News From Alaska Center for Public Policy

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From the Editor

Dear Reader,

As we probably all learn in high school government class, the U.S. federal government is divided into three branches: the executive, legislative, and judicial branches. Typically, descriptions of their respective roles and responsibilities are clear with regard to law: the legislative branch makes laws, the executive branch implements the laws, and the judicial branch interprets law. The State of Alaska operates under the same system.

Every year in mid-January, the Legislature, the branch of Alaska government that makes law, gets a lot of media attention. Here at Alaska Health Policy Review, we are no exception. We closely follow each health-related bill as it makes its way to become law (or not). What doesn't get much attention is how the other branches of government influence how the law is interpreted and regulated.

I spend a fair amount of my time with policy wonks who tend to like thought-provoking subjects to ponder. A friend of mine recently brought to my attention a real life situation involving how law is regulated and how regulation, in effect, shapes law. The resulting interview with Mary Minor, ND, is my new year's gift to those of you who are also policy wonks. You know who you are.

Also in this issue, I briefly report on the results of the legislative priority reader survey we published two weeks ago. It was interesting and affirming to read your responses. One of my hopes as editor of this publication is to open the lines of communication with you. Your responses suggest that that might be appreciated.

To those of you who responded affirmatively to my query about submitting original research, articles, links, or other information for possible use in Alaska Center for Public Policy publications, I will be contacting you soon. If you can't wait, feel free to email me or call 907-276-2277. Thank you all for your responses.

Finally, in this issue we begin our weekly legislative bill watch report, which features bills we determined are health related. If you think we missed one or more, please let me know.

Thank you for reading Alaska Health Policy Review.

Jacqui Yeagle

Managing Editor

Q & A with Mary Minor, ND

Mary Minor, ND

Mary Minor, ND, graduated from Bastyr University with a doctorate in naturopathic medicine in 1983. Dr. Minor moved to Alaska in 1990, and currently works at the Holistic Medical Clinic in Fairbanks. She is past president of the Alaska Association of Naturopathic Physicians. In this interview, Dr. Minor describes what proposed new regulations will mean to the practice of naturopathy in Alaska. This interview was conducted by email between January 14 and 16, 2013. The interview was edited for length and clarity.

AHPR: I understand that you are concerned about regulation changes proposed by the Division of Corporations, Business and Professional Licensing to the practice of naturopathy in Alaska. Is that right?

Dr. Minor: Yes. I have been active in my state association (Alaska Association of Naturopathic Physicians - AKANP) for many years in our attempts to broaden the scope of practice for naturopaths in Alaska so that it would be commensurate with our education and with how our colleagues in licensed states such as Oregon and Washington have practiced for decades. In addressing the proposed regulations from the division, I am now trying to preserve the status quo.

AHPR: What is naturopathy?

Dr. Minor: Naturopathy is a system of healing that blends traditional natural therapies with current scientific advances. The scope of practice, as taught in the federally accredited naturopathic schools, focuses on family and primary care, and includes all aspects of natural medicine. By statute, (AS 08.45.200) the State of Alaska definition is: (3) "naturopathy" means the use of hydrotherapy, dietetics, electrotherapy, sanitation, suggestion, mechanical and manual manipulation for the stimulation of physiological and psychological action to establish a normal condition of mind and body; in this paragraph 'dietetics' includes herbal and homeopathic remedies."

AHPR: Who is proposing the changes?

Dr. Minor: The Division of Corporations, Business and Professional Licensing has recommended changes to these definitions: 1. dietetics; 2. herbal remedy; 3. homeopathic remedy; and 4. prescription drug.

"One way to look at this change is that the current regulations prohibit naturopathic doctors from using "prescription drugs," where "drugs" is a noun and "prescription" is an adjective. .... The new proposed interpretation would make "prescription" the noun."

AHPR: What do the current regulations allow naturopaths to do that the proposed regulations will not allow.

Dr. Minor: The current regulations have been in place since 1994. They include the definition of "dietetics" as nutritional substances, vitamins, minerals, etc. that we use to diagnose, treat, and prevent disease, illness, and conditions. The regulations define "herbal remedy" to include medicines derived from or a concentrate or extract of a plant, tree, root, moss, fungus, or other natural substance. It further says that an herbal remedy cannot be a controlled substance (for example opium) or a prescription drug. A "homeopathic remedy" is a medicine found in the Homeopathic Pharmacopoeia.

