churches greater religious freedom while performing social services. Critics maintain that vast funding amounts were funneled to political allies and Christian organizations that had supported candidate Bush, such as Operation Blessing, a charity run by television evangelist Pat Robertson.  Political bias in the granting of federal funds appeared in the support given the InnerChange prison program. Governor G.W. Bush supported Chuck Colson’s prison ministry, which became a contract service provider to the Texas prison system.  Colson had years before been sent to prison for his involvement in the Watergate scandal.    Colson was also believed to be a member of the “Family” (also known as the Fellowship) and was a signer of the Manhattan Declaration.  

For many who politically supported the Faith-based initiatives these were just empty promises which did not increase funding for beleaguered and legitimate Faith-based social service programs. This was especially true for the smaller religious organizations, as they were still in competition with the larger, established, church-based providers, as well as community-based NGOs.  There was a smaller pot of federal funds actually available due to welfare budget cuts. Charitable Choice federal funding did not fix problems of poverty.  Instead, it seemed to benefit the chosen “politically correct” few. The shift of money in Faith-based programs moved from government-run welfare programs for the poor, serving minority, immigrant, migrant or disabled persons, to focus on upper- middle-class Christians with substance-abuse problems in unregulated private treatment centers.

The White House OFBCI sent letters to all state governors in 2002, 2004, and 2006, encouraging them to create their own OFBCIs.  There were no guidelines on how to establish the offices, or how to fund them, such that an unorganized program implementation resulted.   There are three primary means by which states have implemented the Faith-based initiatives:

1) Creation of liaison positions and/or offices,
2) Passage of legislation and administrative policies
3) Sponsorship of conferences

Three states have added Charitable Choice provisions to legislation. These are: Arizona (1999), California (1999), and Mississippi (2004). Since 1996, legislative appropriations processes in 16 states have offered some type of funding to Faith-based organizations (FBOs) or OFBCIs, leading to 42 separate appropriation bills which have allocated approximately $70 million. In 2007, a total of 10 appropriation laws were passed in 10 states, increasing overall funding for the initiatives. Florida passed appropriations bills directed to Faith-based and community groups for teenage pregnancy prevention programs, granting them $1,500,000 of non-recurring maternal block-grant trust funds.  New Jersey has allocated approximately $3 million a year since 1998.  Public money has been allocated to Faith-based groups, but the lack of standardized oversight once the funds are distributed is a concern, as is whether or not there is political bias in selection of recipients.

The vast majority of OFBCIs and related positions have been created administratively, and some states have given these positions greater permanence by enacting them with legislation. Kentucky (2005), Iowa (2004), Missouri (2007), Virginia (2002), Louisiana (2004), North Dakota (2005), Ohio (2005), Alaska (2007), and Maryland (2008) have created Faith-based legislative positions or OFBCIs by statute.

References and citations:?

  Texas Association of Christian Child Care Agencies Inc is located at 2000 16th St Garland, TX.
  Florida Association of Christian Child Care Agencies Inc is located at Lake City, FL.  http://www.faccca.com/Information.htm.

  Escobedo, Duwayne, “Secrets in the Schoolhouse,” InWeekly.Net.  It took 12 years for Rebecca Ramirez, 28 years old waves a sign that claims Michael Palmer, the founder of the all-girls boarding school, Victory Christian Academy, raped her when she was a 16-year-old student in 1992. The Victory Christian for $1,200 a month, offered parents a "faith-based" program that promises to help their rebellious and troubled daughters. Girls attending the school are sent by their parents for everything ranging from behavioral problems, drug abuse and depression. The courts in California shut him down when he refused to be licensed by the state. California authorities investigated a variety of complaints, including allegations of abuse. State authorities looked into the 1988 death of a 15-year-old girl, while she helped build a new part of the school. Her death was ruled an accident.   And in September, Mexican authorities closed Genesis-by-the-Sea, a similar school Palmer owns near Rosarito Beach, Mexico, after immigration and child abuse complaints. Some former students and parents say neglect and abuse happen, not only at Palmer's Victory Christian Academy, but other schools in Santa Rosa County and across the state that all belong to the same organization—Florida Association of Christian Child Caring Agencies.  FACCCA is a volunteer, non-profit group established by Florida law in 1984 that allows the private, faith-based schools to operate with little state oversight. Instead, they're monitored by FACCCA. FACCCA oversees about 31 schools, including New Beginnings, Rebekah Academy in Pace, run by Pastor Wiley Cameron and his wife, Faye. For years, the Camerons ran the Roloff Group homes in Corpus Christi, Texas. The homes provided strict, Bible-based education and training for troubled girls and boys, as well as some adults. http://www.inweekly.net/article.asp?artID=713.

   Association of Christian Conciliation Services.  P.O. Box 81130, Billings, Montana 59108, http://www.peacemaker.net/site/.
The Christian Concilliation Handbook on  alternative ADR
ccr4peace.org/CCRHandbookBound.doc

   Johnson, Byron R. and Larson, David B., “The InnerChange Freedom Initiative A Preliminary Evaluation of a Faith-Based Prison Program” Center for Research on Religion and Urban Civil Society, CRRUCS 2003 report. Publication year: 2003 | Cataloged on: Oct. 31, 2006. http://nicic.gov/Library/019041   The InnerChange Freedom Initiative (IFI), as it would later be named, was officially launched under the recommendation of then-governor George W. Bush. This was a public-private partnership between Texas Department of Criminal Justice (TDCJ) and Prison Fellowship (PF). It was referred to as the “Prison Fellowship’s ‘InnerChange’: Faith-Based Pre-Release Program.” Several months after the official start-up of the InnerChange Pre-Release Program, Prison Fellowship officially changed the name to the InnerChange Freedom Initiative (IFI).  The IFI program is different than other prison ministries in that it represents the first full-scale attempt to offer religious programs in a prison environment virtually “around-the-clock.” Prison Fellowship identifies itself as a not-for-profit, volunteer-reliant ministry whose mission is to “exhort, equip, and assist the Church in its ministry to prisoners, ex-prisoners, victims, and their families, and to promote biblical standards of justice in the criminal justice system.” Technically, IFI was launched at the Jester II Unit, which was renamed the Carol Vance Unit in 1999. Prison Fellowship’s costs to operate IFI in fiscal year 2000-2001 alone were $1.45 million. All inmates in the TDCJ system are transported to Huntsville and go through this prison when officially released on parole.  http://www.manhattan-institute.org/pdf/ ... change.pdf.

  Dickinson, William B.; Mercer Cross, Barry Polsky (1973). Watergate: chronology of a crisis. 1. Washington D. C.: Congressional Quarterly Inc.. pp. 8 133 140 180 188. ISBN 0871870592. OCLC 20974031. This book is volume 1 of a two volume set. Both volumes share the same ISBN and Library of Congress call number, E859 .C62 1973.

  “Watergate Key Players,” Washington Post,  http://www.washingtonpost.com/wp-srv/on ... ayers.html

   “Manhattan Declaration: A Call of Christian Conscience,” Drafted on October 20, 2009, Released on November 20, 2009 http://demossnews.com/manhattandeclarat ... on_signers.

   “TIME: 25 Most Influential Evangelicals Photo Essay: Charles Colson,” Time Magazine, February 7, 2005, http://www.time.com/time/covers/1101050 ... say/5.html

27
I spoke with Frank La Rue of the UN office on Human Rights Defenders regarding the lack of action on the 2003 UN complaint brought by ISAC under article 22 - or CAT - Convention Against Torture.   The reason for the lack of enforcement of CAT by the UN on US soil was because the US asserted that the US Constitution and laws provide greater protection to the US people than would United Nations enforcement of the Declaration of Human Rights or UN enforcement of the treaties that the US has signed and ratified.  But I believe in my latest report just this past month to the UN, I provided sufficient evidence that the US does not protect constitutional protections for civil rights or human rights for children trapped in these residential treatment centers.  Thus I hope to bring to the attention of the UN and US authorities that we no longer as a nation can claim that we have greater protections guaranteed under the US Constitution and laws - especially as they are now applied.  We do not guarantee human rights protections when governmental contractors are employed or when governmental functions - such as the delivery of TANF food to the needy occurs under governmental grants through subcontractors.   These residential treatment centers have used TANF funds to keep their operations financially solvent while at the same time asserting religious exemption from governmental supervision and oversight.  TANF is currently funded through federal taxes and distributed through Title I (section 104) Charitable Choice provisions in the welfare act.  The Welfare Act of 1996 - Personal Responsibility and Work Opportunity Reconciliation Act was signed into law (PL 104-193) and contained these Charitable Choice provisions.

Thus I believe that the systematic abuse of persons in private NGO run residential treatment centers points clearly to the lack of human rights protections offered by the US Constitution and US law.  The US Supreme Court has refused to enforce human rights protections for persons in these facilities instead relying on religious exemption.  Thus the US Supreme Court has not fully abided by the terms of the CAT treaty to protect the human rights of persons in US jurisdiction.  I believe that this will allow us to assert Article 22 for our survivors/victims.

