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| Montana Administrative Register Notice 24-29-312 | No. 3 02/05/2016 | |
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BEFORE THE DEPARTMENT OF LABOR AND INDUSTRY OF THE STATE OF MONTANA
TO: All Concerned Persons
1. On November 25, 2015, the Department of Labor and Industry published MAR Notice No. 24-29-312 regarding a public hearing on the proposed adoption of the above-stated rules on page 2073 of the 2015 Montana Administrative Register, Issue No. 22.
2. On December 18, 2015, a public hearing was held at which time oral and written comments were received from the public. Additional written comments were received during the public comment period.
3. The department has thoroughly considered the comments and testimony of the public. The following is a summary of the public comments and the department's responses to those comments:
Comment 1: Commenters questioned how the department would ensure that reviewing physicians are neutral and qualified. Response 1: The department has contracted with an independent third party, a medical review organization (MRO), to recruit a pool of Montana-licensed physicians who are available to perform medical reviews. An MRO has been selected via a competitive solicitation process, and the contract with the vendor, Maximus, has been finalized. The MRO is responsible for recruiting and contracting with a sufficient number of Montana-licensed physicians in a range of medical specialties, who will review medical and other information and make recommendations regarding whether closed medical benefits should be reopened. The physicians will be working pursuant to a contract with the MRO, and the MRO is responsible for paying the physicians for the review services.
In addition, the MRO will receive the medical records and other information submitted by the parties. The MRO will organize and distribute the records and information to the reviewing physicians. The MRO will manage workflow so that panel physicians timely submit their reports to the department's medical director.
The department concludes that the physicians who will be recruited by the MRO, assigned by the MRO to individual reviews, and paid by the MRO for review services, are more likely to be independent than if the department was recruiting and scheduling reviews. The MRO has an existing pool of physicians, and the MRO will recruit and screen physicians to ensure that the panel members are properly licensed to practice in Montana. Physicians who have previously treated or examined an injured worker will not be eligible to serve as a reviewer for that worker.
Comment 2: Commenters stated that in order to be eligible to serve on a medical review panel, not only must the physician be licensed to practice in Montana, but also have hospital privileges as specified by 39-71-116(41)(a), MCA, and have been in practice for 5 years. Response 2: The department believes that had the Legislature intended to restrict reviewing physicians to those individuals who meet the criteria of being a "treating physician," that language would have been used. Administrative rules cannot impose additional qualifications when the qualifications are expressed in statute.
As to the suggestion that a reviewing physician have been in practice for 5 years, the department notes that the statutory criteria is that the physician have "expertise and experience" in the area of medicine that is relevant to the injured worker's medical condition. The department is not aware of any scientific studies that correlate a specific number of years of practicing medicine to having "expertise and experience" in a particular field of medicine. The department is amenable to being presented with such data, however, and to amending its rules in the future.
Comment 3: A commenter stated that the definition in NEW RULE II(13) of "physician" should not include any person who is not licensed under Title 37, chapter 3, MCA, and limit the term to individuals referred to in 39-71-116(41)(a), MCA. Response 3: As the commenter notes, the term "physician" is not expressly defined in the Workers' Compensation Act, although the term "treating physician" is defined in the Act. The department notes that there is a wide range of health care providers who are authorized to be a "treating physician" as defined in 39-71-116(41), MCA, and authorized to not only treat an injured worker, but to plan and coordinate the injured worker's medical care. The department concludes that had the Legislature intended to restrict the term, in the context of 39-71-717, MCA, solely to persons licensed under Title 37, chapter 3, MCA, it could have expressly made that limitation within the statute. In implementing the provisions of 39-71-717, MCA, the department concludes that it is reasonable to define, solely for the purposes of reviewing petitions to reopen medical benefits closed by operation of law, the term "physician" more broadly than just persons licensed under Title 37, chapter 3, MCA.
Comment 4: Commenters suggested that the injured worker be allowed to select one of the physicians who will be on the panel. Response 4: The panel members who are not the department's Medical Director will be selected by the MRO from a pool of Montana-licensed physicians, as described in Response 1. Because of the short time allowed by law for medical review, the department concludes that it is not feasible to consult with either the injured worker or the insurer about the prospective panel members who might have an appropriate medical specialty and workload that will allow the review to be performed timely. Even if a party selected a qualified physician to conduct a review, there is no assurance that the selected physician would be willing to perform the review within the time and other constraints imposed under the law.