The last definition that the division would re-define is "prescription drug." The current regulations make an exception to the prohibition against naturopaths using prescription drugs for a device, an herbal remedy, a homeopathic remedy or a dietetic, unless it is a controlled substance. There are many products that are restricted by the prescription label that are not considered "drugs" and are certainly not controlled substances.

In 2011, many of our suppliers stopped providing much needed supplies to our offices across the state because they had been told that we can not use anything that is a prescription. These draconian restrictions are not only a contradiction to how most of us have practiced over the past 18 years, it makes Alaska by far the most restrictive of all licensed states. As a result, patient care has suffered.

The new regulations would change the prohibition against naturopathic doctors using prescription drugs, to a prohibition that would not allow us to use any product that is obtainable only by prescription. One way to look at this change is that the current regulations prohibit naturopathic doctors from using "prescription drugs," where "drugs" is a noun and "prescription" is an adjective. That is, in fact, what the statute that licenses naturopaths says. The new proposed interpretation would make "prescription" the noun. Therefore, therapies that we have believed were perfectly within our scope of practice, such as herbal medications that are not available as an over-the-counter tincture because it has the prescription (Rx) legend on it, would now be unavailable to naturopathic doctors in Alaska.

AHPR: Why do you think the division is proposing the changes?

Dr. Minor: In the cover letter that announced the proposed changes to the naturopathic regulations, Donald Habeger, director of the division, explained that these regulations will "bring regulations into alignment with state statute and clarify for naturopaths, as well as the public and other healthcare providers, the issue of prescriptive authority."

"Every health care provider is limited by his or her training and education. ... Essentially, many safe, effective naturopathic therapies will no longer be available to Alaskans as it has since 1986."

AHPR: How will the proposed changes affect access to care for Alaskans?

Dr. Minor: These regulations are unprecedented. In 1986, the Legislature made a policy decision that people in Alaska should have access to naturopathic medicine. During the 27th legislative session [2011-12], SB 175 and HB 266, if passed, would have taken the current regulations and put them into statute (AS 08.45.050).

Among the arguments against passage of this bill was that it would, as Ward Hulbert, chief medical officer of the Department of Health and Human Services argued, allow naturopaths to prescribe drugs such as digitalis, quinine, cancer medications, and penicillin. Technically, there are many drugs that are derived from natural sources. My colleague, Dr. CW Jasper, addressed this concern in a Senate L&C Committee. He said that even though regulations may have allowed the use of anti-cancer drugs since 1994, naturopaths did not write prescriptions for these medications.

The reason for this is simple. Every health care provider is limited by his or her training and education. Any patient who comes to me that might need digitalis doesn't need to see me; he or she needs a cardiologist. By the same token I cannot tell patients to get nebulized glutathione from their conventionally-trained provider because that is not part of his or her training. Many effective naturopathic therapies that have been part of naturopathic medical practice since 1986 will no longer be available.

"We are using email, social media, whatever resources are at our disposal so that by the deadline, January 24, Alaska consumers can tell the division how this stroke of a pen will affect them and their families."

AHPR: What action are you, other naturopaths, and the Alaska Association of Naturopathic Physicians taking to respond to the proposed changes?

Dr. Minor: We are doing everything we can to alert the public to proposed changes and take the opportunity to tell the division what they think of the proposed regulations. The response has been overwhelming. We set up a website. It takes just a couple of minutes to send the message to Jun Maiquis, regulation specialist at the division. We are using email, social media, whatever resources are at our disposal so that by the deadline, January 24, Alaska consumers can tell the division how this stroke of a pen will affect them and their families.

AHPR: Just a week ago, Sen. Olson introduced HB7, which seems to attempt to clarify the scope of naturopathic practice in Alaska. What do you think of the bill as written?

Dr. Minor: It is a good first step. It does need some tweaking. The proposed changes in regulations really goes off course in its position that prescription dietetics, homeopathics, and herbal medicine are the same thing as prescription drugs. This is a novel interpretation. Both federal and state laws differentiate between prescription "products" and prescription "drugs." For example,

Federal Law 21 USC 360ee (b) (3): some vitamins, minerals and other nutritional substances are prescription only, and are legally classified as "medical food"
Alaska State Law AS 08.80.480 (aka the Pharmacy Act) (9): "drug" means an article recognized as a drug...an article other than food
The Alaska Food, Drug and Cosmetic Act AS 17.20.370 (8) "drug" means an article ... other than food...

