How Will Repeated Oral Reading Practice Impact Reading Fluency Case Study

How Will Repeated Oral Reading Practice Impact Reading Fluency - Case Study Example I teach at an elementary school, J.B. Nachman, in Alexandria, Louisiana. The school starts at Pre-K and goes through to fifth grade. There are approximately 700 students in the school. Nachman is the solitary elementary school in the district that is not considered a Title One school. I teach third grade, and we are not currently departmentalized. There are 23 students in my class: eight African American students, thirteen white students and one Asian student. I have one child with an IEP, and he is with a resource teacher for a majority of the day. There are no other adults in my classroom. I have chosen a small group of students (eight children) for my project based on their most recent DIBELS scores. The children, under my watch, have scored well below benchmark and are likely to need intensive support with regard to oral reading fluency. These are children who enjoy reading and are not intimidated to read aloud, as much as they struggle with word recognition and fluency. Review of Literature Clearly, reading serves many purposes in our daily lives. We use it in our work and play. We use it to help us learn more about ourselves and about the world around us in addition to sharing information with others (Martin-Chang & Levy, 2005). The National Reading Panel Report (2000) contained conclusive research that indicated that reading fluency was an essential element of the entire reading process, and that it was crucial that it is taught to developing readers. â€Å"Just as children and adults love to watch favorite movies over and over, readers of all ages have books, or sections of books, that they enjoy reading and re-reading, time and time again† (Dowhower, 1994, p. 354). ... â€Å"Just as children and adults love to watch favorite movies over and over, readers of all ages have books, or sections of books, that they enjoy reading and re-reading, time and time again† (Dowhower, 1994, p. 354). Since the 1970s, researchers and scholars have collected data that supported the concept that multiple readings of connected text enhanced the reading skills of a regular student. Reading stories to young students, besides their personal rereading, at least three times proved to enrich reading development. This procedure of repeated readings was simple, yet extraordinarily powerful (Dowhower, 1994). Using the common round robin approach in the classroom, where students take turns reading a small portion of the story, substantially limited amount of practice each student received because no child was allowed to read for very long. In order for students to establish significant progress in reading, beyond the initial stages, they needed to be given sufficient opp ortunities to practice reading in a variety of text styles (Pikulski & Chard, 2003). Employing repeated reading on a regular basis in a variety of formats could impact word recognition, reading fluency and comprehension (Rasinski, 2003). There is much evidence to support claims that repeating reading instruction influenced fluency in a diverse array of students. The ultimate goal of repeated reading instruction was to then enable students to generalize fluency to new passages that were being read for the first time (Nanda & Frederick, 2007). According to Pikulski and Chard (2003), repeated oral reading is the most frequently documented approach to improving fluency, with improved outcomes for young students

Effect of Temperature on Vitamin C in Orange Juice

Effect of Temperature on Vitamin C in Orange Juice Abstract: This experiment was planned to study how different temperatures can affect the loss of vitamin C in orange juice stored for a fixed period of time. Equal volume of freshly squeezed orange juices with known (initial) vitamin C concentration were stored at different temperatures i.e. 10 °C, 20 °C, 30 °C, 40 °C, 50 °C and 60 °C for a constant duration of 5 days. After the storage period, the vitamin C concentration for each temperature was measured by DCPIP titration and the difference relative to the initial concentration was calculated to calculate the amount of vitamin C reduced. The result of this experiment showed that the amount of vitamin C lost increases with the increase in temperature and 10oC was the best temperature that gave the least reduction in vitamin C concentration. An analysis using Pearson product-moment correlation coefficient has revealed a strong positive linear relationship between the two variables with the calculated r value exceeds the critical va lue at 5 % significant level thus, supporting the experimental hypothesis. Vitamin C is a remarkable compound derived from one of the ascorbic enantiomers, L-ascorbate. It is a water soluble vitamin that cannot be naturally synthesized in human body.1 Therefore, it is vital to have our diet balanced with adequate amount of it every day. There are two important roles played by vitamin C; antioxidant and collagen formation.2 These two features have placed vitamin C in a class of its own as a future potential in fostering better health. A