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Intent of congress and the laws plain words can be beneficial. i think normal they re issued by the department or agency that administered, health and human services, homeland security, department of commerce. they often, sometimes, they ask the office of legal counsel for their opinion about what the proper interpretation of the sfat out is. but i do think you raise a valid concern a guidance document cannot amount to an amendment of a law. brewer brewer owe drats do not have, department and agency attorneys and members don t have the ability to rewrite the law to make it say what they want to it say f we get away from that principle, we ve roded respect for law in the whole constitutional structure. where congress makes the laws not the executive branch. what about in the context of litigation where you re ....