AS 17.20.370 (12) also defines "food" as an article used for food or drink for man or animal, chewing gum, and articles used for component of either of them. Components of food (vitamins, minerals, amino acids, etc) are considered food, and foods are not drugs.

If clarification is what is needed, then we need to be clear that the prohibition against naturopaths using prescription drugs does not include food.

"This confusion has generated more heat than light and Alaskans have been poorly served. Going forward, I hope we can do a better job of facilitating access to appropriate care instead of erecting unnecessary barriers."

AHPR: If the bill passes as is, what do you think that would that mean for the practice of naturopathy in Alaska?

Dr. Minor: The bill will need some modification if we are to restore the status quo of naturopathic practice in Alaska.

AHPR: Is there anything you wish I had asked or any final comments?

Dr. Minor: I think these regulations are a solution in search of a problem. Director Habeger indicated in testimony to the Senate L&C committee in 2012 that he does not know where the rumor started among suppliers of naturopathic medicines that sending our offices prescription nutritional supplies was against Alaska State law. There is no paper trail that will tell us who started this process, and we will probably never know why this happened.

This confusion has generated more heat than light and Alaskans have been poorly served. Going forward, I hope we can do a better job of facilitating access to appropriate care instead of erecting unnecessary barriers. In the meantime, the public is speaking out against these proposed changes. I only hope the administration will take note.

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For all related matters, please contact the managing editor, Jacqui Yeagle.

Alaska Center for Public Policy Legislative Priority Survey: Brief Report

A couple of weeks ago, Alaska Center for Public Policy initiated a survey to learn what policies our readers hoped the Legislature would address in this session. Forty-nine people responded, identifying a total of about 98 primary issues. Following is a brief report based on the responses we received.

Given Alaska Center for Public Policy's health policy bent, it was not surprising that health policy issues -- cost, care, and access -- were cited more frequently than were other issues. Within that category, access to affordable care, in some form or another, took the number one spot -- 43 of the 98 identified concerns.

"The state has not taken responsibility for moving ahead with 'Obamacare.'"

"Health care is more inaccessible than ever. 'Public' health now charges for everything."

"Health: Medicaid expansion, public health, health-related bills and funding."

Concerns about specific types of health care were also a hot topic.

"Alaskans need accessible, affordable, adequate mental health care."

"Alaska has the fastest growing senior population in the country but we do not have adequate long term care services, or enough home and community based services in the urban an rural areas to keep seniors living independently for as long as possible."

Some responses were really specific.

"We need to have more affordable treatment for opiate addicts."

"Funding for comprehensive obesity programs, coverage for colorectal cancer screening (colonoscopy) of retired state employees."

"Substance abuse and violence treatment."

Concerns about the economy were addressed 24 times in the responses. The majority (12) were about gas, oil, and renewable resources. Growing the economy -- in the form of agriculture, natural resource management, and transportation infrastructure -- was also mentioned several times. Fiscal planning was the third most often cited concern about the economy.

"I would like to see our state's resource revenues invested in public assets and improvements that will provide ongoing benefits to Alaskans in the form of broader and safer transportation options."

"Expansion of renewable energy within the state; oil tax reform that benefits Alaska"

"[W]orried there won't be much revenue if they do an oil tax giveaway."

Rounding out the issues identified in the responses are the environment, education, and concerns for Alaskans.

"[L]egislation to list hazardous chemicals in products and phase them out, particularly those in children's products."

"[E]ducation beyond preparing people to work for oil companies and existing economic powerful businesses."

"It will soon be impossible to keep my home because of the heating fuel costs."

Clearly, readers of Alaska Center for Public Policy's publications are a thoughtful group of people. We were impressed with the passion behind the responses, obvious even through the medium of an electronic survey. Your responses will help guide future publications and conversations.

Thank you to all of you who took the time to share your thoughts.

Bill Watch: Bill Tracking Methodology

Bills listed in Alaska Health Policy Review were selected based on a series of subjective criteria to determine whether they were "health-policy related." All bills currently sitting in the Senate and House Health and Social Services committees were examined, and any that obviously dealt with non-health-related education or social services issues were eliminated. Every other House and Senate committee was then examined for health-related bills, which were included in the final list.