previous research regarding relationship between vitamin C and human brain has shown that vitamin C could help drugs to pass the blood brain barrier.6 This would enable brain diseases such as Parkinson to be effectively treated as artificial dopamine can be delivered directly to the brain. At the same time, the biggest challenge in bone marrow treatment i.e. getting enough cells, could possibly be solved as a recent study by Dunagqing Pei13 on vitamin C, has found that it can boost the production and pluripotency of stem cells in human body. However, Vitamin C is also known to be very vulnerable towards heat. The precursor of vitamin C, ascorbic acid, has molecular of C6H8O6. The proximity of highly electronegative oxygen atoms on the hydroxyl (OH) groups makes the hydrogen atoms to become easily detached from the structure. Meanwhile, the presence of heat causes the hydroxyl bond to break the ascorbic acid is said to undergo destruction or oxidation by losing hydrogen atoms, forming dehydroascorbic acid. Therefore, it is suggested that the rate of ascorbic acid destruction is significantly greater at higher temperature.* Most of the studies on vitamin C degradation are principally based on the effect of storage condition and period, and very few were done on identifying the degradation trend within a specific range of temperature. Previous research, on the effect of storage methods and conditions on vitamin C retention in human milk revealed that freezing reduces the least amount of vitamin C as compared to other storage methods, followed by refrigeration which is better than cold water. Another study at Ankara University, has shown an inverse relationship between temperature and retention rate of vitamin C in citrus fruit concentrates, while orange fruit was found to have higher retention ability than the others. Therefore, this experiment was aimed to find a specific trend regarding the effect of temperature on the loss of vitamin C. Citrus fruits (orange) were used in this experiment due to appreciable amount of vitamin C that they have, thus, increasing the reliability of the results. The results from this study can be used to illustrate how certain temperatures can cause drastic change in vitamin C hence, increasing the awareness on appreciating the effort of preserving vitamin C content in food for optimum health benefit. For instance, in agricultural tropical regions that grow citrus fruits, it becomes very vital to preserve the fruits at low temperature if possible due to higher chance of vitamin C destruction than other regions. Experimental Hypothesis: The higher the temperature, the higher the degradation of vitamin C in freshly squeezed orange juice. Null Hypothesis: There is no significant relationship between the different temperature and the degradation of vitamin C in freshly squeezed orange juice. PLANNING Five types of citrus fruits were randomly chosen, namel: lemon, lime, grapefruit, Clementine and orange. The fresh juice of each fruit was obtained through cutting and squeezing. The vitamin C content for each juice was determined by titration against 1 ml of 1 % DCPIP. The titration was repeated two times to get an average volume of the juice needed to decolourise DCPIP. The result: The least volume of orange was needed to decolourise DCPIP, indicating that it has the highest vitamin C content. Therefore, orange fruit was chosen as it would give significant response towards different temperatures. Determining the best storage period: Several orange fruits were squeezed to obtain fresh orange juice that would be enough for its vitamin C content to be measured on daily basis. Firstly, the initial vitamin C content of the juice was measured and 4.8 ml was needed to decolourise 1 ml of DCPIP solution. Equal volume of the remaining juice was divided into two beakers and each was stored in an incubator of different temperatures (10 °C and 60 °C). Two distinctive temperatures were chosen to allow easy comparison of the trend in each temperature. The result: The result shows no more change in volume of juice required after 5 days for 60 °C. Therefore, storage period of five days were chosen for the main experiment. MAIN EXPERIMENT Variables: Manipulated variable: Different temperatures (oC) (6 incubators were set at different temperatures of 10 °C, 20 °C 0, 30 °C, 40 °C, 50 °C and 60 °C) Responding variable: Amount of vitamin C lost (By DCPIP titration, the difference between initial and final vitamin C concentration in each juice was  calculated to determine the concentration of vitamin C reduced) Fixed variables : Storage period, volume and concentration of DCPIP, type of fruits (The storage period was five days. 1ml of 0.1% DCPIP  Used for each titration) Apparatus: Beakers, knife, test tubes, syringes, Parafilm, aluminium paper, incubators, mortar and pestle, measuring cylinder. Materials: Orange fruits, 1% dichlorophenolinophenol (DCPIP) solution, distilled water, 500 mg vitamin C tablet. Real Experimental Procedures: Standardizing Vitamin C Concentration: 1) A tablet of 500 mg vitamin C tablet was crushed into fine powders using a mortar and a pestle. 