28
Tacitus' Realm / Use of torture - a mindset of governmental officials
« on: August 25, 2011, 04:08:06 PM »
The acceptance of torture as a means to an end is also a mindset held by the former Bush administration.  Please be aware of the excellent work being done by Attorney Kevin Zeese in this area. http://velvetrevolution.us/torture_lawyers/index.php

Several lawyers on his list of "Torture Lawyers" have connections to the research that I do about residential treatment abuse.   Most notably: Alberto Gonzales, Michael Chertoff and John Ashcroft.

Alberto Gonzales-Texas Bar http://velvetrevolution.us/torture_lawy ... t_1_VR.pdf

John Ashcroft-District of Columbia  http://velvetrevolution.us/torture_lawy ... pdfAcrobat (.pdf)

Michael Chertoff-District of Columbia Microsoft http://velvetrevolution.us/torture_lawy ... plaint.pdf

Torture is illegal under both United States and international law. The Constitution prohibits cruel and unusual punishment under the Eighth Amendment, and it states that treaties signed by the U.S. are the “supreme Law of the Land” under Article Six. The Geneva Convention and The Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment both prohibit torture and have been signed by the United States. These laws provide no exception for torture under any circumstances. Moreover, the United States Criminal Code prohibits both torture and war crimes, the latter which includes torture. The Army Field Manual prohibits the use of degrading treatment of detainees.

Despite this well-established law, under the Bush administration, torture was authorized by George Bush and kept secret using classified designations. The White House requested legal memoranda to support its use of torture and it received those authored by a host of attorneys, including John Yoo, Jay Bybee, and Stephen Bradbury. Attorneys who advised, counseled, consulted and supported those memoranda included Alberto Gonzales, John Ashcroft, Michael Chertoff, Alice Fisher, William Haynes II, Douglas Feith, Michael Mukasey, Timothy Flanigan, and David Addington.

Several of these memoranda have recently been released, and clearly demonstrate that these attorneys conspired to violate laws against torture and that their actions resulted in torture and death. Accordingly, these attorneys must be held accountable. We have asked the respective state bars to revoke the licenses of the foregoing attorneys for moral turpitude. They failed to show “respect for and obedience to the law, and respect for the rights of others,” and intentionally or recklessly failed to act competently, all in violation of legal Rules of Professional Conduct. Several attorneys failed to adequately supervise the work of subordinate attorneys and forwarded shoddy legal memoranda regarding the definition of torture to the White House and Department of Defense. These lawyers further acted incompetently by advising superiors to approve interrogation techniques that were in violation of U.S. and international law. They failed to support or uphold the U.S. Constitution, and the laws of the United States, and to maintain the respect due to the courts of justice and judicial officers, all in violation state bar rules.

29
Medical Whistleblower

Abuse and Neglect in U.S.A. Residential Treatment Centers:A Systemic Problem



Summary: Medical Whistleblower provides this preliminary report on the abuse and neglect of persons in residential treatment for “substance abuse” in the U.S.A.  There have been violations of human rights, lack of investigation, prosecution and punishment of the offenders.  This prevailing permissive environment has given de jure or de facto amnesty to those who violate human rights.  Starting in the 1970’s there were residential treatment facilities for teens that were found to be abusive.  The SEED, Straight Inc. and its derivatives, Roloff Homes, WWASPS and, more recently, Teen Challenge were adjudicated “guilty” of human rights abuses.  This report explores the ways these perpetrators of abuse have used the political system to protect themselves and exploit loopholes in the law to expand their network of abusive residential treatment facilities for youth.


US Congressional investigations don’t stop abusive rehab centers

A recent report by the US Congress revealed that there are significant problems in the “teen rehabilitation” industry, including a general lack of oversight and accountability. In 2009 there were Capitol Hill briefings related to abuse of teens in facilities run by WWASPS and other programs.   The US House, led by Congressman George Miller, conducted investigations by the Government Accountability Office (GAO) during the 110th Congress (2008).  These uncovered thousands of cases alleging child abuse and neglect since the early 1990’s at teen residential programs. Further, the investigation revealed that currently these programs are governed only by a weak patchwork of state and federal standards. A separate GAO report,    conducted at the committee’s request, found major gaps in the licensing and oversight of residential programs, including some programs not covered by any state licensing standards. GAO concluded that, without adequate oversight, “the well-being and civil rights of youth in some facilities will remain at risk.” State-reported data to the National Child Abuse and Neglect Data System in 2005 found that 34 states in the United States of America (USA) reported 1503 incidents of youth maltreatment by residential facility staff. Of the states surveyed by GAO, 28 reported at least one youth fatality in a residential facility in 2006. GAO concluded that both of these statistics understate the incidents of maltreatment and death. They emphasized that many facilities are outside the scope of this limited study and many still remain unregulated and uninspected.            

In 1971, the US Senate Judiciary Committee convened a sub-committee on constitutional rights under Senator Sam Ervin to investigate government's role in behavior modification. Senator Ervin's 650-page report was published in November 1974 under the title “Individual Rights and the Federal Role in Behavior Modification.”    

The US Congress previously examined problems in The SEED  and then in later residential treatment programs. These later substance abuse treatment programs were modeled on the Synanon program,  the SEED and Straight Inc.  Each time, the offending substance abuse treatment program was shut down.  However, new programs rapidly emerged with new legal identities to start the same kind of operation.  There are now even more programs reported to be abusive, despite numerous local, state and federal investigations.  Those who have been victimized in one of these facilities are frustrated and dismayed to realize that not even several US Congressional investigations can prevent the recurrence of the same kind of abuse.  Although Straight Inc. programs were closed, the governing principles remain a model for drug rehabilitation. It is a national disgrace that the abuse of children in residential centers has not stopped. Rather, governmental sanction hides its true nature from law enforcement and regulators.   Abusive teen rehabilitation centers are now more numerous and the industry remains unregulated by state or federal law.  

The list includes:
Synanon,    The SEED,Straight Inc. and its derivatives, WWASPS Rebekah /Roloff Homes,Straight Inc. program at Morgan Yacht
KIDS, Sea Org Refuge, CEDU Brown Schools and derivatives, Aspen Education Group,    Elan School, Ridge Creek School/Hidden Lake
Wilderness Programs, Weight Loss Programs,    Mission Mountain School, Public Sector Gulags, SAFE, Vision Quest,
Daytop Village, Lighthouse of Northwest Florida, Growing Together/L.I.F.E., Kids Helping Kids,   Straight Inc. by the Sea,   Hyde Schools

 
There are no adequate means to monitor these facilities for human rights abuses.  They have used political influence and power to prevent effective regulation and inspection of their facilities.  They deny Child Protective Services (CPS) access to investigate child abuse complaints.  

To understand the background, it is useful to trace development of public policy related to these residential treatment programs in order to recognize how they managed to evade public scrutiny and government control.  

On October 10-11, 2007, the U.S. House Committee on Education and Labor heard testimony about cases of child neglect and abuse.  Among cases investigated were the Catherine Freer Wilderness Therapy Programs, a private residential treatment facility in the Pacific Northwest.      

This problem is not limited to the United States of America.  These abusive methods have been exported to many countries in the world.  The Bergen KIDS program has been transplanted to Alberta, Canada as The Alberta Adolescent Recovery Centre (AARC).   The Alberta Adolescent Recovery Centre    is a drug abuse rehabilitation clinic for teenagers and adolescents in Calgary, Alberta, Canada.  AARC has been the subject of controversy in Canada over allegations of physical, emotional, and sexual abuse made by former patients. This has led to widespread protests against AARC, and calls for a government inquiry by Alberta's provincial New Democratic Party.  

US citizens had been transported over international boundaries and taken to facilities in Mexico such as Abundant Life.   The children were found to be abused there.  Mexican immigration officials of the Instituto National de Migracion (INM) raided the facilities and deported the children back to the U.S.A.  Mexican authorities cited immigration violations for the clients, and also immigration violations related to the staff of these facilities.  There was lack of proper municipal licensure of these facilities. They had not obtained the requisite approval of health and education authorities in Mexico.  In addition, the teen “clients” of these facilities described habitual mistreatment during their illegal detention. They were denied access to communication with persons outside the facilities.  In 2004, the Mexican government rounded up 590 US teenagers, who had been placed in institutions throughout Mexico, without proper immigration paperwork.  These children were considered “troubled teens” by their American parents.  They were sent to these locked facilities in a foreign country for treatment of problems with behavior and parental authority.