After determining the full set of health-related bills still in committee or pre-filed for the new session, they were divided into several general categories. This was done to facilitate finding bills that dealt with certain key health policy issues and to make overall navigation of the list easier. The remaining bills were categorized as "general" health policy-related because of the wide range of subjects they covered.

The information listed for each bill includes the bill number, the short title, the primary sponsor or sponsors, the committee in which the last action on the bill took place, and the date on which the last action on the bill took place. A short summary or long title of each bill is also included.

Abbreviations have been used for committee names. The committee names and their abbreviations are:

(H) HSS: House Health and Social Services Committee
(S) HSS: Senate Health and Social Services Committee
(H) L&C: House Labor & Commerce Committee
(S) L&C: Senate Labor & Commerce Committee
(H) EDC: House Education Committee
(S) EDC: Senate Education Committee
(H) FIN: House Finance Committee
(S) FIN: Senate Finance Committee
(H) JUD: House Judiciary Committee
(S) JUD: Senate Judiciary Committee
(H) STA: House State Affairs Committee
(S) STA: Senate State Affairs Committee
(S) RLS: Senate Rules Committee
(H) CRA: House Community and Regional Affairs Committee
(S) CRA: Senate Community and Regional Affairs Committee
(H) TRA: House Transportation Committee
(S) TRA: Senate Transportation Committee
(H) RES: House Resources Committee
(S) RES: Senate Resources Committee
(H) MLV: Military and Veterans' Affairs

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Bill Watch: Drugs

HB53 Consultation for Opiate Prescription
Committees and date of last action: Read for the first time, referred to (H) HSS and L&C, 01/16/13
Sponsor: Rep. Keller
Description: "An Act establishing a consultation requirement with respect to the prescription of opiates under certain circumstances."

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Bill Watch: Health Professional Workforce and Education

HB 6 Pharmacy Audits
Committees and date of last action: Read for the first time, referred to (H) FIN and L&C, 01/16/13
Sponsor: Rep. Olson
Description: "An Act establishing procedures and guidelines for auditing pharmacy records; and providing for an effective date."

HB7 Practice of Naturopathy
Committees and date of last action: Read for the first time, referred to (H) FIN and HSS, 01/16/13
Sponsor: Rep. Olson
Description: "An Act relating to the practice of naturopathy; and providing for an effective date."

HB43 University Institutes of Law and Medicine
Committees and date of last action: Read for the first time, referred to (H) EDC and L&C, 01/16/13
Sponsor: Rep. Kawasaki
Description: "An Act authorizing the establishment of institutes of medicine and law at the University of Alaska."

HB44 Advance Health Care Directives Registry
Committees and date of last action: Read for the first time, referred to (H) HSS and JUD, 01/16/13
Sponsor: Rep. Holmes
Description: "An Act relating to a registry for advance health care directives."

SB 8 Pharmacy Audits
Committees and date of last action: Read for the first time, referred to (S) L&C and STA, 01/16/13
Sponsor: Sen. Egan
Description: "An Act establishing procedures and guidelines for auditing pharmacy records; and providing for an effective date."

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Bill Watch: Mental Health

HB66 Approp. Mental Health Budget
Committees and date of last action: Read for the first time, referred to (H) FIN, 01/16/13
Sponsor: Rules by request of the governor
Description: "An Act making appropriations for the operating and capital expenses of the state's integrated comprehensive mental health program; and providing for an effective date."

SB20 Approp: Mental Health Budget
Committees and date of last action: Read for the first time, referred to (S) FIN, 01/16/13
Sponsor: Rules by request of the governor
Description: "An Act making appropriations for the operating and capital expenses of the state's integrated comprehensive mental health program; and providing for an effective date."

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Bill Watch: Family Health Issues

HB45 Electronic Bullying in Schools
Committees and date of last action: Read for the first time, referred to (H) EDC and JUD, 01/16/13
Sponsors: Reps. Costello and Gattis
Description: "An Act relating to harassment, intimidation, or bullying by students attending a public school in the state."

HB54 Placement of a Child in Need of Aid
Committees and date of last action: Read for the first time, referred to (H) HSS and JUD, 01/16/13
Sponsors: Reps. Gara and Thompson
Description: "An Act relating to the identification, location, and notification of specified family members of a child who is in state custody."

