In September 2010, six months after the passage of the Affordable Care Act, a "BBC" article stated that among the "sticky charges" that had stuck against the bill was the false charge of "government 'death panels' deciding who can get what sort of care". A survey by the Regence Foundation and "National Journal" released in 2011 showed 40% of Americans knew that the "death panels" were not in the Affordable Care Act, while 23% said they thought the law allowed government to make end-of-life care decisions on behalf of seniors, and 36% said they did not know. Other findings from the survey included:  Atul Gawande, a physician who writes on health care topics for "The New Yorker", said "that the whole death panel reduction and reaction to it" temporarily "shut down our ability to even have a national discussion about how to have the right [end-of-life] conversation" between doctors and patients. When investigating for his article "Letting Go", Gawande was asked to refrain from writing about palliative care by physicians who were concerned the article might be manipulated to create another political controversy—and as a result, hurt their profession. Professor Harold Pollack wrote that given the "anxieties captured in the crystalline phrase 'death panel,' I would not commence a national cost-control discussion within the frightening and divisive arena of end-of-life care." Bishop "et al". were fearful of how their publication on CPR/DNR would be received by the medical and bioethics communities. They were concerned because in "the era of rhetoric centered on fictional 'death panels' " their paper addressed "the quest for immortality implicit in US culture, a culture of 'life-at-all costs' that medical technology has advanced". Bishop "et al". interpreted cautioning comments from their peers as a suggestion "that land mines of 'death panels' await us". PolitiFact gave Palin's claim its lowest rating—"Pants on Fire!"—on August 10 and on December 19 it was named "Lie of the Year" for 2009. "Death panel" was named the most outrageous term of 2009 by the American Dialect Society. The definition was given as "A supposed committee of doctors and/or bureaucrats who would decide which patients were allowed to receive treatment, ostensibly leaving the rest to die". FactCheck called it one of the "whoppers" of 2009. Megan Garber of the "Columbia Journalism Review" called the topic "irresistible" to reporters because it covered conflict, drama, innuendo, and Sarah Palin.