2) The powdery form of vitamin C was then dissolved into 100 ml of distilled water in a beaker to form 5 mg/ml of ascorbic solution. 3) 1 ml of 1% DCPIP solution was measured and placed into a test tube by using a syringe. 4) 1 ml of 5 mg/ml of ascorbic acid solution was then taken using a syringe and added drop by drop into the measured DCPIP solution until decolourised. 5) The volume of ascorbic acid solution needed to decolourise the DCPIP solution was recorded. 6) The titration process was repeater three times to get an average volume. The result of titration is as follows: Volume of Juice Titrated / ml Hence, 2.5 ml of 5 mg/ml of ascorbic acid solution was needed to decolourise 1 ml of 1% DCPIP solution To find a formula to calculate vitamin C concentration in orange juice, Conc. of orange juice (mg/ml) Vol. of orange juice (mg/ml) = 5 mg/ml 2.5 ml Since the volume needed to decolourise is proportional to vitamin C concentration. So. Conc. of orange juice (ml) 2.5 ml = 5 mg/ml Vol. of orange juice (mg/ml) 2.5 ml Concentration of orange juice (mg/ml) = X 5 mg/ml Vol. of orange juice (ml) Therefore, this calculation would be used to calculate the vitamin C concentration. Determining vitamin C loss: 10 orange fruits were cut and squeezed to obtain fresh juice. 1 ml of 1% DCPIP solution was measured and placed into a test tube by using a syringe. 1 ml syringe was filled with the orange juice and added drop by drop into the DCPIP solution until it decolourised. The volume of juice added was recorded. The titration was repeated five times to get an average volume and its vitamin C concentration was calculated using the derived formula. The juice was then divided into 6 equal volumes and each placed into 100 ml beaker. The top of each beaker was sealed with Parafilm and its surface was wrapped with aluminium paper and labelled with different temperatures. The beakers were placed in six incubators of different temperatures according to the label and left for five days. After five days, the beakers were sealed off. 1 ml of 1% DCPIP solution was measured and transferred into a test tube by using a syringe. The orange juice stored in 10 °C was taken by a syringe and added drop by drop into the DCPIP until it decolourised. The volume of juice added was recorded The titration was titrated three times to get an average volume and its vitamin C concentration was calculated using the formula: 2.5 ml Concentration of orange juice (mg/ml) = X 5 mg/ml Vol. of orange juice (ml) Steps 8-10 were repeated but this time using the orange juices stored in  °C, 30 °C, 40 °C, 50 °C and 60 °C. The difference between the initial concentration and the final concentration of each juice was calculated to determine the amount of vitamin C lost. Risk Assessment: The process of cutting the orange fruits required the use of knife, so it was done carefully to avoid any injury. The fruits were then squeezed very gently to minimise heat production. The juice was only prepared right before the experiment was about to be carried out. DCPIP is a strong dye which is hard to be removed so lab coat was worn. During the titration of juice against DCPIP, the test tube was not shaken vigorously to avoid oxygen from dissolving. The juice was discarded immediately after the experiment. Results: Statistical Analysis: Based on the result from the table, it is known that there is an obvious trend and correlation between the temperature and vitamin C loss. Therefore, Pearson product-moment correlation coefficient (PMCC) was chosen to measure the strength of this relationship. In this method, the value of correlation coefficient, r needs to be calculated which ranges from -1 to 1. The details of its values are as follow: Therefore, the value of correlation coefficient, r, using Pearson product-moment correlation coefficient has shown a strong positive linear relationship between temperatures and loss of vitamin C. Hence, null hypothesis is rejected. Data Analysis: Table 4 shows the volume of the freshly-squeezed orange juice needed to decolourise 1ml of 1% DCPIP solution. The average volume was used to calculate the concentration of vitamin C present initially. Meanwhile, Table 5 shows the amount of vitamin C concentration reduced after being stored at different temperatures for five days. From the table, there is an inverse relationship between the vitamin C concentration left and the amount of vitamin C lost. There is also a huge difference in the amount of vitamin C left between the juice stored in 10 oC andt the one stored at 60 oC, which is 2.11 mg/ml. This represents 77.6% of the original concentration of vitamin C. The calculated statistical correlation coefficient, r of 0.9584 is absolutely a strong indicator to support this relationship. Graph 1 illustrates the trends and correlation between the two variables. From the graph, it can be concluded that generally, the higher the temperature, the higher the amount of vitamin C lost. 10 oC is the best temperature that gave the least reduction in vitamin C level with only 0.12 mg/ml (4.4%) decrease after five days. Meanwhile, 60 oC caused maximum drop in concentration after five days with 2.23 mg/ml (82%) of vitamin C had lost. The largest gap in vitamin C loss