In 2006, then U.S. Senator Hillary Clinton introduced a bill to benefit lung cancer research. Six years later, by tucking it away in a totally unrelated bill, the U.S. Congress finally passed it.
If you just happened to be reading -- very carefully -- through the 1,170 page National Defense Authorization Act for Fiscal Year 2013 (H.R. 4310), on page 1,131, your will find Section 5022: Scientific Framework for Recalcitrant Cancers, which is also the Recalcitrant Cancer Research Act, which is also the Lung Cancer Mortality Reduction Act, originally introduced by Sen. Clinton in 2006.
The Recalcitrant Cancer Research Act moves pancreatic, lung cancer and other recalcitrant cancers to the front of the list of cancers to be evaluated by the National Cancer Institute (NCI) in developing a master plan of action for improved treatment methods. The bill gives the NCI 18 months to deliver its master plan of action to Congress.
The term "recalcitrant" is applied to such cancers because of their cells' tendency to remain dormant and undetected, often for years, only to begin to grow and spread through some yet undiscovered process.
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Perhaps bills which remain dormant in Congress, only to reappear years later, hidden in unrelated bills should be called "recalcitrant legislation."
For example, the Native American Apology Resolution, first proposed in 2004, and finally approved in 2009, tucked stealthily into the completely unrelated Defense Appropriations Act of 2010.
While the practice of including unrelated bills in the massive spending bills of the annual federal budget is common and legal under the rules of the legislative process, it results in a lack of transparency and openness in the workings of Congress, which many people already consider pretty "recalcitrant" itself.