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This paper examines empathetic behavior in the United States, a strongly individualistic country, as contrasted with Hungary and Ethiopia, which are moderately individualistic and strongly collectivistic respectively. It suggests that empathy may have a wider than originally perceived application in diverse settings to combat factors of ethnic bias and discrimination that adversely impact health. Models that distinctly focus on the development of healthcare provider empathic care are needed to enable the needs of resource scarce regions of the world to be met, including pockets of the U.S. More investigation is warranted on how empathic behavior can positively impact health outcomes and disparities.

Unhealthy eating habits and physical inactivity along with lack of access to quality healthcare contribute to the marked health disparities in chronic diseases among African–Americans. Faith-based public health conferences offer a potential opportunity to improve health literacy and change health behaviors through health promotion within this population, thereby reducing health disparities. This study examined the self-reported health behaviors and preventive healthcare utilization patterns of 77 participants at a predominantly African–American faith-based public health conference, Healthy Churches 2020. A self-administered questionnaire was distributed to a sample of attendees to assess their health behaviors (diet and physical activity), preventive healthcare utilization (annual healthcare provider visits), and health-promoting activities at their places of worship. The results indicate that attendees of a faith-based public health conference have adequate preventive healthcare utilization, but suboptimal healthy behaviors. Our findings support the need for ongoing health-promoting activities with an emphasis on diet and physical activity among this population.

Purpose The purpose of this article is to provide an overview of changing sleep patterns and common sleep disorders in older adults and to discuss treatment options of sleep disturbances within inpatient rehabilitation facilities (IRFs). Methods Through extensive review of the existing literature, common sleep disorders among older adults and several key factors that may impact sleep in older adults in inpatient rehabilitation facilities, such as behavioral and environmental factors, psychosocial and emotional factors, medical conditions, and medications were identified. Findings Current literature on the factors associated with sleep disturbance in older adults in IRFs is based on work with community‐dwelling older adults and those in long‐term care facilities. While interventions to address these disorders and research investigation key factors associated with sleep problems among older adults appear in the literature, there is very little work that applies these interventions within IRFs. Conclusions and Clinical Relevance Research is needed to examine the impact of sleep problems on older adults in IRFs, including work that focuses on intervention trials to identify successful treatments for these problems and translate those approaches into practice.

In New York, the applicable rule is New York Rules of Professional Conduct Rule 1.7, Conflict of Interest: Current Clients, which provides as follows: (a) Except as provided in paragraph (b), a lawyer shall not represent a client if a reasonable lawyer would conclude that either: (1)the representation will involve the lawyer in representing differing interests; or (2)there is a significant risk that the lawyer's professional judgment on behalf of a client will be adversely affected by the lawyer's own financial, business, property or other personal interests. (b) Notwithstanding the existence of a concurrent conflict of interest under paragraph (a), a lawyer may represent a client if: (1) the lawyer reasonably believes that the lawyer will be able to provide competent and diligent representation to each affected client; (2) the representation is not prohibited by law; (3) the representation does not involve the assertion of a claim by one client against another client represented by the lawyer in the same litigation or other proceeding before a tribunal; and (4) each affected client gives informed consent, confirmed in writing.1 In addition, because sponsor and portfolio representations often occur in a transactional setting, guidance might come from the Professional Ethics Committee of the New York City Bar Formal Opinion 2001-2, which applies factors including how adversarial the relationship is between the lawyer's clients and whether the lawyer has a disproportionately important relationship with one client compared to the other such that the lawyer truly can provide undivided loyalty to both clients.2 Additional rules apply in bankruptcy. Pursuant to New York Rules of Professional Conduct Rule 1.8, \"Current Clients: Specific Conflicts of Interest Rules,\" a lawyer shall not enter into a business transaction with a client if they have differing interests and if the client expects the lawyer to exercise professional judgment for the protection of the client unless (1) the transaction is fair and reasonable to the client, (2) the client is advised in writing of the desirability of seeking the advice of independent legal counsel on the transaction, and (3) the client gives informed written consent.12 May the lawyer truly provide undivided loyalty to both clients in these circumstances? If the portfolio company fails, is the lawyer \"disinterested\" under the Bankruptcy Code - i.e., is the lawyer one who does not have \"an interest adverse to the interest of the estate or of any class of creditors or equity security holders, by reason of any direct or indirect relationship to, connection with, or interest in, the debtor, or for any other reason\"?13 While not a case involving dual representation of sponsor and portfolio companies, the pending litigation between Jay Alix and McKinsey & Co. has highlighted the issue of such firm investments.14 Like law firms, financial advisors are also subject to the disinterestedness and disclosure requirements. A law firm that wishes to represent the portfolio company in its restructuring (many do, since debtor representation is more challenging and lucrative), but also continue to represent the sponsor on \"unrelated matters,\" must conclude that it can provide truly undivided loyalty to both clients, including on matters potentially adverse to the sponsor, and that its judgment will not be compromised if it must bite the hand that feeds it (i.e., the sponsor).15 Although the effect of a professional's personal investments in its sponsor clients (and ultimately the portfolio companies they own and control) is not yet decided in the Alix litigation, the U.S. Trustee and bankruptcy courts will likely look more closely at potential conflicts, disinterestedness and disclosures by professionals in these contexts.