occurred between 40 oC and 50 oC with 1 mg/ml (37%) of increase recorded. Based on the graph, the amount of degradation at 20 °C and 30 °C opposed the general trends when 0.6 mg/ml vitamin C had lost at 10 °C which is greater than 0.56 mg/ml at 30 °C. However, the difference is so small which suggests that this anomaly might be due to several reasons: Higher rate of oxidation of ascorbic acid by oxygen in the atmosphere. False end-point titration Apart from that, the results obtained have also shown that there is only a little change in vitamin C concentration from 10 °C to 30 °C. However, drastic change in concentration started to occur after 40 °C. This suggests that orange fruits should be kept below 30 °C with better vitamin C retention at lower temperature. Evaluation: From the results of the experiment, the huge difference in vitamin C lost between 40 °C and 50 °C could be explained by the presence of enzyme ascorbate oxidase in citrus fruits. The function of this enzyme is still not fully understood, but one best suggestion is that it might involve in controlling the oxidation process of ascorbic acid.12 Just like any other enzymes, when the optimum temperature is exceeded, the bonds holding the ascorbate oxidase together start to break and it is said to be denatured. Therefore, the destruction of ascorbic acid takes place without any control. Measurement of vitamin C in this experiment was done by titrating the juice against dichlorophenolindophenol (DCPIP). It is a strong oxidizing agent with distinctive blue colour and decolourised when being reduced by vitamin C.15 Therefore, the destruction of vitamin C by heat means that more is needed to decolourise DCPIP solution. Oxidation of DCPIP by oxygen in the atmosphere is one of the limitations of this experiment. Hence, the test tubes were not shaken vigorously during titration in order to minimise this limitation as vigorous moves can increase the rate of oxygen dissolving in a solution. The other limitation could be the side decomposition of vitamin C due to the presence of light and air. Just like temperature, ultraviolet ray from incidence light causes the hydroxyl bond in ascorbic acid to break, thus become oxidised. To reduce this limitation, the beakers containing orange juice to be stored at different temperatures were neatly wrapped with aluminium paper which is a good reflector of light and heat. The surfaced of the beakers were also sealed with Parafilm. This would prevent the entry of air and significantly reduce unnecessary oxidation of vitamin C in the juice. Several modifications can be made in the future to improve the accuracy and reliability of the results of this experiment. Iodine titration could be used as an alternative for DCPIP titration. Although this technique may require the use of more reagents, the result from the trial experiment has shown that the end point of titration is much easier to be identified. Besides, orange juice could be obtained by blending the peeled orange fruits instead of squeezing them. This ensures maximum amount of juice obtained from each fruit as well as preventing destruction of vitamin C by heat. Finally, percentage of vitamin C degraded can be used as the response variable instead of concentration. This would allow clearer illustration of the amount of vitamin C reduced for the readers and also make the comparison process easier. Conclusion: Based on the result of this experiment, it can be concluded that the higher the temperature, the greater the degradation of vitamin C in freshly squeezed orange juice. The statistically calculated r value using Pearson product-moment correlation coefficient, 0.9584, is significantly higher than the critical value at 5% significance level thus, providing a strong evidence to support the hypothesis. Sources Evaluation: Several recourses were used in providing me important information in completing this assignment. Sources 1 and 2 are books that are specially made about fruit management and also detailed information about vitamin C as well as compelling research on it. Both books were published after year 2005, so the information available is mostly up to date. Besides, I have also accessed journals available online. Sources 3 and 4 come from two well known websites for food and nutrition based journals. The American Journal of Clinical Nutrition is a trustable website with over 3100 members, publishing up to dates research related to nutrition and human. Sources 7, 8 and 9 are chemistry based websites, serving enormous information on the structures and reaction of biological compounds. Chemwiki is a virtual online based chemistry textbook, accessed by millions of people searching for chemistry knowledge. Sources 10 and 11 are websites exclusively made for vitamin C. The Vitamin C Foundation, for instance, is recognised by Internal Revenue Service, IRS in protecting vast information about vitamin C for public reference. Source 12, Scientific American magazine is a popular scientific magazine established for nearly two centuries since 1845 with more than 3.5 million readers all over the world. Therefore, there would be no doubt in reliability of the content in this magazine.

