3    appropriate benchmark against which to evaluate the care delivered at Angola. In  essence, Plaintiffs contend that Moore’s reliance on standards promulgated by the ACA,  a trade association, is fundamentally flawed and that standards articulated by the National  Commission on Correctional Health Care (“NCCHC”), which Plaintiffs represent were  developed by an association of medical professionals, authoritative on the minimal  standard of care.  The Defendants counter that Dr. Moore examined and provides opinions regarding  Angola’s medical delivery policies and practices and that the ACA was only one aspect  of review. Dr. Moore’s report points out that Angola “has referenced the American  Correctional Association Standards (ACA) in many of its policies.”11 Moore concedes that  the National Commission on Correctional Health Care (NCCHC) also publishes  standards, but she looked to the ACA standards, among others,12 because those are the  standards to which Angola’s policies refer.  II. ANALYSIS  The Plaintiffs’ challenge is to the basis of Dr. Moore’s opinions. Dr. Moore  described the NCCHC standards as “more aspirational” and the ACA standards as “more  realistic”.13 In any event, Moore testified that a correction facility “can practice care that  is not constitutional and still be accredited” under either the ACA or the NCCHC.14 The  Court finds that whatever standards the prison abides by, or fails to abide by, is one factor  in a fact intensive inquiry into whether the facility delivers adequate and reasonable care   11 Rec. Doc. 191-2, p. 4. 12 Moore indicates that she also relied on the “Nurse Practice Acts, Rules and Regulations for EMS staff.” Rec. Doc. 192-2, p. 4. 13 Rec. Doc. 192-3, p. 32. 14 Rec. Doc. 192-3, p. 37-38.  Case 3:15-cv-00318-SDD-RLB Document 321 09/27/17 Page 3 of 4