While the U.S. Congress continues to debate budget issues, the Executive Branch is active and releasing proposed rules and other regulatory policies that could impact the attractions industry. In the past few weeks, IAAPA has submitted comment letters on the J1 Visa Summer Work Travel program, and menu labeling provisions under the Patient Protection and Affordable Care Act (PPACA).
The interim final rule on the Summer Work Travel program incorporates many of the changes seen in the pilot program announced late last year, including pre-placement, employer verification, and prohibited job placements. In our letter to the U.S. Department of State, we explained the importance of the J1 visa program, not only to attractions and their employees but also to the surrounding communities, and how the changes made by the interim final rule will address some of the negative publicity the J1 program has recently received. The interim final rule is effective July 15, 2011. It is unlikely the state department will finish reviewing all of the comments before then. Once the review is complete, State may offer a revised final rule, or just allow the interim final rule to stand indefinitely.
IAAPA felt the proposed rule implementing the menu labeling provisions of the PPACA was favorable to the attractions industry. In our comment letter to the U.S. Food and Drug Administration (FDA), IAAPA agrees with the FDA’s definition of retail food establishment as “an establishment whose primary business activity is the sale of food to consumers,” and the FDA’s example that, generally speaking, amusement parks are not restaurants. Since this was a proposed rule, the FDA will now consider feedback and publish an interim final rule at some point in the future. The PPACA dictated the Secretary of Health and Human Services implement this provision by March 23, 2011, so already the rule is delayed. My educated guess is we'll see a final rule by the end of the year.
The interim final rule on the Summer Work Travel program incorporates many of the changes seen in the pilot program announced late last year, including pre-placement, employer verification, and prohibited job placements. In our letter to the U.S. Department of State, we explained the importance of the J1 visa program, not only to attractions and their employees but also to the surrounding communities, and how the changes made by the interim final rule will address some of the negative publicity the J1 program has recently received. The interim final rule is effective July 15, 2011. It is unlikely the state department will finish reviewing all of the comments before then. Once the review is complete, State may offer a revised final rule, or just allow the interim final rule to stand indefinitely.
IAAPA felt the proposed rule implementing the menu labeling provisions of the PPACA was favorable to the attractions industry. In our comment letter to the U.S. Food and Drug Administration (FDA), IAAPA agrees with the FDA’s definition of retail food establishment as “an establishment whose primary business activity is the sale of food to consumers,” and the FDA’s example that, generally speaking, amusement parks are not restaurants. Since this was a proposed rule, the FDA will now consider feedback and publish an interim final rule at some point in the future. The PPACA dictated the Secretary of Health and Human Services implement this provision by March 23, 2011, so already the rule is delayed. My educated guess is we'll see a final rule by the end of the year.
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