The Development of Janes Character from Passionate Child to Independen

The Development of Jane's Character from Passionate Child to Independent Woman Jane's character changes immensely throughout the course of the novel. In Victorian England, there were distinctive boundaries of social classes and I intend to study Jane's social elevation, from a destitute orphan to that of a beloved wife. When Jane was a child her parents died and she was sent to Mr Reed, her late mother's brother. "my own uncle - my mother's brother in his last moments he had required a promise of Mrs Reed that she would rear and maintain me as one of her own" Her uncle died and she was left with Mrs Reed and her three cousins who all despised her. They only looked after her because of the promise to Mr Reed. It was typical in Victorian England for an orphan to stay with relatives because if they didn't they would be sent to the workhouse. They would either be loved or despised - like in Jane's case. Jane was a spirited child who was not afraid to stand up to Mrs Reed or John Reed. She was isolated and explains how unloved and ill treated she was at Gateshead "if anyone asks me how I liked you, and how you treated me, I will tell them the very thought of you makes me sick" Jane is a brave, little girl and tells things as they are. She accepts how badly she was treated and lets Mrs Reed know this just before leaving to go to school at Lowood. When Mr Brocklehurst visited her at Gateshead, she was forceful and told him directly "Psalms are not interesting." This action was not typical of others in Victorian England, as they would not have answered so bluntly. Jane Eyre leaves Gateshead and attends Lowood School, she forms alliances with Helen Burns and Miss Temple, and she becomes a much .. ...character it helps to focus and underline the thoughts and feelings of the writer without feeling embarrassed, instead it allows the writer to get their opinions into society through another means other than themselves. However, I do not believe that the whole novel is feminist because a Victorian woman's aspiration was to marry and in the end this is what Jane ends up doing. The period when Jane is at school is when she learns to control herself and become more "Victorian", but again in contrast to this, it has been suggested that Miss Temple and Jane were more than just friends up until the point when Miss Temple got married. It seems to me that sections of the novel do point to being 'feminist', trying to get men and women on equal terms, whereas some sections are more typical in the way that they represent Jane and a more usual 'Victorian' manner.

Charities Essay

The legal definition of charity has historically been somewhat elusive and stands distinct from any understanding of charity in a general or popular sense. As Lord Wright observed, in its legal sense the word â€Å"charitable is a word of art, of precise and technical meaning†[1]. Viscount Simmonds further remarked that, â€Å"no comprehensive definition of legal charity has been given either by legislature or in judicial utterance, there is no limit to the number and diversity of ways in which man will seek to benefit his fellow men†. The Preamble to the Charitable Uses Act 1601, also referred to as the Statute of Elizabeth I, contained a list of purposes which were then regarded as charitable. It assumed a central role for the courts as a reference point or catalogue of accepted instances of charity until almost 300 years later when Lord MacNaughten in the Pemsel case, famously classified charitable objects into four principal divisions: (i) trusts for the relief of poverty, (ii) trusts for the advancement of education, (iii) trusts for the advancement of religion, (iv) trusts beneficial to the community not falling under any of the preceding heads. These four heads of charity were used as reference whenever the inherent charitable nature of a purpose or institution was questioned until the Charities Act 2006 received royal assent. Section 2(2) of the 2006 Act now provides a modern statutory definition of charity by listing 13 descriptions of purposes deemed charitable at law. In order to be charitable, an organisation has to be established for one or more purposes within the descriptions recognised by the law as capable of being charitable, and for the public benefit. Charity law in England and Wales has developed within the context of the traditional monotheistic religions but it has embraced for many years religions other than Christianity and Judaism. In Bowman[3], Lord Parker effectively held that it was not just the promotion of Christianity that would be recognised but that the Courts of this country were not precluded â€Å"from giving effect to trusts for the purposes of religions which, however sacred they may be to millions of His Majesty’s subjects, either deny the truth of Christianity or, at any rate, do not accept some of its fundamental doctrines†. Furthermore in the Commission’s Scientology[4] decision it was firmly established that â€Å"The law does not prefer one religion to another and as between religions the law stands neutral†[5]. The English courts have, for a long time, resisted closely defining what makes some belief systems religious and others not. However in the Scientology case, the Commissioners accepted that there are various characteristics of religion which can be discerned from the legal authorities: †¢ Belief in a god or a deity or supreme being – R v Registrar General[6] †¢ Two of the essential attributes of religion are faith and worship: faith in a