Teen Challenge has had numerous complaints and multiple investigations regarding abuse in their facilities. Although Teen Challenge is directly connected with Assemblies of God church through both management and financial connections, they attempt to hide this association when recruiting clients for their centers. Teen Challenge USA International is headquartered in Springfield, Missouri.   It has grown to include 231 locations in the United States, including residential programs and evangelical outreach centers. Teen Challenge, run by the Assemblies of God church, operates its own credit union located in Missouri.  Teen Challenge operates two organizations with international scope: Teen Challenge USA International and Teen Challenge Global. The Assemblies of God church operates Teen Challenge as an outreach program within its own centers in numerous countries. Teen Challenge Global operates in 87 countries with over 1,100 centers. Its headquarters are in Columbus, GA.  

Hon. George Miller, Chair of the Committee on Education and Labor in the U.S. House of Representatives initiated the legislation, Stop Child Abuse in Residential Programs for Teens Act of 2009 H.R. 911 (formerly H.R. 6358, H.R. 5876).  U.S. Representative Miller had received a shocking report from the Government Accountability Office (GAO) regarding abusive and neglectful treatment of children in residential programs.   The report also contained information about fraudulent practices of these institutions. Subsequent investigations and GAO reports indicate that there is a widespread problem of abuse in the residential treatment industry which has flourished due to a lack of government regulation, inspection and accountability.          

There was very disturbing testimony provided to the US Congress about the pervasiveness of the abuse and the failure to curb it by Health and Human Services or the Department of Justice.    Video tapes of those testimonies can be seen here.     After much discussion and deliberation The House of Representatives approved legislation to Stop Child Abuse in Teen Residential Programs.  The bill was intended to ensure that parents have information they need to keep their children safe.            

The U.S. Senate has not moved to act on the bill or to draft suitable legislation to stop further abusive practices in the teen residential treatment industry.

Human Rights Defenders and Mandated Reporters – No protections

Abuse of children and teens within residential treatment facilities, located in both the US and in other countries that are run by non-profit organizations legally based in the U.S.A., has occurred for more than four decades.  In spite of numerous reports from human rights defenders and mandated reporters, there have been no significant changes to stop the practice.  There are no protections for witnesses/victims/survivors or for their human rights defenders.  Mandated reporters of such human rights violations are more likely to lose their employment or be demoted, suffer personal and professional retaliation.    

There is an entrenched unwillingness within the US government to expose the root cause of the political tolerance for the deregulation, lack of inspection, lack of financial transparency and accountability, lack of law enforcement action to investigate these crimes, lack of appropriate prosecution of perpetrators, and lack of any punishment for the offenses.   The moral, ethical, and legal obligations to uphold human rights by US legislators, US Department of Justice officials, and even judges have not been fulfilled.  When they have permitted this course of conduct to continue for four decades, they are culpable for the egregious human rights violations that have occurred.

Victims/Survivors are left with no access to redress or reparations.  This systemic failure to protect children and young adults is a “crime against humanity” about which the US government has been fully informed, yet refused to prevent.  Criminal acts that have occurred in these treatment facilities include:

•   Murder (homicide)
•   Enslavement
•   Deportation or forcible transfer
•   Imprisonment or severe deprivation of physical liberty in violation of fundamental rules of international law
•   Torture
•   Rape, forced pregnancy, forced abortions
•   Persecution against persons not of Christian faith, especially those of Jewish faith
•   Persecution of persons who are gay, lesbian, bisexual or transgendered
•   Enforced disappearance of persons
•   Other inhumane acts that intentionally cause great suffering, or serious injury to body, to mental or physical health
•   Psychological, emotional, and sexual trauma leading to suicide.

These acts are crimes of serious concern to the international community as a whole. The number of suicides secondary to psychological and emotional trauma as well as sexual abuse of young teens trapped in these rehabilitation centers came to the attention of public health officials who monitor suicide rates.    Licensed medical professionals, psychologists, therapists, child protective services personnel, and other mandated reporters were obligated to report this sudden rise in suicide which was linked to a particular type of residential substance abuse treatment program.

Licensed medical professionals are morally and ethically obligated by their Hippocratic Oath to protect their patients’ safety.  Under US law and international standards of proper professional conduct, they are also Mandated Reporters of torture and abuse.  Licensed medical professionals are Defenders of Human Rights, the watchdogs for vulnerable patients in need of care.  The reality in many residential treatment centers is that “the fox is in charge of the hen house.”

Government oversight and the role of mandated reporters

The U.S. Department of Health and Human Services or state or local department of social and rehabilitation services  is often the agency doing the child abuse investigation, but their investigative officers do not have law enforcement powers and thus do not have experience nor authority to protect mandated reporters or whistleblowers from retaliation.

There is in the U.S.A. no governmental agency or organization empowered, mandated and authorized to defend mandated reporters from witness intimidation and retaliation directed against them personally and professionally.  The closest governmental office to possibly protecting mandated reporters – at least within federal service  – is the Office of Special Counsel within the Department of Justice.  

In the United States mandated reporters   are professionals who, in the ordinary course of their work and because they have regular contact with children, disabled persons, senior citizens, or other identified vulnerable populations, are required to report (or cause a report to be made) whenever financial, physical, sexual or other types of abuse has been observed or is suspected, or when there is evidence of neglect, knowledge of an incident, or an imminent risk of serious harm.  These persons are by statute defenders of human rights.  When reported abuse cases move forward into the investigation phase, perpetrators of abuse can usually readily determine the identity of the mandated reporter.  Thus mandated reporters, who are human rights defenders, may immediately experience retaliation.   In addition, because these abusive residential treatment centers are not licensed or regulated they do not abide by state standards regarding mandated reporting, they do not train staff about mandated reporting laws and the need to report abusive treatment and neglect.

RAINN   maintains a database of mandatory reporting regulations regarding children and the elderly by state, including who is required to report, standards of knowledge, definitions of a victim, to whom the report must be made, information required in the report, and regulations regarding timing and other procedures.  RAINN applied for funding through Charitable Choice during the former President Bush’s Administration only to be turned down for federal funding for their very important program that serves sexual assault and abuse survivors/victims.


The Office of Special Counsel and Scott Bloch

The OSC is an independent federal agency charged with safeguarding the merit-based employment system by protecting federal employees and applicants from prohibited personnel practices.  A critical role is protection of federal whistleblowers, whose efforts safeguard American citizens and taxpayers.  Bloch headed the OSC from 2004 through 2008.

In theory, as the Chief Counsel for the OSC, Bloch was responsible to investigate complaints related to waste, fraud and abuse, and to protect whistleblowers. Government employees, who report violations of the public trust, as well as illegal or dangerous activities, are known as whistleblowers.

Whistleblowers and Mandated Reporters (persons legally required to report certain violations by virtue of their employment and/or licensure) constitute our national alert system against serious threats to public safety and trust. Unfortunately, there has developed a tolerance for retaliation against a whistleblower by his or her management. Retaliation has occurred in the form of forced transfers, demotions, revocation of security clearances, and employment termination.  

Whistleblowers who experience retaliation expect to be able to go to the OSC to seek redress. The U.S. Office of Special Counsel is chartered to act independently. The OSC can force investigations into retaliation and/or misconduct that is reported by whistleblowers.  Under Scott Bloch, the officially-designated safe harbor at the OSC became a very unfriendly place to whistleblowers.  In fact, Bloch intentionally caused hundreds of whistleblower cases to be permanently destroyed without an investigation.

All whistleblower appeals of reported medical fraud, labor violations, prison abuse and child abuse cases handled directly by federal agencies would ultimately be placed (according to the established chain of command) in front of the Office of Special Counsel.  Scott Bloch came under criticism for alleged retaliation against his own employees and for closure of whistleblower cases without investigation.  Bloch summarily dismissed hundreds of whistleblower complaints, including any complaints about Teen Challenge and any other private NGO residential treatment centers.  The whistleblowers were in agencies such as Health and Human Services (HHS), Substance Abuse and Mental Health Administration (SAMSHA), National Institute on Drug Abuse (NIDA), Department of Labor, Federal Bureau of Prisons and the Food and Drug Administration (FDA).  Bloch closed cases that involved valid complaints by human rights defenders who were federal employees or whose complaints identified errant federal employees or contractors getting federal tax money.  

The OSC is charged to enforce the Hatch Act, which prohibits government employees from use of federal resources for political ends. The Special Counsel reports directly to the White House.  When staff expressed concerns for how Bloch handled cases, Bloch retaliated.  

Bloch eventually came under investigation himself for a variety of violations, including prohibited personnel practices and discrimination against the employees in his office.  Bloch purged more than 20% of his staff, many of whom were experienced career professionals with years of work with whistleblowers.

