Heidi Heitkamp actually said...

"That is one of your recommendations in your report, is that we actually look at written policies as it relates to guidance..."

"It looks like it is a shortcut to changing the rule."

"But, we should know what those requirements are from both the statute and the substantive rulemaking, and when it seems like we cross that rubicon, when we stop thinking that this is helpful in interp..."

"We all agree, hopefully, here that a guidance does not have the full force and effect of law, right?"