HB59 Missing Vulnerable Adult Response Plan
Committees and date of last action: Read for the first time, referred to (H) MLV and STA, 01/16/13
Sponsor: Rep. Gruenberg
Description: "An Act relating to missing vulnerable adult prompt response and notification plans."

SB6 Funding for School Meals
Committees and date of last action: Read for the first time, referred to (S) EDC and FIN, 01/16/13
Sponsor: Sen. Wielechowski
Description: "An Act providing for funding for school lunch and breakfast; and providing for an effective date."

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Bill Watch: Public Safety

HB24 Self Defense
Committees and date of last action: Read for the first time, referred to (H) JUD and FIN, 01/16/13
Sponsor: Rep. Neuman
Description: "An Act relating to self-defense in any place where a person has a right to be."

HB55 Authorize Firearms for School Personnel
Committees and date of last action: Read for the first time, referred to (H) EDC and JUD, 01/16/13
Sponsor: Rep. Lynn
Description: "An Act allowing school districts and private schools to adopt a policy authorizing one or more permanent employees to possess one or more firearms on school grounds under certain conditions."

HB73 Crimes; Victims; Child Abuse and Neglect
Committees and date of last action: Read for the first time, referred to (H) JUD and FIN, 01/16/13
Sponsor: Rules by request of the governor
Description: "An Act relating to the commencement of actions for felony sex trafficking and felony human trafficking; relating to the crime of sexual assault; relating to the crime of unlawful contact; relating to forfeiture for certain crimes involving prostitution; relating to the time in which to commence certain prosecutions; relating to release for violation of a condition of release in connection with a crime involving domestic violence; relating to interception of private communications for certain sex trafficking or human trafficking offenses; relating to use of evidence of sexual conduct concerning victims of certain crimes; relating to procedures for granting immunity to a witness in a criminal proceeding; relating to consideration at sentencing of the effect of a crime on the victim; relating to the time to make an application for credit for time served in detention in a treatment program or while in other custody; relating to suspending imposition of sentence for sex trafficking; relating to consecutive sentences for convictions of certain crimes involving child pornography or indecent materials to minors; relating to the referral of sexual felonies to a three-judge panel; relating to the definition of 'sexual felony' for sentencing and probation for conviction of certain crimes; relating to the definition of "sex offense" regarding sex offender registration; relating to protective orders for stalking and sexual assault and for a crime involving domestic violence; relating to the definition of 'victim counseling centers' for disclosure of certain communications concerning sexual assault or domestic violence; relating to violent crimes compensation; relating to certain information in retention election of judges concerning sentencing of persons convicted of felonies; relating to remission of sentences for certain sexual felony offenders; relating to the subpoena power of the attorney general in cases involving the use of an Internet service account; relating to reasonable efforts in child-in-need-of-aid cases involving sexual abuse or sex offender registration; relating to mandatory reporting by athletic coaches of child abuse or neglect; making conforming amendments; amending Rules 16, 32.1(b)(1), and 32.2(a), Alaska Rules of Criminal Procedure, Rule 404(b), Alaska Rules of Evidence, and Rule 216, Alaska Rules of Appellate Procedure; and providing for an effective date."

SB22 Crimes; Victims; Child Abuse and Neglect
Committees and date of last action: Read for the first time, referred to (S) JUD and FIN, 01/16/13
Sponsor: Rules by request of the governor
Description: "An Act relating to the commencement of actions for felony sex trafficking and felony human trafficking; relating to the crime of sexual assault; relating to the crime of unlawful contact; relating to forfeiture for certain crimes involving prostitution; relating to the time in which to commence certain prosecutions; relating to release for violation of a condition of release in connection with a crime involving domestic violence; relating to interception of private communications for certain sex trafficking or human trafficking offenses; relating to use of evidence of sexual conduct concerning victims of certain crimes; relating to procedures for granting immunity to a witness in a criminal proceeding; relating to consideration at sentencing of the effect of a crime on the victim; relating to the time to make an application for credit for time served in detention in a treatment program or while in other custody; relating to suspending imposition of sentence for sex trafficking; relating to consecutive sentences for convictions of certain crimes involving child pornography or indecent materials to minors; relating to the referral of sexual felonies to a three-judge panel; relating to the definition of 'sexual felony' for sentencing and probation for conviction of certain crimes; relating to the definition of "sex offense" regarding sex offender registration; relating to protective orders for stalking and sexual assault and for a crime involving domestic violence; relating to the definition of 'victim counseling centers' for disclosure of certain communications concerning sexual assault or domestic violence; relating to violent crimes compensation; relating to certain information in retention election of judges concerning sentencing of persons convicted of felonies; relating to remission of sentences for certain sexual felony offenders; relating to the subpoena power of the attorney general in cases involving the use of an Internet service account; relating to reasonable efforts in child-in-need-of-aid cases involving sexual abuse or sex offender registration; relating to mandatory reporting by athletic coaches of child abuse or neglect; making conforming amendments; amending Rules 16, 32.1(b)(1), and 32.2(a), Alaska Rules of Criminal Procedure, Rule 404(b), Alaska Rules of Evidence, and Rule 216, Alaska Rules of Appellate Procedure; and providing for an effective date."