The survivors/victims of these abusive centers were concerned that Bloch, in his former Office of Faith-based and Community Initiatives (OFBCI) position, was responsible for failure to protect the human rights of U.S.A. citizens in the programs such as Teen Challenge that were funded by the OFBCI.  The safety of persons within these centers (which were exempt from government oversight and accountability) was not addressed by him during his tenure in the OSC.  The residential treatment centers were known to hire ex-convicts with convictions for sexual abuse of children, drug dealing, domestic violence and money laundering.  There had already been criminal investigations of labor abuse, credit card fraud, affinity fraud, TANF fraud as well as investigations into physical and sexual child abuse.  

During his leadership of the Task Force on Faith-based and Community Initiatives, Bloch turned a blind eye when Teen Challenge staff were accused of abuse of minors and young adults, often based on discrimination against their religious beliefs or their sexual orientations.  

Attorney Bloch disrespected both U.S.A. federal and international law when he dismissed whistleblowers’ complaints about child abuse and other serious concerns for the public health and welfare without investigation, thus enabling human rights violations to continue.  Bloch showed a troubling disregard for international laws against torture, for the legal rights of children and adults, and for the long term adverse consequences to the victims/survivors, whistleblowers, and human rights defenders.

When the individual whistleblowers and mandated reporters (who form the only tangible defense against human rights violations) are betrayed by the system they must report to, we cannot protect civil rights or human rights.  When retaliation is the reward for meeting one’s legal duty and there is no valid entity to receive reports, there is an erosion of constitutional protections for every American’s human rights.

On April 27, 2010 Bloch pled guilty to criminal contempt of Congress for, according to the U.S. Attorney, "willfully and unlawfully withholding pertinent information from a House committee investigating his decision to have several government computers wiped ...."  Bloch pled guilty and faced a minimal jail sentence of one month.   Bloch admitted as part of his guilty plea that he withheld information from the congressional staff; that before he ordered the wipe of the computers, he understood the procedure would make it virtually impossible to recover deleted files or e-mails.  Bloch was informed he would serve jail time and asked the judge to withdraw his guilty plea to avoid mandatory jail time.  Bloch stated in a court filing that he did not know when he pled guilty to a misdemeanor charge of criminal contempt of Congress that he would face a minimum of a month behind bars.  This would seem to indicate that he views himself above the law, while his neglect of duty resulted in critical violations of human rights for vulnerable children and adults.

Many felt that the 30-day prison sentence imposed by United States Magistrate Judge, Judge Deborah A. Robinson, was too light of a punishment and that prosecutors had failed to properly charge him. Bloch was prosecuted only for one count of criminal contempt of Congress - a misdemeanor.  Whistleblowers felt he should have been charged with perjury, obstruction of justice and destruction of evidence.   However, aided and abetted by government prosecutors and a federal judge, Bloch managed to avoid serving any part of that sentence.  On August 3, 2011, Chief U.S. District Judge Royce C. Lamberth allowed Bloch to withdraw his guilty plea.

Scott Bloch’s Plea Agreement  

Judge denies Scott Bloch’s right to appeal sentencing verdict 3-29-11

Judges order is stayed pending appeal in Scott Bloch case March 10, 2011

Bloch’s DOJ press release 4-27-10  

Whistleblowers request special prosecutor in Scott Bloch case    



Due process & constitutional concerns  


These abusive residential treatment facilities are being in part federally funded through The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) “Charitable Choice” legislation and the use of subcontracting. These private residential treatment centers use federal funds as contractors under block grants such as Temporary Assistance for Needy Families (TANF) and also sometimes utilize Medicaid/Medicare funds.  Exempt from local, state and federal inspections and licensing requirements, these facilities do not train staff to report abuse and neglect to governmental authorities. They do not submit to governmental inspection. These residential treatment facilities do not protect constitutional civil liberties and instead insist that they have religious exemption from constitutional restrictions on their conduct.

The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996 repealed Aid to Families with Dependent Children (AFDC), the federal cash assistance program, and replaced it with Temporary Assistance for Needy Families (TANF), a cash assistance program primarily operated by the individual states.  Prior to PRWORA, determination of which applicants qualified for federal benefits was performed by a public agency staff in civil service. (Title I, Section 104)  President George W. Bush’s “Charitable Choice” Faith-based initiative was intended to reduce the size of government, but not necessarily the amount spent.  His applied method shifted the responsibility for delivery of numerous social services from government agencies to newly-recognized, Faith-based organizations.  

Privatization of social services by delegation to contractors and subcontractors for service provision raises due process and accountability issues. Social service programs involve provision of adequate food, adequate clothing, adequate shelter, and minimal preventive public health care.  Although the government has been viewed as the most obvious provider of these programs, faith-based programs have also frequently provided services to those in need including residential treatment.    

The use of subcontractors or outsourcing has often been used to abdicate social and moral responsibility.  There are significant legal, political and economic advantages to the perpetrator of human rights abuses, of using subcontractors, because it ultimately helps obscure the relationship between the perpetrator and the actual act.  It is a politically valuable device, because even if abuses are exposed, it will frequently look as if someone else (the contractor) was responsible.  This ultimately makes it difficult to hold a violator legally accountable and to be able to apply appropriate sanctions.  Thus the very effective human rights tactic of public shaming, in these circumstances, often becomes ineffective.  Outsourcing to contractors permits the perpetrators to ignore the societal norms and to conceal the perpetrators breach of those norms.  In addition, it legally protects perpetrators from both legal prosecution and embarrassment.  Subcontracting to corporations providing services such as prisons, healthcare and the military are particularly problematic, as in these settings there is reduced transparency to the public and less scrutiny by law enforcement.  When operated as a for profit business, cost reductions can lead to inadequate care, lack of adequate programming and abuse.  Outsourcing allows the perpetrator to not just abdicate responsibility but also assists the aggressor in maintaining a respectable public persona in the public eye. This often amounts to abuse of state-sanctioned power and authority.  Often outsourcing is presented to the public as necessary to cut costs. The use of subcontractors makes it more difficult to determine who is responsible for abuses and these cases are very complex.

Although the government can contract out services, it cannot contract out the function of governing or the responsibility for doing so.  Providing the safety net is a core public function which should remain responsive to democratic principles and accountable to elected officials. The government, which is elected and accountable to the citizenry, still is responsible and accountable to see that social justice prevails and a decent chance at a reasonably healthy and active life can be provided for all citizens.  

In concert with diminished regulation over federally funded programs, the social safety net is vulnerable to exploitation.  The privatization of social services such as residential treatment can lead to a lack of adequate financial or service-quality oversight for contractors.  In theory, the contractors should police themselves and their subcontractors, but there is little profit incentive to do proper oversight.  

Private entities which provide services paid by the federal or state government are not governed by constitutional constraints.  In other words, if a private contract provider of social services commits a wrongful action, the wronged person cannot invoke constitutional protections. The legal doctrine that defines “State Action” determines that a person who is a government actor and commits a wrongful act is subject to constitutional constraints.  State government and federal employees are clearly government actors, but private entities usually are not.  With government privatization contracts, authorization is transferred to private entities, but not “state actor” obligations.  Liability for actions is effectively diminished.  Privatization of contracts for welfare services permits autonomy without supervision or legal accountability.  Although there may be statutes in state or federal law that give the wronged person the opportunity to receive notice and obtain a hearing, these laws are generally not enforceable.  The courts have held that, unless there is a specific provision for enforcement, there will be no enforcement of these procedural rights.   The wronged person can sue under the third-party beneficiary principle - to compel compliance with the terms of the contract between the government and the private entity, but this is rarely successful.  

Contracts are often drawn up with the simple insertion of a provision in the contract that bars third-part lawsuits. Social service recipients are largely at the mercy of the political process to grant legal protection entitlements and due process rights.  They are also at the mercy of contracted parties to define and/or grant them contractual rights.  

Despite these constitutional and due process concerns, an increased number of government services are now contracted out to private providers, which leaves clients with little or no recourse if their constitutional rights are violated.  Privatization may, in reality, simply replace a government bureaucracy with a private monopoly.      

Critical decisions that affect our society’s most vulnerable citizens can become based on short-term private incentives rather than long-term public interests.     Government authority may be unable to scrutinize the work of private entities adequately because of budgetary restrictions or unfamiliarity with contract management.  The lack of oversight could mean that the public is not assured that tax dollars awarded to government contractors will yield a privatized service that performs adequately or that contractors do not abuse clients human rights.

Privatization can be undermined by corruption if lucrative contracts are awarded to political allies, relatives or friends of public officials.  Many of these contractors are not qualified for the work or may cut corners to expand profits, especially when oversight is limited.  Contractors have been found to commit fraudulent and illegal practices. These practices are difficult to prove, to monitor for and to investigate.   Freedom of information and open records acts do not apply to private contractors.  This makes it difficult to determine how public funds were spent.   It also makes it nearly impossible to track human rights violators and hold them accountable for their actions.


