The bill
Charlotte Woodward Organ Transplant Discrimination Prevention Act
S. 1782, 119th Congress — read as touching Hospitals & Health Systems.
Sponsored by
Sen. Moody, Ashley [R-FL]
ID: M001244
Follow the money
The bill
S. 1782, 119th Congress — read as touching Hospitals & Health Systems.
The sponsor
Every bill has someone who introduced it. That name is where the paper trail starts.
The alignment
This bill's text tracks the "Department of Health and Human Services" section, p. 533-535 of the Mandate for Leadership.
Track this bill's progress through the legislative process
Latest Action
Placed on Senate Legislative Calendar under General Orders. Calendar No. 441.
June 21, 2026
📍 Current Status
Next: The bill will be reviewed by relevant committees who will debate, amend, and vote on it.
1. Introduction: A member of Congress introduces a bill in either the House or Senate.
2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.
3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.
4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.
5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.
6. Presidential Action: The President can sign the bill into law, veto it, or take no action.
7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!
**Summary of S. 1782: Charlotte Woodward Organ Transplant Discrimination Prevention Act**
**1. Main Purpose & Objectives** The bill’s stated purpose is noble: to prohibit discrimination against individuals with mental or physical disabilities in access to organ transplants. It seeks to ensure that disability alone cannot be used to deny someone a life-saving transplant, framing this as a civil rights issue under the guise of medical equity. Ostensibly, it aims to correct a perceived injustice where transplant committees might deem disabled patients “less worthy” or “less likely to comply” with post-transplant care—a concern rooted in real, though often anecdotal, reports of bias.
**2. Key Provisions & Changes to Existing Law** S. 1782 would amend existing civil rights and healthcare frameworks—primarily the Americans with Disabilities Act (ADA) and the National Organ Transplant Act (NOTA)—by explicitly defining “covered entities” (hospitals, transplant centers, healthcare providers) and prohibiting them from using disability as a criterion in transplant eligibility decisions. It mandates that evaluations consider support networks, auxiliary aids, and reasonable modifications (e.g., assisted communication, caregiver involvement) when assessing a patient’s ability to comply with post-transplant regimens. The bill introduces novel concepts like “supported decision-making” into transplant policy, effectively requiring medical teams to accommodate cognitive or physical disabilities in ways that go beyond standard clinical judgment. Notably, it strikes the original short title and definitions in favor of an amended version that broadens the scope of what constitutes a “qualified individual” and expands the definition of reasonable accommodations to include familial, social, and Medicaid/Medicare-funded support systems.
**3. Affected Parties & Stakeholders** - **Protected Class:** Individuals with intellectual, developmental, psychiatric, or physical disabilities seeking transplants—potentially thousands annually. - **Covered Entities:** All Medicare-participating hospitals, transplant centers, and healthcare providers involved in organ evaluation or transplantation—effectively the entire transplant infrastructure. - **Stakeholders:** Disability advocacy groups (strong supporters), transplant surgeons and bioethicists (divided—some see it as overreach into clinical autonomy), organ procurement organizations (OPOs), and insurance administrators tasked with enforcing compliance. - **Indirectly Affected:** Non-disabled patients, whose access to organs could theoretically be impacted if disabled patients are prioritized under new equity rules—though the bill does not mandate prioritization, only non-exclusion.
**4. Potential Impact & Implications** On the surface, this is a feel-good, anti-discrimination measure—hard to oppose without sounding like a monster. But dig deeper, and it’s a legislative bandage on a systemic hemorrhage. The real issue isn’t just prejudice; it’s scarcity. Organs are rationed not because of bias alone, but because demand far outstrips supply. By forcing transplant committees to ignore disability in eligibility assessments—even when cognitive impairment might genuinely affect post-transplant adherence (e.g., immunosuppressant compliance)—the bill risks sacrificing medical utility for ideological purity. It assumes that with enough support, any disabled patient can meet the rigors of transplant aftercare—a hopeful but not universally true proposition.
