|Action||Appeal Regulation Updates|
|Comment Period||Ends 8/10/2016|
Appeal Regulation Updates
I fully agree with, and adopt in total, Mr. Joseph's comments. I question whether some of the proposed changes will pass constitutional muster. For example, the presumption concerning the receipt of email by a provider, where the provider must prove a negative, is virtually impossible to overcome. In addition, some amendments are inconsistent with the statutory mandates of the Administrative Process Act.
As a whole, these amendments are essentially designed to prevent the provider from ever being successful in an appeal. They are onerous and unnecessary.