We must stop client abuse in residential treatment

The survivor/victims of residential treatment center abuse need to feel that the government of the U.S.A. will create effective measures to stop the violations, to verify facts, and to provide public disclosure of the full truth. This abuse still occurs in worldwide in violation of international treaty obligations, international law, the Helsinki Declaration and the Nuremberg Code.  There has been no cogent effort to reduce the risk or address the harm caused. Effective regulatory control over residential treatment centers and wilderness camps is immediately required.  The infractions identified are gross violations of international human rights law and serious violations of international humanitarian law, which need guarantees of non-repetition.

There must be denial of de jure or de facto amnesty to the human rights violators and they should be required to make effective and adequate reparations to the survivors/victims of this institutional child abuse.  Many victims, including but not limited to those abused in Straight Inc., Roloff Homes, Teen Challenge and WWASPS programs, desire a public apology that includes acknowledgment of the facts and acceptance of responsibility because the U.S. government knew of the abuse but failed to protect the children.

To stop further abuse of children and teens in residential programs, the U.S.A. must identify the persons and practices that enable this activity to flourish. We must deny the perpetrators’ access to grant money and political power.  

The federal government must retain legislative powers that permit regulation and inspection of all residential treatment facilities, regardless of whether they are private NGO facilities, federal or state subcontractors.  This is necessary to assure protection of the human rights of persons inside such facilities.  It is a national obligation under international human rights law.

Much information is already available through several U.S. Congressional investigations.  The most recent exposure was done by the House Education and Labor Committee, chaired by Rep. George Miller.  Important legislation like H.R. 911: “Stop Child Abuse in Residential Programs for Teens Act of 2009” passed the U.S. House of Representatives on Feb 23, 2009; it has not yet received any real action in the U.S. Senate.  This act was “To require certain standards and enforcement provisions to prevent child abuse and neglect in residential programs, and for other purposes.”   The U.S. Senate should be strongly encouraged to pass this legislation.

The United States must look carefully at provisions in federal and state laws that perpetuate a lack of transparency and accountability for residential facilities. The Charitable Choice program must be carefully scrutinized to see that it does not fund programs that violate civil rights and human rights.  Non-government organizations (NGOs) and corporations must be supervised to prevent use of government contractor status for unwarranted immunity if legal transgressions are committed.  Lack of accountability permits abuse.

These aberrant NGOs and other corporations constitute a “black hole” into which government funds are poured with ineffective outcomes, yet little transparency and accountability have been required of them.

Careful attention should be paid to ways in which a criminal element can invade religious non-profits and become able to compromise the safety of children, and exploit service provision and financial assets.  Persons with criminal records of sexual assault or sexual abuse should not have access to children or young people held in locked facilities.  Those with criminal records for substance abuse, violent crimes, or financial crimes should not have their records “expunged,” so that they qualify for unrestricted access to victims in new positions of authority over vulnerable persons.  White collar criminals capable of affinity fraud have been able exploit the naiveté and inexperience of church elders; thus, they are not a lesser risk as “restored” ex-convicts.  It is necessary to have government oversight to prevent and address abuse, especially in programs funded by taxpayers.

The United States, as part of the international community, should keep faith and human solidarity with victims, survivors and future human generations. Also, the U.S.A. must reaffirm the international legal principles of accountability, justice and the rule of law, Human Rights Law International and U.S. Law.


In Conclusion

The United States government cannot, at the present time, guarantee the protection of human rights for persons in private residential treatment centers funded through federal tax dollars. Persons abused or neglected in such facilities do not have constitutional protections or access to due process for reparations and redress for human rights violations. The lack of governmental regulation, licensing and inspection has led to multiple incidents of human rights violations, as well as lack of civil rights protections. Torture and degrading humiliating abuse is illegal under both United States and international law.  The Constitution prohibits cruel and unusual punishment under the Eighth Amendment, and it states that treaties signed by the U.S. are the “supreme Law of the Land” under Article Six.  The Geneva Convention and The Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment both prohibit torture and have been signed by the United States.  Thus the United States of America has both a duty and a legal obligation to stop further abuse in these private residential treatment facilities and to properly investigate and provide redress and reparations to the survivors/victims of this abuse.


See our website: http://medicalwhistleblowernetwork.jigsy.com

Sign our petitions: http://change.org/medicalwhistleblower/


References and citations:

  Washington, D.C., U.S.A., Capitol Hill Briefing - February 2009, Abuse of Youth in Residential Placements: A Call to Action, sponsored by the Alliance for the Safe, Therapeutic, and Appropriate Use of Residential Treatment on (ASTART) and co-sponsored by the Community Alliance for the Ethical Treatment of Youth (CAFETY), on Capitol Hill.  http://astart.fmhi.usf.edu/.
http://www.cafety.org/testimonies/732-u ... estimonies

http://www.cafety.org/testimonies/733-u ... estimonies

http://www.cafety.org/events/archives-c ... ry-19-2009.

  Final GAO Report on Residential Facilities (Full Report) (May 2008) Residential Facilities: Improved data and enhanced oversight would help safeguard the well-being of youth with behavioral and emotional challenges, Report to Committee on Education and Labor, House of Representatives [PDF, 95 pages]  GAO.gov, http://www.gao.gov/new.items/d08346.pdf.

  Final GAO Report on Residential Facilities (Highlights) (May 2008) Residential Facilities: Improved data and enhanced oversight would help safeguard the well-being of youth with behavioral and emotional challenges, Report to Committee on Education and Labor, House of Representatives [PDF, 1 pages] GAO.com, http://www.gao.gov/highlights/d08346high.pdf.

  GAO Report: Concerns Regarding Abuse and Death in Certain Programs for Troubled Youth (Full Report) (October 10, 2007) Full report of testimony before the Committee on Education and Labor, House of Representatives. [PDF, 38 pages]  GAO.gov, http://www.gao.gov/new.items/d08146t.pdf.

  Residential Facilities: State & Federal Oversight Gaps May Increase Risk to Youth (Highlights) (April 24, 2008) Highlights of the report by Government Accountability Office of testimony before the Committee on Education and Labor, House of Representatives [PDF, 1 pages], GAO.gov, http://www.gao.gov/highlights/d08696thigh.pdf.

  Residential Facilities: State & Federal Oversight Gaps May Increase Risk to Youth Well-Being (April 24, 2008) Full report by the Government Accountability Office of testimony before the Committee on Education and Labor, House of Representatives [PDF, 21 pages], GAO.gov,  http://www.gao.gov/new.items/d08696t.pdf.

  Residential Programs: Selected Cases of Death, Abuse, and Deceptive Marketing (Full Report) (April 24, 2008) Full report of testimony before the Committee on Education and Labor, House of Representatives. [PDF, 24 pages].

  Individual Rights and the Federal Role in Behavior Modification – A Study Prepared by the Staff of the Subcommittee, Scribd.com,
  http://www.scribd.com/.../Individual-Ri ... bcommittee,  
 or obtained at NCJRS.gov http://www.ncjrs.gov/App/publications/A ... ?id=142690.

  TheStraights.com, Synanon Story, http://thestraights.com/theprogram/syna ... tm#theseed.

  The Seed, Inc. was founded in 1970 in Fort Lauderdale, Florida. Seed received a $1.8 million U.S. government grant from the National Institute on Drug Abuse (NIDA) soon after it opened. And the grant had been administered by the founding director of NIDA who also happened to be the second White House Drug Czar-Robert DuPont.  http://thestraights.com/images/seed-funding.gif  http://thestraights.com/images/seed-Ervin-brainwash.htm.
 
  Surviving Straight Inc.,  http://www.survivingstraightinc.com/Flo ... ombine.pdf
http://www.thestraights.com/articles/ru ... report.htm.

  Szalavitz, Maia “The Cult That Spawned the Tough-Love Teen Industry,”  Mother Jones,  August 20, 2007,  http://www.motherjones.com/news/feature ... ustry.html.

  CEDU Sued for Abuse and Fraud, International Survivors Action Committee, was at http://www.isaccorp.org/cedu/ceduabuse.pdf  but now see website SurvivingStraightInc.com,  http://www.survivingstraightinc.com.  

  Morgan, Fiona, “One big dysfunctional family: A former member of the Synanon cult recalls the ‘alternative lifestyle’ that shaped her, for better and worse,” Salon Magazine, March 29, 1999, http://www.rickross.com/reference/synanon/synanon2.html.

  Clark, Michael D.,  Her life with "One Big Brother,” San Jose Mercury News, March 19, 1999, http://www.rickross.com/reference/synanon/synanon4.html.

  Fager, Wesley, Where did it come from?, Synanon Church and the medical basis for the $traights, or Hoopla in Lake Havasu, by Wes Fager (c) 2000, http://thestraights.com/theprogram/synanon-story2.htm

  Wes Fager, “Has Operation PAR become the new treatment arm of Drug Free America Foundation? Or: 3 strikes and the 6th Circuit is out!,” TheStraights.net,  http://thestraights.net/articles/op-par-and-dfaf.htm.