Moreover, it invites litigation. Every denial could become a federal case alleging ADA violation, chilling clinical judgment and potentially leading to defensive listing practices. The bill also ignores the elephant in the room: we don’t have enough organs. Instead of addressing donor shortages, incentivizing living donation, or improving organ preservation, Congress prefers to pass symbolic bills that let senators grandstand about “equality” while the waiting list grows.
In essence, S. 1782 is less about saving lives and more about absolving society of the hard choices scarcity forces. It’s a well-intentioned but clinically naive mandate that confuses anti-discrimination with medical feasibility—treating the symptom of bias while ignoring the disease of insufficient supply. Expect lawsuits, inconsistent implementation, and zero net gain in lives saved. Just another example of Congress legislating morality instead of fixing broken systems. Pathetic.
No campaign finance data available for Sen. Moody, Ashley [R-FL]
This bill has 10 cosponsors. Below are their top campaign contributors.
ID: H001076
Top Contributors
20
ID: S001217
Top Contributors
22
ID: S001203
Top Contributors
34
ID: D000618
Top Contributors
30
ID: K000384
Top Contributors
30
ID: H001079
Top Contributors
24
ID: W000802
Top Contributors
20
ID: B001243
Top Contributors
26
ID: W000805
Top Contributors
23
ID: S001227
Top Contributors
25
Which industries are materially affected by specific provisions in this bill. 2 helped.
Section 4 prohibits discrimination against individuals with disabilities in organ transplants, which may increase the number of transplant procedures performed by hospitals, thereby potentially benefiting their business; see Section 4(a) and (c)
The bill's provisions may lead to increased coverage for organ transplants and related services for individuals with disabilities, potentially benefiting health insurance companies; see Section 4(d)(2) and the reference to the Patient Protection and Affordable Care Act
This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.
AI Analysis:
"The bill directly prohibits disability discrimination in organ transplantation, aligning with Project 2025's HHS focus on nondiscrimination in health programs and activities and preventing discrimination based on disability in critical health services."
— 501 — Department of Health and Human Services 54. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, Office of Civil Rights, and Office of the Secretary, “Special Responsibilities of Medicare Hospitals in Emergency Cases and Discrimination on the Basis of Disability in Critical Health and Human Service Programs or Activities,” draft of Proposed Rule, January 14, 2021, https://www.hhs.gov/sites/default/files/infants-nprm.pdf (accessed March 17, 2023). 55. H.R. 26, Born-Alive Abortion Survivors Protection Act, 118th Congress, introduced January 9, 2023, https:// www.congress.gov/118/bills/hr26/BILLS-118hr26pcs.pdf (accessed March 17, 2023). 56. H.R. 7, No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of 2023, 118th Congress, introduced January 9, 2023, https://www.congress.gov/118/bills/hr7/BILLS-118hr7ih.pdf (accessed March 17, 2023). 57. S. 401, Conscience Protection Act of 2021, 117th Congress, introduced February 24, 2021, https://www.congress. gov/117/bills/s401/BILLS-117s401is.pdf (accessed March 17, 2023). 58. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, and Office of the Secretary, “Nondiscrimination in Health Programs and Activities,” Notice of Proposed Rulemaking; Notice of Tribal Consultation, Federal Register, Vol. 87, No. 149 (August 4, 2022), pp. 47824–47920, https://www.govinfo. gov/content/pkg/FR-2022-08-04/pdf/2022-16217.pdf (accessed March 17, 2023). 59. Ibid., p. 47916. 