god and worship of that god – South Place Ethical Society[7] †¢ To advance religion means â€Å"to promote it, to spread the message ever wider among mankind; to take some positive steps to sustain and increase religious belief and these things are done in a variety of ways which may be comprehensively described as pastoral and missionary†. United Grand Lodge v Holborn BC[8]. Having considered these characteristics, the Commissioners concluded that the definition of a religion in English charity law was characterised by a belief in a supreme being and an expression of that belief through worship. This definition is further refined in the 2006 Act where s2 (3) a gives a partial definition of the word religion. However, the law does not automatically recognise as a religion everything that may designate itself as a religion and there are some principles to which a purpose must conform if it is to be regarded as within the Charities Act’s description of ‘the advancement of religion’. These general principles are gathered from the common law of England and Wales but also take into account the body of law which has developed concerning the European Convention right to freedom of thought, conscience and religion. As a general proposition, for its advancement to be capable of being charitable in this context, a religion should have a certain level of cogency, seriousness, coherence and importance[9]. Also, in order to be charitable for the advancement of religion, the content of any system of faith and worship has to be of a positive nature, impacting beneficially on the community. Sir John Wickens, V-C. in Cocks v Manners[10] observed: â€Å"It is said, in some of the cases, that religious purposes are charitable, but that can only be true as to religious services tending directly or indirectly towards the instruction or the edification of the public†¦Ã¢â‚¬  Hence, to be charitable a religious purpose has to be serious, tend directly or indirectly to the moral and spiritual improvement of the public as well as being for the public benefit. In Holmes v Attorney General[11] Walton J commented: â€Å"†¦ It is not for the benefit of the adherents of the religion themselves that the law confers charitable status, it is in the interests of the public. † Hence, as a general proposition, in the case of charities for the advancement of religion the purpose must not simply be for the benefit of the followers of the particular religion. Formerly, the proposition stated that â€Å"as between different religions the law stands neutral, but it assumes that any religion is at least likely to be better than none†[12]. Plowman J in Re Watson[13] considered a case for the publication and distribution of the fundamentalist Christian writings of an individual where he quoted authority that the court does not prefer one religion or sect to another and said that â€Å"where the purposes in question are of a religious nature †¦ then the court assumes a public benefit unless the contrary is shown†. He then went on to say that the only way of disproving a public benefit is to show that the doctrines inculcated are adverse to the very foundations of all religion, and that they are subversive of all morality. However, that part of the judgment being inconsistent with the judgment of the court of appeal and opinions given by the House of Lords in Gilmour v Coats, where it was held: â€Å"†¦the question whether a trust is beneficial to the public is an entirely different one from the question whether a trust is for the advancement of religion†, it is not regarded a binding. Since the Charities Act 2006, there is no longer any presumption that, because a purpose falls within the description â€Å"the advancement of religion†, it is for the public benefit. Section 3(2) of the Act provides: â€Å"In determining whether [the public benefit] requirement is satisfied in relation to any †¦purpose, it is not to be presumed that a purpose of a particular description is for the public benefit†. Hence, with the removal of the presumption and in the modern context the proposition may now be interpreted as meaning that advancing religion can be seen as a public good if such advancement can be demonstrated to be in relation to a system having a benign and positive content which is being advanced for the benefit of the public. Over the years, there are some purposes which, despite being beneficial and religious and indeed seriously religious, did not fall within the legal framework. For example, fostering private piety, although being a religious activity, is not a charitable purpose due to the absence of benefit to the public. In Cocks v Manners[14] (supra) it was said that â€Å"a voluntary association of women for the purpose of working out their own salvation by religious exercises and self-denial seems to have none of the requisites of a charitable institution. † In the Re Joy[15] case it was held that the real object contemplated by the testator was the non-charitable purpose of improvement of the membership of a society by prayer. Further, in Re White[16], it was held that â€Å"a society for the promotion of private prayer and devotions by its own members and which has no wider scope, no public element, and no purpose of general utility would not be charitable†. Lord Simonds in the Gilmour[17] case later confirmed the decision in Cocks v Manners and said that activities â€Å"good in themselves but solely designed to benefit individuals associated for the purpose of securing that benefit, which may not have some repercussions or consequential effects beneficial to some