  Szalavitz, Maia, “Why Jesus Is Not a Regulator,” American Prospect, April 8, 2001, Prospect.org,  
http://prospect.org/cs/articles?article ... _regulator.

  Catherine Freer Wilderness Therapy Program, 420 Southwest 3rd Avenue, Albany, OR 97321-2261.

  Catherine Freer Wilderness Therapy Programs responds to Congressional Hearings 11 OCT 2007 — Catherine Freer Wilderness Therapy Programs responds to the testimony before the U.S. House Committee on Education and Labor on "Cases of Child Neglect and Abuse at Private Residential Treatment Facilities."

  CBC News Canada.  “Alberta drug rehab centre abused us, former teen patients allege. Executive director calls them 'liars',” February 13, 2009, CBC News, The Fifth Estate CBC.Ca,  http://www.cbc.ca/news/canada/story/200 ... abuse.html

  The Alberta Adolescent Recovery Center, 303 Forge Road S.E. Calgary, AB T2H0S9.

  CBC, Canada,  http://www.cbc.calcanada/story/2009/032/la1b use.html.

  Guadalajara Reporter, Immigration Busts Lakeside Area Boarding School for Troubled Teens, Friday December 17, 2004, GuadalajaraReporter.com Guadalajara Reporter  +52 (33) 3615-2177 and+ 52 (33) 3615-0606.

  Teen Challenge Global Website, http://www.globaltc.org/.

  October 10, 2007 (first) GAO Report on Residential Treatment Programs, GAO.gov,  http://www.gao.gov/new.items/d08146t.pdf.

  May 14, 2008 – GAO Report Shows Need for Minimum Standards to Protect Teens in Residential Programs, Says Chairman Miller—Education & Labor Committee Will Vote Tomorrow on Legislation to Stop Child Abuse in Residential Programs, House.gov,  http://www.house.gov/apps/list/speech/e ... eport.html.

  May, 2008 – Residential Facilities – Improved Data and Enhanced Oversight Would Help Safeguard the Well-Being of Youth with Behavioral and Emotional Challenges, GAO.gov,  http://www.gao.gov/new.items/d08346.pdf.

  May, 2008 – Residential Facilities – Improved Data and Enhanced Oversight Would Help Safeguard the Well-Being of Youth with Behavioral and Emotional Challenges, GAO.gov,  http://www.gao.gov/new.items/d08346.pdf.

  October 10, 2007 – Also Residential Treatment Programs: Concerns Regarding Abuse and Death in Certain Programs for Troubled Youth GAO-08-146T, GAO.gov, http://www.gao.gov/products/GAO-08-146T.

  April 24, 2008 text of the day’s testimonies, GAO.gov, http://www.gao.gov/htext/d08713t.html.

  HR 5876 – “Stop Child Abuse in Residential Programs for Teens Act of 2008?, Several Videos regarding this legislation on You Tube, YouTube.com, http://youtu.be/YkmGgH11Dmk
http://youtu.be/z7PJBxwd7kc
http://youtu.be/dr47O5OjC_A .

  2008 Congressional Vote, Govtrack.us/congress, http://www.govtrack.us/congress/vote.xpd?vote=h2008-459.

  April, 2008 – 110th Congress – Growing and Strengthening America’s Middle Class (more info on this act), House.gov,  http://www.house.gov/ed_workforce/publi ... et0408.pdf.

  Legislation H.R. 6358 (formerly H.R. 5876) The  Bill, Thomas.loc.gov,  http://thomas.loc.gov/cgi-bin/bdquery/z?d110:h.r.06358:   Bill Passed, GovTrack.us/congress, http://www.govtrack.us/congress/vote.xpd?vote=h2008-459, govtrack.us,   http://www.govtrack.us/congress/vote.xpd?vote=h2008-459 Vote on HR 6358:  GovTrack.us/congress, http://www.govtrack.us/congress/vote.xpd?vote=h2008-459.

  June 25, 2008 – House Approves Legislation to Stop Child Abuse in Residential Programs, House.gov, http://www.house.gov/apps/list/speech/e ... 2508c.html.

  May 13, 2008 – The Gavel, Speaker.gov/blog, http://www.speaker.gov/blog/?p=1334.

  Smith, Angela, H.E.A.L., Provo Canyon School and similar programs use a harmful and ineffective program of behavior modification or "thought reform"/"brainwashing" to violate children in their "care". http://www.youtube.com/watch?v=GSjW2gh2 ... re=related.

  U.S. Department of Health and Human Services, Administration for Children and Families, Mandatory Reporters of Child Abuse and Neglect: Summary of State Laws, Child Welfare Information Gateway, April 2010,   http://www.childwelfare.gov/systemwide/ ... /manda.cfm.

  RAINN - (Rape Abuse and Incest National Network) RAINN, 2000 L Street NW, Suite 406, Washington, DC 20036, phone: +1- 202-544-1034, rachelg@rainn.org.  http://www.rainn.org/public-policy/lega ... g-database.

  United States v. Bloch, No. 10-0215M-01, 2011 WL 833641, UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA,  US Magistrate Judge Deborah A. Robinson

  Davis, Julia, “Former head of OSC Scott Bloch gets off scott free,” Examiner, Aug. 3, 2011, Examiner.com,  Former head of OSC Scott Bloch gets off scott-free - Los Angeles Homeland Security | Examiner.com http://www.examiner.com/homeland-securi ... z1U5SeXnxE.

  “Scott Bloch” Legal Times Typepad, LegalTimes.Typepad.com, http://legaltimes.typepad.com/files/dqu29000.pdf.
  Talking Points Memo “Judge denies Scott Bloch’s Request to Appeal Sentencing in Geek on Call Case”. Talkingpointsmemo.com,  http://www.talkingpointsmemo.com/docume ... php?page=1.

  Legal Times Typepad - Judge Deborah A. Robinson’s Order, LegalTimes.Typepad.com,  http://legaltimes.typepad.com/files/robinson_order.pdf.
  “Bloch Press Release 4-27-10,” Legal Times Typepad, LegalTimes.Typepad.com,  http://legaltimes.typepad.com/files/blo ... -27-10.pdf.

  TP Muckracker, “Open Letter from Community of Whistleblowers to Attorney Eric Holder,” February 2010, TalkingPointsMemo.com,  http://www.talkingpointsmemo.com/docume ... php?page=1.

  Freeman, Jody, 116 Harv. L. Rev. 1285, 1304-05 (2003).

  Estrin Gilman, Michele, “Legal Accountability in an Era of Privatized Welfare,”  81 Cal. L. Rev. 569, 611-12 (2001).

  Freeman, Jody,  “Extending Public Law Norms Through Privatization,” 116 Harv. L. Rev. 1285, 1300 (2003).

  Jody Freeman, “The Contracting State,” 28 Fla. St. U. L. Rev. 155, 170 (2000).  Persons concerned about the potential negative results associated with privatization are called  “consequentialists.”

  Diller, Matthew, Form and Substance in the Privatization of Poverty Programs, 49 UCLA L. Rev. 1739, 1740 (2002).

  Shue, Henry, Basic Rights: Subsistence, Influence, and U.S. Foreign Policy,p. 23, Princeton University Press (1996).

  Stevenson, Dru,  “Privatization of Welfare Services: Delegation by Commercial Contract:, 45 Ariz. L. Rev. 83, 88 (2003).

  “Safety Net for Sale: Dangers of Privatizing Social Services,”  American Federation of State, County and Municipal Employees, AFL-CIO,  1625 L Street, N.W., Washington, D.C. 20036-5687, Web site:www.afscme.org,
 Privatization Section, http://www.afscme.org/private/index.html

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30
In 1985 the Semblers feared civil suits by abuse victims and possible criminal prosecution. They changed the mission of Straight, Inc. from “treatment” to “education” and its name from “Straight, Inc.” to “Straight Foundation, Inc.”  Although it may have appeared to close in 1993, the Straight Inc. program continued instead under the guise of the Pathway Family Center and also gave rise to many other derivative residential treatment programs.  In 1995, Betty Sembler changed the name of the educational foundation again to the Drug Free America Foundation (DFAF).  They changed the corporate mission to be a guide for companies to set up drug-free workplace environments, and they obtained a federal grant.  The name was changed to Drug Free America Foundation and another mission was added: to establish national and international drug policy.  

Drug Free America Foundation Inc., 5999 Central Ave Ste 301, St Petersburg , FL 33710 Web Address: http://www.dfaf.org,  DFAF states that it does Mental Health, Crisis Intervention / (Alcohol, Drug and Substance Abuse, Dependency Prevention and Treatment). Year Founded: 1978????, Mission statement: To Prevent Drug Abuse and promote awareness through education.