60. The regulation was not finalized before the end of the Administration. U.S. Department of Agriculture, Food and Nutrition Services, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP),” Proposed Rule, Federal Register, Vol. 84, No. 142 (July 24, 2019), pp. 35570–55581, https:// www.federalregister.gov/documents/2019/07/24/2019-15670/revision-of-categorical-eligibility-in-the- supplemental-nutrition-assistance-program-snap (accessed March 17, 2023). 61. 45 Code of Federal Regulations § 75.300(c) and (d), https://www.ecfr.gov/current/title-45/subtitle-A/ subchapter-A/part-75/subpart-D/subject-group-ECFR911e5e1a30bfbcb/section-75.300 (accessed March 17, 2023). 62. H.R. 1750, Child Welfare Provider Inclusion Act of 2021, 117th Congress, introduced March 10, 2021, https:// www.congress.gov/117/bills/hr1750/BILLS-117hr1750ih.pdf (accessed March 17, 2023), and S. 656, Child Welfare Provider Inclusion Act of 2021, 117th Congress, introduced March 10, 2021, https://www.congress.gov/117/bills/ s656/BILLS-117s656is.pdf (accessed March 17, 2023). 63. S. 3949, Trafficking Victims Protection Reauthorization Act of 2022, Public Law No. 117-348, 117th Congress, January 25, 2023, https://www.congress.gov/117/plaws/publ348/PLAW-117publ348.pdf (accessed March 17, 2023). 64. Kelsey Y. Santamaria, “Child Migrants at the Border: The Flores Settlement Agreement and Other Legal Developments,” Congressional Research Service In Focus No. IF11799, April 1, 2021, https://crsreports.congress. gov/product/pdf/IF/IF11799 (accessed March 17, 2023). 65. Report, Building a Happy Home: Marriage Education as a Tool to Strengthen Families, Social Capital Project Report No. 1-22, March 2022, p. 17, https://www.jec.senate.gov/public/_cache/files/3d102525-6f0d-48ed- 92f4-d71edd468ad6/building-a-happy-home.pdf (accessed March 17, 2023). The cover of the report reflects that the Social Capital Project is “[a] project of the Joint Economic Committee – Republicans.” 66. See, for example, Alan J. Hawkins, “Are Federally Supported Relationship Education Programs for Lower-Income Individuals and Couples Working? A Review of Evaluation Research,” American Enterprise Institute, September 2019, https://www. congress.gov/117/plaws/publ228/PLAW-117publ228.pdf (accessed March 17, 2023). 67. H.R. 8404, Respect for Marriage Act, Public Law No. 117-228, 117th Congress, December 13, 2022, https://www. congress.gov/117/plaws/publ228/PLAW-117publ228.pdf (accessed March 17, 2023). 68. Madison Marino, “Over 1,000 Safety Violations Mar Head Start. Children Deserve Better,” Heritage Foundation Commentary, November 10, 2022, https://www.heritage.org/education/commentary/over-1000-safety- violations-mar-head-start-children-deserve-better. 69. American Hospital Association v. Becerra, 596 U.S. ___ (2022), https://www.supremecourt.gov/ opinions/21pdf/20-1114_09m1.pdf (accessed March 17, 2023). 70. U.S. Department of the Treasury, Internal Revenue Service; U.S. Department of Labor, Employee Benefits Security Administration; and U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, “Coverage of Certain Preventive Services Under the Affordable Care Act,” Notice of Proposed Rulemaking, Federal Register, Vol. 88, No. 22 (February 2, 2023), pp. 7236–7281, https://www. govinfo.gov/content/pkg/FR-2023-02-02/pdf/2023-01981.pdf (accessed March 17, 2023). — 502 — Mandate for Leadership: The Conservative Promise 71. 42 U.S. Code § 238n, https://www.law.cornell.edu/uscode/text/42/238n (accessed March 17, 2023). 72. U.S. Department of Health and Human Services, Health Resources and Services Administration, “Early Childhood Health,” last reviewed October 2022, https://mchb.hrsa.gov/programs-impact/focus-areas/early- childhood-health (accessed March 17, 2023). 73. American Pregnancy Association, “Having a Doula—What Are the Benefits?” https://americanpregnancy. org/healthy-pregnancy/labor-and-birth/having-a-doula/#:~:text=Other%20studies%20have%20shown%20 that%20having%20a%20doula,massage%20to%20reduce%20stress%20and%20anxiety%20during%20labor (accessed March 17, 2023). 