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Bill Watch: General Health Policy

HB16 Adult Public Assistance Eligibility
Committees and date of last action: Read for the first time, referred to (H) JUD and L&C, 01/16/13
Sponsor: Rep. Keller
Description: "An Act relating to citizenship requirements and an alcohol impairment and drug testing program for applicants for and recipients of specified cash assistance."

SB9 Price Gouging Involving Energy Resources
Committees and date of last action: Read for the first time, referred to (S) L&C, RES, FIN, 01/16/13
Sponsor: Sen. Wielechowski
Description: "An Act making sales of and offers to sell certain energy resources at prices that are unconscionable an unlawful act or practice under the Alaska Unfair Trade Practices and Consumer Protection Act."

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Alaska Health Policy Review Special Legislative Session Subscription

The Alaska Health Policy Review is issued electronically, weekly during the regular legislative session and monthly the rest of the year. A standard 12-month subscription to the Alaska Health Policy Review is available for $850.

Tell your friends! Share the news! Alaska Health Policy Review is also available at a special rate of $425 during the months of the legislative session only.

During the legislative session, Alaska Health Policy Review features a bill tracking section so you can stay informed about the status of health-related bills just by opening your email! Other features include interviews with health policy makers, original and reprinted health policy research, and a calendar of health policy-related events.

Discount rates apply for multiple recipients in the same organization, legislators, and small nonprofit organizations. Don't miss an issue! Direct orders, comments, and inquiries to Alaska Center for Public Policy by email or by phone at 907-276-2277.

Alaska Health Policy Calendar

This calendar of health policy and related meetings is current as of January 17, 2013.

Full Lives Conference for Direct Service Professionals
When: Thursday and Friday, April 11 and 12, 2013
Where: Sheraton Anchorage Hotel
Other information: The Full Lives Conference features national and Alaska experts on key issues that affect direct service staff and the people they support. Presentations are provided on a wide variety of topics, allowing attendees to choose sessions based on their personal and professional interests, such as: promoting healthy relationships, person-centered best practices, honoring cultural diversity, stress management, climbing the career ladder, and community inclusion strategies. Registration will be available in February.
Contact: Email Raelynn Smith or call 907-264-6244 for more information.

The Foraker Group Leadership Summit: "Telling Our Stories As Leaders, As Organizations, and As A Sector"
When: Monday and Tuesday, April 22 and 23, 2013
Where: Hotel Captain Cook, Anchorage, AK
Other information: Don't miss the chance to engage with national leaders in the field and statewide experts who will provide inspiration, strategies, and tools for effective communication. Here are just a few of the people who will offer their experience and insight: Thaler Pekar, Kivi Leroux Miller, Tom Ahern, and Steve Culbertson. Early bird registration ends February 22, 2013. You can learn more and register online.

Business of Clean Energy in Alaska Conference
When: Thursday and Friday, May 2 and 3, 2013
Where: Dena'ina Civic and Convention Center, Anchorage
Other information: Join leaders and clean energy experts from across the globe for two interactive days of workshops, discussions, and exhibits on the growing economic opportunities related to renewable energy and energy efficiency in Alaska. Sign up on our BCEA email update list to stay posted on updates for this year's event. Save $125 by registering by March 29.

AHPR Staff and Contributors

Lilly Conducy, Proofreader

Lauren Young, Proofreader

Jacqui Yeagle, Managing Editor