Today, Straight Inc. has morphed into an organization called the Drug Free America Foundation (DFAF), specialized to help small businesses set up drug-free workplaces, and to promote national and international drug policy.  Working with such federal programs as Ready4Work,  DFAF still dominates the drug rehabilitation and re-entry social welfare programs.  Through the DFAF and other think tanks such as the American Enterprise Institute,   Melvin Sembler continues to influence drug policy in this country by promoting public policy that allows coercive and abusive treatment methods.

Ready4Work is a nationally recognized program assisting ex-offenders with re-entry into the community and workforce, effectively leading participants toward a productive life.  Operating with a four-pronged approach; case management, life-coaching, job training and job placement assistance, Ready4Work motivates and moves individuals to become productive, responsible citizens within the community. Commitments and strategic partnerships with faith-based organizations, local businesses, community outlets and the judicial system assist to ensure individuals transition successfully back into the community.  This collaborative effort means that DFAF policy permeates the welfare to work programs and that persons with ties to DFAF influence and sometimes control these policy choices.  

In 2003, President George W. Bush selected Operation New Hope as the pilot site for the Ready4Work program.  Applauded by President Bill Clinton in his book, “Giving,” and endorsed by President Barack Obama, Ready4Work is considered by many to be a model program for the nation.  Other supporters include current and former City of Jacksonville leaders Mayor John Peyton, Sheriff John Rutherford, Sheriff Nat Glover and former U.S. Secretary of Labor Elaine Chao. http://www.operationnewhope.com/ready4work/

Melvin Sembler is on the board of the AEI or  American Enterprise Institute for Public Policy Research, 1150 Seventeenth Street, N.W., Washington, D.C. 20036.  The American Enterprise Institute for Public Policy Research (AEI) is a conservative think tank.   As an independent non-profit organization it is primarily supported by grants and contributions from foundations, corporations, and individuals.  Its headquarters are in Washington, D.C. Some AEI scholars are considered to be among the leading architects of the second Bush administration's public policy.  More than twenty AEI scholars and fellows served either in a Bush administration policy post or on one of the many governmental panels and commissions. AEI.org, http://www.aei.org/.
Board of Trustees
 

AEI is governed by a Board of Trustees, composed of leading business and financial executives.

Kevin B. Rollins, Chairman
Senior Adviser
TPG Capital

Tully M. Friedman, Vice Chairman
Chairman and CEO
Friedman Fleischer & Lowe, LLC

Gordon M. Binder
Managing Director
Coastview Capital, LLC

Arthur C. Brooks
President
American Enterprise Institute

The Honorable Richard B. Cheney

Harlan Crow
Chairman and CEO
Crow Holdings

Daniel A. D'Aniello
Co-Founder and Managing Director

The Carlyle Group
 

Note: The Carlyle Group is a global asset management firm, specializing in private equity, based in Washington, D.C. The Carlyle Group operates in four business areas: corporate private equity, real assets, market strategies and fund-of-funds, through its AlpInvest subsidiary. In its 2010 annual report, Carlyle reported assets in excess of $150 billion under management diversified over 84 distinct funds. The firm employs more than 890 employees, including 495 investment professionals, in 20 countries with offices in the Americas, Europe, Asia, and Australia, and its portfolio companies employ more than 415,000 people worldwide. The firm has over 1,300 investment partners in 71 countries.  Carlyle Group  controls the patent on the Anthrax vaccine, which was given to military personnel and public health workers when the US Congress was mailed the Anthrax letters.   Carlyle has been involved in the development of that vaccine since the 1980's -  in facilities in South Africa.    The vaccine had not successfully gone through the approval process with the FDA prior to its use on active military personnel during the "crisis" of the anthrax biological terrorist attack.  The government contract to vaccinate was very lucrative.  Carlyle Group is a huge investment bank - has no public stock and is a privately owned entity and thus its corporate decisions are not open to public scrutiny. Carlyle Group has close ties to the Bush family.  Carlyle Group is a major arms dealer and defense contractor.

John V. Faraci
Chairman and CEO
International Paper Company

Christopher B. Galvin
Chairman
Harrison Street Capital, LLC

Raymond V. Gilmartin
Harvard Business School

Harvey Golub
Chairman and CEO, Retired
American Express Company ( American Express handles the shipping of urine samples for drug testing to the testing laboratories of the Drug Proof company)

Note: Drug Proof does all testing for the Department of Transportation in Seattle and  in many other US cities. Drug Proof does testing of all "impaired doctors" for the Washington Physicians Health Program, and also testing of police officers in the King County Police Department.  Nationwide Drug Proof, a Canadian based company, has cornered the market for drug testing for municipalities - because all testing companies must be approved and listed in the federal public registrar - few are listed and Drug Proof is by far the largest company doing the drug testing for most municipal governments in the U.S.A.)

Robert F. Greenhill
Founder and Chairman
Greenhill & Co. Inc.

Frank J. Hanna
Hanna Capital, LLC

Bruce Kovner
Chairman
Caxton Associates, LP

Marc S. Lipschultz
Partner
Kohlberg Kravis Roberts & Co.

John A. Luke Jr.
Chairman and CEO
MeadWestvaco Corporation

Robert A. Pritzker
President and CEO
Colson Associates, Inc.

J. Peter Ricketts
President and Director
Platte Institute for Economic Research, Inc.

Edward B. Rust Jr.
Chairman and CEO
State Farm Insurance Companies

D. Gideon Searle
Managing Partner
The Serafin Group, LLC

Mel Sembler
Founder and Chairman
The Sembler Company


Wilson H. Taylor
Chairman Emeritus
CIGNA Corporation

William H. Walton
Managing Member
Rockpoint Group, LLC

William L. Walton
Rappahannock Ventures LLC

Marilyn Ware
Ware Family Office

James Q. Wilson
Boston College Pepperdine University

 
AIE Emeritus Trustees

    Willard C. Butcher
    Richard B. Madden
    Robert H. Malott
    Paul W. McCracken
    Paul F. Oreffice
    Henry Wendt

AIE Officers
 

Arthur C. Brooks
President

David Gerson
Executive Vice President

Jason Bertsch
Vice President, Development

Henry Olsen
Vice President, Director of the National Research Initiative

Danielle Pletka
Vice President, Foreign and Defense Policy Studies
 
Council of Academic Advisers
 


AEI's Council of Academic Advisers, chaired by political scientist James Q. Wilson and including distinguished academics from a variety of policy-related fields, advises AEI's president on the Institute's research agenda, publications, and appointments, and each year selects the recipient of the Irving Kristol Award.

James Q. Wilson, Chairman
Boston College and Pepperdine University

Alan J. Auerbach
Robert D. Burch Professor of Economics and Law
University of California, Berkeley

Eliot Cohen
Paul H. Nitze School of Advanced International Studies
Johns Hopkins University

Martin Feldstein
George F. Baker Professor of Economics
Harvard University

Robert P. George
McCormick Professor of Jurisprudence
Director, James Madison Program in American Ideals and Institutions
Princeton University

Gertrude Himmelfarb
Distinguished Professor of History Emeritus
City University of New York

R. Glenn Hubbard
Dean and Russell L. Carson Professor of Finance and Economics
Columbia Business School

John L. Palmer
University Professor and Dean Emeritus
Maxwell School of Citizenship and Public Affairs
Syracuse University

Sam Peltzman
Ralph and Dorothy Keller Distinguished Service Professor of Economics
Booth School of Business
University of Chicago

George L. Priest
John M. Olin Professor of Law and Economics
Yale Law School

Jeremy A. Rabkin
Professor of Law
George Mason University School of Law

Richard J. Zeckhauser
Frank Plumpton Ramsey Professor of Political Economy
Kennedy School of Government
Harvard University


In an effort to test all school children for drugs (often without their parents consent) and thus put them into a DFAF program,  the DFAF rolled out the Teen Screen and other programs testing children for drug use and screening for mental illness.  The case below shows the influence of the DFAF and the Drug and Alcohol Testing Industry Association (DATIA) which works with the DFAF to increase the use of psychotropic drugs on school children.  Most countries of the world -  even in Europe and other developed countries - only drug 1-2% of school age children (grades 1-12)  but in the U.S.A. - we drug now 20% and if the DATIA and DFAF have their way it would be many more children on life long psychiatric drugs (usually at the tax payers expense).