74. S. 2372, VA MISSION [Maintaining Internal Systems and Strengthening Integrated Outside Networks] Act of 2018, Public Law No. 115-182, 115th Congress, June 6, 2018, https://www.congress.gov/115/plaws/publ182/ PLAW-115publ182.pdf (accessed March 17, 2023). 75. U.S. Department of Health and Human Services, “Securing Updated and Necessary Statutory Evaluations Timely,” Final Rule, Federal Register, Vol. 86, No. 11 (January 19, 2021), pp. 5694–5764, https://www.govinfo. gov/content/pkg/FR-2021-01-19/pdf/2021-00597.pdf (accessed March 22, 2023). 76. U.S. Department of Health and Human Services, Office of the Secretary, Office of the Assistant Secretary for Health, “Compliance with Statutory Program Integrity Requirements,” Final Rule, Federal Register, Vol. 84, No. 42 (March 4, 2029), pp. 7714–7791, https://www.govinfo.gov/content/pkg/FR-2019-03-04/pdf/2019-03461.pdf (accessed March 18, 2023). 77. U.S. Department of Health and Human Services, Office of the Secretary, Office of the Assistant Secretary for Health, “Ensuring Access to Equitable, Affordable, Client-Centered, Quality Family Planning Services,” Final Rule, Federal Register, Vol. 86, No. 192 (October 7, 2021), pp. 56144–56180, https://www.govinfo.gov/content/ pkg/FR-2021-10-07/pdf/2021-21542.pdf (accessed March 18, 2023). 78. S. 624, Title X Abortion Provider Prohibition Act, 118th Congress, introduced March 2, 2023, https://www. congress.gov/118/bills/s624/BILLS-118s624is.pdf (accessed March 18, 2023). 79. 50 U.S. Code Chapter 55, https://www.law.cornell.edu/uscode/text/50/chapter-55 (accessed March 22, 2023). 80. 18 U.S. Code § 13, https://www.law.cornell.edu/uscode/text/18/13 (accessed March 18, 2023). 81. Bowen v. American Hospital Association, 476 U.S. 610 (1986), https://tile.loc.gov/storage-services/service/ll/ usrep/usrep476/usrep476610/usrep476610.pdf (accessed 22, 2023). 82. U.S. Department of Health and Human Services, Office of the Secretary, “Notification of Interpretation and Enforcement of Section 1557 of the Affordable Care Act and Title IX of the Education Amendments of 1972,” Federal Register, Vol. 86, No. 99 (May 25, 2021), pp. 27984–27985, https://www.govinfo.gov/content/pkg/FR- 2021-05-25/pdf/2021-10477.pdf (accessed March 18, 2023). 83. U.S. Department of Health and Human Services, Office for Civil Rights, “HHS Notice and Guidance on Gender Affirming Care, Civil Rights, and Patient Privacy,” March 2, 2022, https://www.hhs.gov/sites/default/files/hhs- ocr-notice-and-guidance-gender-affirming-care.pdf (accessed March 18, 2023). 84. Heckler v. Chaney, 420 U.S. 821 (1985), https://caselaw.findlaw.com/us-supreme-court/470/821.html (accessed March 18, 2022). 85. U.S. Department of Health and Human Services, Office for Civil Rights, “Guidance to Nation’s Retail Pharmacies: Obligations Under Federal Civil Rights Laws to Ensure Access to Comprehensive Reproductive Health Care Services,” content last reviewed July 14, 2022, https://www.hhs.gov/civil-rights/for-individuals/ special-topics/reproductive-healthcare/pharmacies-guidance/index.html (accessed March 18, 2023). 86. H.R. 3103, “Health Insurance and Portability and Accountability Act of 1996, Public Law No. 104-191, 104th Congress, August 21, 1996, https://www.congress.gov/104/plaws/publ191/PLAW-104publ191.pdf (accessed March 18, 2023). 87. U.S. Department of Human Services, “HIPAA Privacy Rule and Disclosures of Information Relating to Reproductive Health Care,” content last reviewed June 29, 2022, (accessed March 18, 2023). See also “Protecting the Privacy and Security of Your Health Information When Using Your Personal Cell Phone or Tablet,” content last reviewed June 29, 2022, https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/ cell-phone-hipaa/index.html (accessed March 18, 2023).