section of the general community† do not meet the prerequisites of a charitable institution. In Re Warre’s Will Trusts, on the matter of a retreat house, Harman J said: â€Å"Activities which do not in any way affect the public or any section of it are not charitable. Pious contemplation and prayer are, no doubt, good for the soul, and may be of benefit by some intercessory process, of which the law takes no notice, but they are not charitable activities. † Thus, in Re Hetherington[18] it was held that the celebration of a religious rite in private does not contain the necessary element of public benefit since any benefit of prayer or example is incapable of proof in the legal sense and any element of spiritual or moral improvement (edification) is limited to a private not public class of those present at the celebration. However, in the same case it was also held that the holding of a religious service which is open to the public is capable of conferring a â€Å"sufficient public benefit because of the edifying and improving effect of such celebration on the members of the public who attend. † There are also other purposes related to religion whose pursuits have not been considered as charitable because the purpose itself is not exclusively charitable. For example a trust ‘for Roman Catholic purposes’ may not be for exclusively charitable purposes furthering the Roman Catholic faith[19]. Also a gift to an Anglican vicar of a parish â€Å"for parochial institutions or purpose†Ã¢â‚¬â„¢[20] was not considered charitable. A bequest to an archbishop to be applied â€Å"in any manner he might think best for helping to carry on the work of the Church in Wales†[21] is not charitable either and neither is a generally stated purpose â€Å"for religious, educational and other parochial requirements†[22]. On the other hand, In Re Schoales[23], it was clarified that there is no distinction, from the point of view of validity as a gift for charitable purposes, between a gift to the Church of England and a gift to another Church. A gift for the general purposes of a particular church or denomination or faith community falls are considered in law as a gift which has to be applied only for such of its purposes as are for the advancement of religion for the public benefit, and hence charitable. As mentioned above, charitable purposes require some promotion or advancement that is to â€Å"spread its message ever wider among mankind; to take some positive steps to sustain and increase religious belief†[24]. Proselytising is one way of advancing religious purposes[25] but it may raise public benefit issues if it breaks the law or results in harm or detriment. Therefore, it would not be compatible with public benefit principles for an organisation to seek to inhibit anyone from their rights of freedom of thought, conscience or religion (Article 9 ECHR) and to manifest or change such beliefs. This matter was considered in Kokkinakis v Greece[26] and the court in considering attempts to forbid activities of a Jehovah’s Witness confirmed that a democratic society has a plurality of beliefs and held that freedom to manifest one’s religion includes the right to convince one’s neighbor. But, the court drew a clear distinction between bearing Christian witness and improper proselytism by stating that the former was true evangelism and the latter representing a corruption or deformation of it. Furthermore, proselytising being unlawful in some countries, the Commission dealt with the issue of whether it was possible to recognise a religious purpose as charitable in England and Wales which is not charitable and may be illegal abroad in its annual report in 1993 which mentioned: â€Å"One should first consider whether they would be regarded as charities if their operations are confined to the United Kingdom. If they would, then they should be presumed also to be charitable even though operating abroad unless it would be contrary to public policy to recognise them. Hence, an organisation whose purpose is to proselytize, even if its activity is carried out internationally, may be charitable in England and Wales unless it causes harm or detriment which outweighs the public benefit. The High Court considered the statement in the Sonsino case[27] in 2002 and upheld it. However, it still remains unclear as to what the courts would rule contrary to public policy. Another way of advancing a religion would be by means of undertaking pastoral work. However, where a charity is operating solely for the purpose of advancement of religion, then any secular pastoral work which it undertakes should be as a means of advancing the particular religion. A convent in Cocks v Manners[28] was held charitable and there the nuns were engaged in exterior works (teaching the ignorant and nursing the sick) as part of their religious work. In the United Grand Lodge[29] case, Donovan J said that taking positive steps to sustain and increase religious beliefs was something done â€Å"in a variety of ways which can be comprehensively described as pastoral and missionary†. More recently, the Pilsdon Community House, a religious community living according to Christian principles and giving practical help in cases of drug addiction, drink, having been in prison or loneliness was considered in Re Banfield[30]. The court held that the fact that a religious community makes its services available to those of all creeds and of none does not prevent it being a charity for the advancement of religion also that furthering the purposes of the community amounted to the advancement of religion.

