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.