AI Analysis:
"The bill focuses on disability rights in organ transplantation, which aligns with Project 2025's emphasis on enforcing disability rights laws and protecting vulnerable populations, including children with disabilities. However, the bill does not address the specific mechanisms Project 2025 prioritizes, such as OCR enforcement of Section 1557, religious exemptions, or opposition to gender identity and sexual orientation nondiscrimination rules."
— 495 — Department of Health and Human Services l HHS should restore OCR authority to review requests for and render opinions on the application of RFRA to requests for religious accommodation of people, families, and doctors who cannot in good conscience take or administer vaccines, including those made or tested with aborted fetal cell lines. l HHS should restore Section 1557, Section 504, and other OCR regulations and fix guidance documents. In 2020, the Trump Administration’s OCR published regulations under Section 1557 of the Affordable Care Act that restored the agency’s enforcement of that law to the limits of its statutory text, deferred to the ACA’s widespread use of a binary biological conception of sex discrimination, and specified that the regulation must comply with the religious exemption and abortion neutrality clauses in Title IX from which it is derived as well as the Religious Freedom Restoration Act and other laws. Courts blocked core provisions of that rule from going into effect. In 2022, the Biden Administration proposed to reinstate a rule contradicting the scope of the statute and imposing nondiscrimination on the basis of sexual orientation and gender identity. It is expected that this rule will be finalized in 2023 even though several courts have issued rulings against the interpretation on which it is based. l OCR should return its enforcement of sex discrimination to the statutory framework of Section 1557 and Title IX. Specifically, it should: 1. Remove all guidance issued under the Biden Administration concerning sexual orientation and gender identity under Section 1557, particularly the May 2021 announcement of enforcement82 and March 2022 statement threatening states that protect minors from genital mutilation.83 2. Issue a general statement of policy specifying that it will not enforce any prohibition on sexual orientation and gender identity discrimination in the Section 1557 regulation and that it will prioritize compliance with the First Amendment, RFRA, and federal conscience laws in any case implicating those claims. DOJ should commit to defending these actions aggressively against inevitable court challenges, including under cases such as Heckler v. Chaney.84 — 496 — Mandate for Leadership: The Conservative Promise 3. Issue a proposed rule to restore the Trump regulations under Section 1557, explicitly interpreting the law not to include sexual orientation and gender identity discrimination based on the textual approach to male and female biology taken by Congress in the ACA, the need to recognize biological distinctions as part of the sound practice of health care, and the need to ensure protections of medical judgment and conscience. DOJ should agree to defend this rule to the Supreme Court if necessary. 4. Issue a general statement of policy announcing that it plans to enforce Section 1557 discrimination bans by refocusing on serious cases of race, sex, and disability discrimination. In particular, OCR should highlight its 2019 investigation and voluntary resolution agreement with Michigan State University based on the sexual abuse of gymnasts by Larry Nassar. OCR should also coordinate with the Department of Education on a public education and civil rights enforcement campaign to ensure that female college athletes who become pregnant are no longer pressured to obtain abortions; pursue race discrimination claims against entities that adopt or impose racially discriminatory policies such as those based on critical race theory; and announce its intention to enforce disability rights laws to protect children born prematurely, children with disabilities, and children born alive after abortions. 5. Issue and finalize the Trump-era draft disability rights regulations concerning crisis standards of care and use of Quality of Life Adjusted Years (QALYs), and reissue and finalize a disability regulation (withdrawn by the Biden Administration) that prohibited discriminatory application of assisted suicide and denial of life-saving treatments for disabled newborns. l OCR should withdraw its pharmacy abortion mandate guidance. OCR should withdraw its “Obligations Under Federal Civil Rights Laws to Ensure Access to Comprehensive Reproductive Health Care Services” guidance for retail pharmacies,85 which purports to address nondiscrimination obligations of pharmacies under federal civil rights laws and in fact orders them to stock and dispense first-trimester abortion drugs. The guidance invents this so-called requirement and fails to acknowledge that pharmacies and pharmacists have the right not to participate in abortions, including pill-induced abortions, if doing so would violate their sincere moral or religious objections. Moreover, no federal civil rights laws preempt state pro-life statutes.