Financial Environment Essay

Introduction With recent big changes in healthcare legislation, health care organizations are moving towards a system that changes reimbursement procedures. Health care organizations will be reimbursed by the government based on the quality of care provided by that organization. The Affordable Care Act (ACA) requires certain steps to make Medicare more resourceful by decreasing the amount of overpaid funds to insurance companies, adjusting reimbursement rates to levels that are more suitable, and altering payment scales and systems to support the delivery of efficient, premium health care (â€Å"Centers For Medicare & Medicaid Services†, 2013). There are several different types of health care organizations that offer medical services to patients. Because of the many different services and organizations in healthcare, the financial aspect of health care is not so cut and dry. Health care organizations can be described as either for-profit, not-for-profit, or part of a government organization. Some examples of these health care organizations are hospitals, nursing homes, health insurance companies, and home health care agencies. Gapenski (2008) explains that he healthcare field is different from any other field mainly because of two factors. Unlike other types of services, most healthcare providers and organizations are structured as not-for-profit rather than being owned by an investor. Another major factor that contributes to its uniqueness is the fact that payment is made by a third party rather than the individual who receives the services. For-profit Organizations The Watermark at Logan Square, Tenet Healthcare, and Hospital Management Associates (HMA) are just three examples of for-profit health care organizations in today’s market. These are investor owned organizations that must pay taxes and do not receive the same benefits that not-for-profit organizations receive. For-profit healthcare organizations are owned by investors. In terms, this means they have shareholders who benefit directly from any profits that are generated from this organization. Unlike, not-for-profit organizations, these for-profit organizations do not usually have the mission of taking on charity work or cases. Not-for-profit Organizations Not-for-profit hospitals are nongovernment entities that are organized with the main goal of providing inpatient healthcare services. Three examples of not-for-profit healthcare organizations include The Hospital of the University of Pennsylvania (HUP), Memorial Sloan-Kettering Cancer Center, and The Cleveland Clinic. Gapenski (2008) explains that not-for-profit organizations must be structured and managed so that they operate exclusively to the interest of the public. Non-profit organizations were formed with the purpose of servicing the needs of the less fortunate. This later led to non-for-profit hospitals being free from paying taxes because of the fact that they were providing certain social services. Due to the fact that individuals can not benefit from the profits of not-for-profit organizations, dividends from these organizations cannot be paid (Gapenski, 2008). Not-for-profit organizations are also controlled by a board of trustees, which often times makes it hard to make certain changes or decisions without everyone in agreement. Because of the current economy, Ebrahim (2010) explains that not-for-profit organizations stand out more in the area of public policy and the delivery of public services than they have ever before. Currently, the existing economic crisis has caused cuts in funding at both the state and local level. These financial cuts often times force many not-for-profit organizations to reduce the services offered. Obtaining funding with these setbacks is a major challenge for any nonprofit organization. When these organizations are not getting the funds they were once given, it takes a lot of budget restructure to not be incomplete deficit. It is still important  for these organizations to gain some type of profit to be able to purchase more equipment, technology, or even land to help provide quality care. For-profit vs. Not-for-profit Both for-profit and not-for-profit hospitals produce revenues through their daily operations and interactions. Unlike not-for-profit hospitals, for-profit hospitals are able to generate funds by issuing stocks. On the other hand, not-for-profit hospitals can accept tax-deductible contributions. The two different types of organizations generally have different ways of handling decisions regarding different financial and capital investments. A not-for-profit organization does not have the same opportunities for the capital structure that a for-profit organization does. In particular, a not-for-profit organization cannot sell new shares or ownership interests. Governmental Organizations Government organizations, like not-for-profit organizations, have no stockholders who receive the remaining assets when they are liquefied. Government health care organizations offer care to patients at a certain cost or agreed fee. The patient is responsible for a certain amount and the insurance is responsible for the remainder of the bill (Berger, 2008). Conclusion Healthcare finance is not always easy to grasp. It is important that one has a general understanding of how finances are managed in healthcare. It is essential for one to understand the differences in the types of organizations and it may help understand why certain decisions are made. It is also beneficial for one to stay updated on legislation in healthcare because it may directly shape the way that finances are handled. References Berger, S. (2008). Fundamentals of health care financial management. A practical guide to fiscal issues and activities. John Wiley & Sons. Centers for Medicare & Medicaid services. (2013). Retrieved from http://www.cms.gov/medicare-coverage-database/ Ebrahim, A. (2010). Nonprofit agency challenges. Journal Of Policy Analysis & Management, 29(3), 628-632. Gapenski, L. C. (2008) Healthcare finance: An introduction to accounting and financial management. (4th ed.). Chicago, IL: Association of University Programs in Health Administration. 0 replies | 0 drafts