BOARD OF EDUC. OF INDEPENDENT SCHOOL DIST. NO. 92 OF POTTAWATOMIE COUNTY, OKLAHOMA Petitioner, v. EARLS.  June 27, 2002 These are the signers of the Amicus brief in support of drug testing.  The signers include: Drug Free America Foundation (DFAF);   Robert DuPont who is on DFAF's advisory board;  Peter Bensinger (Peter Bensinger is former head of the DEA and is the business partner with Robert DuPont);  Julie Murdoch, Esq. (an employee with Bensinger, DuPont & Associates);  Bensinger DuPont & Associates, Bethesda, MD;  Institute for Behavior & Health, Bethesda, MD (another Robert DuPont company); Institute on Global Drug Policy (a division of  DFAF);   Eric Voth, MD, Topeka, KS (but Dr. Voth is the director of DFAF's  Institute on Global Drug Policy);  Ambassador Melvyn Levitsky who has co-authored an article on drug policy with Dr. Eric Voth;  Donald Ian Macdonald, M.D. (Straight's former national research director turned White House Drug Czar); Stephanie Haynes of Save Our Society From Drugs TM,  (but SOS is a Betty Sembler foundation);  Legal Foundation Against Illicit Drugs (an organization founded by Calvina Fay, executive director of DFAF, and others);  Otto Hauswirth, M D, of the International Scientific and Medical Forum on Drug Addicts (DFAF's Calvina Fay is director the International Scientific and Medical Forum on Drug Abuse); Carolyn Burns, of Louisville, KY. DFAF's Calvina Fay is a board member and past president of  Drug Watch International (DWI).  DWI or its International Drug Strategy Institute division  includes or has included  Robert L. DuPont and  Peter Bensinger, Straight's former national research director Donald Ian Macdonald, Straight's former national clinical director Miller Newton and Straight-Springfield's former research director Dr. Richard Schwartz, MD. Straight's former national executive director Bill Oliver is an Honorary Advisor for DWI (he also became director of parent training for P.R.I.D.E.).  Joyce Tobias, formerly acting secretary for DWI, used to be a very active Straight parent.  Alex Romero, a DWI board member,  and Nancy Starr, a DWI delegate,  were signers.  And, of course, the Drug and Alcohol Testing Industry Association (DATIA) was a signer.  You may see the brief itself at this website: http://www.datia.org/resources/amicusbrief.htm.

See also:

Wes Fager, “Has Operation PAR become the new treatment arm of Drug Free America Foundation? Or: 3 strikes and the 6th Circuit is out!,” TheStraights.net,  http://thestraights.net/articles/op-par-and-dfaf.htm

The Influence of Straight, Inc. (Drug Free America Foundation) On National and International Drug Policy, thestraights.net,  http://www.thestraights.net/pickets/dfa ... -short.doc.

Drug Free America Foundation, formerly known as Straight, Inc. from 1976-1985.  DFAF is a 501(c)(3) non-profit organization.

Current DFAF Board of Directors
Betty S. Sembler, Chair
D. Jay Snyder, Esq., Legal Counsel/Vice Chair
James D. Sewell, Ph.D, Director
James W. Holton, Esq., Director
John E. Stross, Director
Joseph Garcia, Esq., Secretary
Kevin P. Kauffman, Director
Stuart Lasher, Treasurer
Walter P. Loebenberg, President/Vice Chair
William S. Jacobs, Jr., M.D., Director

Current DFAF Advisory Board
Aejandro Vassilaqui
Alfred Hoffman, Jr.
Ambassador Melvyn Levitsky
Andrew P. Thomas, Esq.
Christy McCampbell, Deputy Assistant US Department of State, INL
Clayton M. Wilcox, Ph.D., Former Superintendent Pinellas County Schools
Columba Bush, Former First Lady State of Florida (Jeb Bush’s wife)
Daniel Lungren, Esq., Former Attorney General
Darryl Ervin Rouson, Esq., State Representative/Former President NAACP
H. Lee Moffitt, Esq., Former Speaker Florida House of Representatives  


Current DFAF Special Advisors
David A. Gross, M.D., FAPA
David G. Evans, Esq.
Eric Voth, M.D., FACP
Ernest Aeschbach, M.D.
Stephanie Haynes


Another DFAF associated organization with worldwide influence is the Drug Prevention Network of the Americas.

  Drug Prevention Network of the Americas (DPNA), http://www.dpna.org/DPNA%20Calvina.html.

  Drug Watch International, Drug Watch International, P.O. Box 45218, Omaha, NE  68145-0218, USA,  http://www.drugwatch.org/.

Drug Watch International
BOARD OF DIRECTORS

John J. Coleman, Ph. D., Virginia, President
Mina Seinfeld de Carakushansky, Brazil, Vice President
Ed Moses, Missouri, Secretary
Susie Dugan, Nebraska, Treasurer
Heitor De Paola, M.D., Brazil
Lee Dogoloff, Delaware
Terrence P. Farley, Esq., New Jersey
Grainne Kenny, Ireland
Margaret L. Petito, Washington, DC
David Risley, Esq., Illinois
Alex J. Romero, Arizona
Wayne Roques, Florida
Geraldine Silverman, New Jersey
Joan Bellm, Founder and Honorary Director, Illinois
Board of Director Summary Bios

Drug Watch International
COUNCIL OF ADVISORS

Pat Barton, Florida
Daniel Bent, Esq., Hawaii
James M. Ch'ien, M.D., Hong Kong
Dr. Kachit Choopanya, Thailand
C. E. Edwards, Arizona
Chief Ruben Greenberg, South Carolina
Datuk Haji Idris Ibrahim, Dmsm Jsm, Malaysia
Jerry Johansen, Texas
Cliff Kincaid, Maryland
Lt. Col. (USA Ret.) Robert Maginnis, Washington, DC
Gabriel Nahas, M.D., Ph.D., New York
Fred J. Payne, MD, Louisiana
Bill Oliver, Georgia
Maggie Petito, Washington, D.C.
David Risley, Esq., Illinois
Arlene Seal, Ph.D., Pennsylvania
Padma Talcherkar, M.D., FAAP, Illinois


Drug Watch International:
International Drug Strategy Institute


The International Drug Strategy Institute is a group of physicians, attorneys, educators, law enforcement officials and drug prevention and treatment specialists who provide expertise on national and international drug strategies. The Institute pursues public policy on drug issues consistent with the mission and goals as established by Drug Watch International.  

Director, John J. Coleman (VA, USA)
Joseph E. Atchison, Ph.D. (FL, USA)
Joan Bellm (IL, USA)
William M. Bennett, M.D. (OR, USA)  
Peter Bensinger (IL, USA)
Daniel A. Bent, Esq. (HI, USA)
Vesta Boswell, (New Zealand)
Daniel Brookoff, M.D., Ph.D. (TN, USA)
Guy A. Cabral, Ph.D. (VA,USA)
Jose Paulo Carneiro (Brazil)
Jose Carranza, M.D. (TX, USA)
Franklin Alcaraz Castillo, (Bolivia)
Katarina Cnattingius, (Sweden)
Beverly Cox (TN, USA)
James L. Curtis, M.D. (NY, USA)
Susan Dalterio, PhD. (TX, USA)
Dr. Luis Alfredo Vidal de Carvalho (Brazil)
Olavo de Carvalho, (Brazil)
Lee I. Dogoloff, LCSW (MD, USA)
Robert L. DuPont, M.D. (MD, USA)
Drew Edwards, M.S. (FL, USA)
Dr. Albu VanEeden (South Africa)
Rachel Ehrenfeld, Ph.D. (NY, USA)
Fanny Feldman, (Mexico)
Guillermo Fernandez, (Argentina)
Gary Fields, Ph.D. (IL, USA)
Mark Gold, M.D. (FL, USA)
K. F. Gunning, M.D. (The Netherlands)
Franziska Haller, M.D. (Switzerland)
Edward Jacobs, M.D., FAAP (WA, USA)
Grainne Kenny, (Ireland)
Dr. Frans Koopmans (The Netherlands)
John Lamp, Esq. (WA, USA)
Janet Lapey, M.D. (MA, USA)
MaLou Lindholm, (Sweden)
John Malouf, (Australia)
Cesar Malpartida, (Peru)
Ian McDonald, M.D. (MD, USA)
Connie Moulton (MA, USA)
Gabriel Nahas, M.D., Ph.D. (NY, USA)
Miller Newton, Ph.D. (FL, USA)
Charles Perkins, (Canada)
Maggie Petito (DC, USA)
Torgny Peterson, (Sweden)
Edwin Petrik, MD (KS, USA)
Tom Pool, DEA (Ret.) (WA, USA)  
David Risley, Esq. (IL, USA)
Blanca Rizzo, (Argentina)
Wayne Roques, DEA (Ret.) (FL, USA)
Ove Rosengren, (Sweden)
Richard Schwartz, M.D. (VA, USA)
Arlene B. Seal, Ph.D., (PA, USA)
Botho Simolin, (Finland)
Ulla Skiden, (Sweden)
David Spencer, M.D. (MN, USA)
Alvera Stern, Ed.D. (MD, USA)
Ann Stoker, (England)
Peter Stoker, (England)
Donald Taskin, M.D. (CA, USA)
Forest Tennant, M.D. (CA, USA)
Albu VanEeden, (South Africa)
Paulo Wengorski, (Brazil)
E. Joe Wiese, MS, LPC (TX, USA)
Renee Wijenko, (The Netherlands)
Juan Alberto Yaria, (Argentina)

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