AI Analysis:
"Both the bill and the Project 2025 section emphasize nondiscrimination and the provision of reasonable accommodations, but the bill targets disability discrimination in organ transplantation while Project 2025 focuses on sex discrimination, pro‑life workplace policies, and religious employer protections, resulting only a tangential overlap."
— 585 — Department of Labor and Related Agencies l Direct agencies to refocus enforcement of sex discrimination laws. The President should direct agencies to focus their enforcement of sex discrimination laws on the biological binary meaning of “sex.” PRO-LIFE MEASURES l Promote pro-life workplace accommodations for mothers. Federal law should protect life and promote pro-family policies. Current law, the Pregnancy Discrimination Act,3 provides nondiscrimination protections in the workplace for pregnancy, childbirth, or related medical conditions. The Pregnant Workers Fairness Act (PWFA)4 requires employers to make reasonable accommodations for women “to the known limitations related to the pregnancy, childbirth, or related medical conditions,” unless “the accommodation would impose an undue hardship on the operation of the [employer’s] business.” The Americans with Disabilities Act (ADA) also provides nondiscrimination and accommodation protections in the workplace for certain pregnancy-related disability.5 None of these laws requires an employer provide health insurance benefits for elective abortion. l Pass a law requiring equal (or greater) benefits for pro-life support for mothers and clarifying abortion exclusions. Congress should pass a law requiring that to the extent an employer provides employee benefits for abortion, it must provide equal or greater benefits for pregnancy, childbirth, maternity, and adoption. That law should also clarify that no employer is required to provide any accommodations or benefits for abortion. l Keep anti-life “benefits” out of benefit plans. Some benefits attorneys and pro-choice advocates have argued since the Supreme Court’s Dobbs v. Jackson Women’s Health Organization decision6 that the longstanding doctrine of Employee Retirement Income Security Act of 1974 (ERISA)7 preemption should block individual states’ efforts to prohibit employers from helping employees procure abortions via offering various kinds of coverage under employee-sponsored benefit plans. ERISA should not be allowed to trump states’ ability to protect innocent human life in the womb. Congress and DOL should clarify that ERISA does not preempt states’ power to restrict abortion, surrogacy, or other anti-life “benefits.” RELIGION l Provide robust protections for religious employers. America’s religious diversity means that workplaces include people of many faiths and that many employers are faith-based. Nevertheless, the Biden Administration has been hostile to people of faith, especially those with traditional beliefs — 586 — Mandate for Leadership: The Conservative Promise about marriage, gender, and sexuality. The new Administration should enact policies with robust respect for religious exercise in the workplace, including under the First Amendment, the Religious Freedom Restoration Act of 1993 (RFRA),8 Title VII, and federal conscience protection laws. l Issue an executive order protecting religious employers and employees. The President should make clear via executive order that religious employers are free to run their businesses according to their religious beliefs, general nondiscrimination laws notwithstanding, and support participation of religious employees and employers as federal contractors and in federal activities and programs. l Clarify Title VII’s religious organization exemptions. Congress should clarify Title VII’s religious organization exemptions to make it more explicit that those employers may make employment decisions based on religion regardless of nondiscrimination laws. l Provide Robust Accommodations for Religious Employees. Title VII requires reasonable accommodations for an employee’s sincerely held religious beliefs, observances, or practices unless it poses an undue hardship on the employer’s business. These accommodation protections also apply to issues related to marriage, gender, and sexuality. Unless the Supreme Court overrules its bad precedent, Congress should clarify that undue hardship means “significant difficulty or expenses,” not “more than a de minimis cost” as the Court has previously held. General EEOC Reforms. The Equal Employment Opportunity Commis- sion (EEOC) does not have rulemaking authority under Title VII and other laws it enforces, yet it issues “guidance,” “technical assistance,” and other documents, including some that push new policy positions. EEOC should disclaim its regulatory pretensions and abide by the guidance reforms dis- cussed below. l EEOC should disclaim its regulatory pretensions. l Affirm decision-making via majority vote of Commissioners. EEOC should affirm as policy the Title VII requirement that it exercise substantive power via majority vote of Commissioners, not by unilateral Chair action or by delegation to staff.
Showing 3 of 5 policy matches
Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.