However, providers often argue that decisions about treatment should be tailored to the needs of individual patients, and that this type of sensitivity to patient characteristics cannot be captured through adherence to simple rules. In a recent New York Times editorial, cardiologist Sandeep Jauhar argued that “. . . guidelinesand checklists are unpopular among most American providers. Instead of being allowed to deliver “patient-centered” care, manyproviders feel they are being co-opted by regulations. . . Guidelines are supposed to assist and advise. But all too often, recommended care in certain situations becomes mandated care in all situations.” (New York Times, Dec. 11, 2014). Moreover, the use of guidelines raises significant issues about how meaningful protocols are to be established.