The purpose of this article is to provide an overview of changing sleep patterns and common sleep disorders in older adults and to discuss treatment options of sleep disturbances within inpatient rehabilitation facilities (IRFs). Through extensive review of the existing literature, common sleep disorders among older adults and several key factors that may impact sleep in older adults in inpatient rehabilitation facilities, such as behavioral and environmental factors, psychosocial and emotional factors, medical conditions, and medications were identified. Current literature on the factors associated with sleep disturbance in older adults in IRFs is based on work with community-dwelling older adults and those in long-term care facilities. While interventions to address these disorders and research investigation key factors associated with sleep problems among older adults appear in the literature, there is very little work that applies these interventions within IRFs. Research is needed to examine the impact of sleep problems on older adults in IRFs, including work that focuses on intervention trials to identify successful treatments for these problems and translate those approaches into practice.

Furthermore, this group of patients requires more nursing hours of care and is more likely to have delayed discharge, which may result in a decline in health and an increase in hospital costs. Aim A multidisciplinary team of hospital staff who participate in a 60-min educational dementia presentation will demonstrate an increase in awareness, understanding, and an improved attitude toward dementia patients in a hospital setting. Recognizing this need may provide a better understanding of care for dementia patients in a hospital setting while decreasing the length of stay for hospitalization and the cost of care.

Furthermore, this group of patients requires more nursing hours of care and is more likely to have delayed discharge, which may result in a decline in health and an increase in hospital costs. Aim A multidisciplinary team of hospital staff who participate in a 60-min educational dementia presentation will demonstrate an increase in awareness, understanding, and an improved attitude toward dementia patients in a hospital setting. A two-part valid and reliable instrument named Questionnaire in Palliative Care for Advanced Dementia (qPAD), originally developed in 2006 (Long et. al., 2012), was used to measure staff's knowledge and attitudes of persons with dementia.

In response to the increase in accountability, based on federal and state legislation, educators have searched for factors to positively impact student achievement. The Coleman Report (1966) stated that student socioeconomic status was the greatest predictor of academic success. Researchers and educators alike have worked to demonstrate that other factors within a school's control may be powerful predictors as well and may assist schools in overcoming this environmental obstacle. The purpose of this study was to examine academic optimism as a construct consisting of academic emphasis, collective efficacy, and trust in students and parents and their relationship to instructional leadership behaviors and student achievement among a sample of urban elementary schools in Virginia. A convenience sample of 35 urban elementary schools in Virginia serving students K-5 was used to collect survey data from full-time teachers during a faculty meeting using the Norfolk Public Schools Teacher Climate Survey. Student achievement data were obtained from the 2008–2009 Virginia Standards of Learning assessment results in English and mathematics for students in grades 3–5. The initial factor analysis confirmed that academic optimism is a unified construct comprised of academic emphasis, collective efficacy, and trust in students and parents. The construct of instructional leadership was also confirmed using a factor analysis to ensure the survey items pulled together and measured along a common factor. Correlational analyses demonstrated a moderate, positive relationship between academic optimism and student achievement and academic optimism and instructional leadership even when controlling for socioeconomic status. Correlational analysis did not demonstrate a direct relationship between instructional leadership and student achievement. While limited, this study may offer educational practitioners insight on how instructional leaders can indirectly impact student achievement by creating a culture of academic optimism.

Lessors negotiating lease terminations with tenants in financial distress should be aware of two recent circuit court decisions highlighting a growing risk that a tenant's creditors might seek to claw back the value of the terminated lease if the tenant ends up in bankruptcy. In this context, many bankruptcy courts have strained to conclude that a noncollusive transfer may not be avoided, at times heavily relying on policy considerations and the potential negative impact of a contrary holding on the real estate markets.3 Prior to 2016, the circuit-level authority appeared to support the conclusions reached by the majority of the lower courts that a noncollusive pre-petition lease termination could not be avoided.4 Recent decisions from two different circuits have given rise to lessor concerns about the continued viability of lower court decisions protecting pre-petition lease terminations from avoidance, particularly when the trustee is seeking to recover money damages from the lessor (as opposed to attempting to resurrect, and then assume and assign, a previously terminated lease). Following the Fifth Circuit's decision in Hometown 2006-1 1925 Valley View LLC v. Prime Income Management LLC5 and the Seventh Circuit's decision in In re Great Lakes Quick Lube LP,6 the lessor's analysis of whether (and how) to terminate a lease pre-petition has become considerably more complicated, requiring significant review of the facts and circumstances underlying each lease, as well as consideration of whether and under what conditions the lessee might commence a bankruptcy case. Great Lakes Quick Lube Great Lakes Quick Lube operated...

U.S. District Court Judge James Zagel, who had withdrawn the reference to the bankruptcy court of the trustee's adversary proceedings against BNY Mellon, conducted a 17-day bench trial in 2010 and ruled in the bank's favor on all counts, notwithstanding the fact that he found (among other things) that the bank's officers had lied during the trial.12 In August 2012, the Seventh Circuit initially affirmed the district court's ruling, stating that while Sentinel's use of client funds as collateral to finance proprietary trading was \"quite troubling,\" those transfers were not made with fraudulent intent because Sentinel \"made the transfers to pay off one set of creditors in an attempt to save the enterprise from sinking. According to the Seventh Circuit, it is insufficient for a lender to simply rely on the loans documents and representations made by the borrower, as BNY Mellon did in this case, after concerns were raised about the borrower's account.