recommendations identified in the Protecting Our Infants Act: Final Strategy. (Recommendation 1) We provided a draft of this report to HHS for review, and HHS provided written comments, which are reprinted in appendix III. HHS also provided technical comments, which we incorporated as appropriate. In its written comments, HHS concurred with our recommendation to expeditiously take steps to address NAS and re-stated that its Strategy will be used to inform planning and policy across HHS. Specifically, HHS said that as part of its broader initiative to address the opioid crisis, the department will develop and implement a plan—that will include priorities, timeframes, roles and responsibilities, and methods for assessing progress—to address as appropriate and possible, the NAS-related recommendations in its Strategy. HHS also stated that full implementation would be contingent on funding, though it provided no information on how much funding was needed or how the funding would be used. Developing a plan to guide implementation can help the department determine what resources, if any, are needed to implement the recommendations in its Strategy. Recommendation for Executive Action Agency Comments and Our Evaluation Page 34 GAO-18-32 Newborn Health We are sending copies of this report to the appropriate congressional addressees, the Secretary of Health and Human Services, and other interested parties. In addition, the report will be available at no charge on GAO’s website at http://www.gao.gov. If you or your staff have any questions about this report, please contact me at (202) 512-7114 or at iritanik@gao.gov. Contact points for our Office of Congressional Relations and Office of Public Affairs can be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix IV.Neonatology and the specter of the law S. Van McCrary∗ Clinical Ethics Consultation Service, Stony Brook University Medical Center, Stony Brook, New York, NY, USA 1. Introduction When I began my career with dual training in bioethics and law, my research and clinical interests were focused on the suffering of terminally ill adults due to unwanted treatment and how perceptions of law among health care providers contributed to this problem. A central goal of my work was to try to prevent situations where physicians would aggressively continue to treat patients in ways contrary to their expressed wishes and ignore the attempts of family members to implement the preferences of their loved ones. It was apparent that some physicians were so anxious about the impact of legal factors on their practice that they were willing to tolerate additional suffering of patients to protect themselves. Further, I suspected that many of these physicians were not well versed in the nuances of applicable laws and were making these judgments with inaccurate information. Hence my research was designed, in part, to dispel misperceptions by physicians of legal constraints on their practice and encourage them to educate themselves about law. I also hoped to suggest that some physicians modify their approach to cases of serious illness to evaluate all elements of the case proportionally, carefully considering the impact of suffering on both patients and families, rather than ascribing excessive importance to the impact of legal factors. Later in these pages, I will briefly describe some results of this research regarding cases of adult patients. As I became involved with ethical issues in neonatology, however, ∗Corresponding author: Center for Medical Humanities, Compassionate Care, & Bioethics Health Science Center- Level 3, Stony Brook, NY 11794-8335, USA. Tel.: +1 631 444 8029; Fax: +1 631 444 9744. I rapidly recognized that both health care providers’ perceptions of the legal rules, and the rules themselves, were markedly different regarding treatment decisions for neonates. I also observed that the reactions of families of neonates sometimes differed from reactions of families of critically ill adults. These recognitions have caused me to reflect on these differences and their implications for both research and health policy addressing the interactions between neonatal medicine and the law. In this commentary, I will first review the history of the controversies about treatment decisions for infants with genetic and chromosomal aberrations which resulted in the federal and state laws now known collectively as the Baby Doe rules, as well as the ongoing dispute within the pediatrics and bioethics communities about clinical implementation of these rules. Second, I will examine briefly the current research on outcomes in extremely preterm infants with a focus on its implications for comparing international cultures on the practice of neonatology, as well as predictions of mortality and morbidity. Third, I will describe and discuss my own research about the effects of legal perceptions on medical decision making for terminally ill adult patients, and evaluate its implications for decisions about neonates. Fourth, I will attempt to draw some conclusions from the preceding sections and offer a few observations from clinical experience about how neonatologists may differ from physicians who treat older children and adults, as well as how the practice of neonatology coexists with serious legal constraints amid