Comment 5: Commenters stated that an injured worker should have the right to object to a physician selected as a panel member. Response 5: The department believes that both the injured worker and the insurer will have an opportunity to object to the qualifications of a selected physician during judicial review. The department concludes that given the 60-day timeline provided by 39-71-717, MCA, it is not feasible to provide either party with a pre-medical review challenge to a physician selected to be on the review panel. See also Response 16 for a more detailed description of business process used to comply with the 60-day timeline.
Comment 6: Commenters stated that the opinion of the treating physician should be taken into account by the medical reviewer(s). Response 6: The department agrees, to the extent that the opinion of the treating physician is reflected in the medical records or other information submitted as part of the review process. The department notes that the injured worker is allowed to submit medical records and additional information along with the petition, or within the 14-day submission period. The department suggests that medical records and other information be submitted with the petition, but does not require that medical records or other information be submitted contemporaneously with the petition.
Comment 7: Commenters stated that the department should direct members of the medical review panel to apply the Montana common-law rules of evidence in evaluating the medical reports and other information as part of the reopening process. Response 7: The department notes that the role of the medical review panel is to provide a professional evaluation of the information presented, not to make a legal determination. The department, through its MRO vendor, will provide training for panel members, including the appropriate evaluation of information presented as part of the review process.
Comment 8: Commenters stated that the reopening rules should be as simple as possible. Response 8: The department agrees, and believes that NEW RULES I through IX are as simple as reasonably feasible, given the text of the statute that the rules implement.
Comment 9: A commenter stated that in NEW RULE I(2)(c) the reference to claims where the insurer did not fully accept liability was somewhat ambiguous, and suggested defining when a claim is not "fully accepted." The commenter stated that it assumed that the phrase meant that the claim was denied, but was uncertain if that was the meaning. Response 9: The department agrees that the present wording is not as clear as it should be. The department has amended NEW RULE I accordingly.
Comment 10: Commenters suggested that the phrase "or occupational disease" be added where the current language only refers to an injury. Response 10: The department agrees with the comment and has amended NEW RULE I accordingly.
Comment 11: A commenter pointed out that certain phraseology used in NEW RULE VI(4) and in NEW RULE III(5)(a) and NEW RULE VIII(5) was not identical, and suggested that the phrase "nature and extent" be used consistently throughout the rules. Response 11: The department agrees with the comment, and has amended NEW RULE VI accordingly.
Comment 12: Commenters requested that rules expressly acknowledge that the recommendations of the medical director are subject to being overturned by the Workers' Compensation Court or the Montana Supreme Court. Response 12: The department acknowledges that virtually all of its decisions are subject to judicial review. The department believes that there is no dispute that the decision of a court of competent jurisdiction overturning a department determination is binding upon the department. The department concludes that the requested language is not needed, and would unnecessarily complicate the wording of the rules without providing meaningful clarification.
Comment 13: Commenters objected to the provisions of NEW RULE III(6) as being beyond the statutory authority granted to the department, and injects an additional layer of administrative review into the reopening process. Response 13: The department believes that the provisions of NEW RULE III(6) are reasonably necessary to implement 39-71-717, MCA, and the process for reopening medical benefits that are closed by operation of law. As noted in NEW RULE I(2)(c), the reopening process does not apply to claims where there is a dispute over the compensability of the underlying claim. The department reasons that if the insurer has not accepted liability for the underlying claim (including disputing liability by paying benefits pursuant to a reservation of rights), there are no medical benefits that have been determined to be owed to the injured worker, and therefore an entitlement to benefits has not begun. The provisions in question do not apply to situations where the insurer has accepted liability for the claim. The provisions do not apply where the insurer merely denies liability for certain medical conditions. The provisions of NEW RULE III(6) provide an insurer an opportunity to dispute that it has accepted liability for the claim, and that the reopening rules do not apply to the claim. While the department believes that such a scenario is unlikely to occur more than four years after the claim was submitted to the insurer, the department recognizes that such a possibility exists.
The department disagrees with commenter's suggestion that NEW RULE III(6) creates a new or additional layer of administrative review. To the contrary, NEW RULE III(6) makes it clear that the reopening process cannot make a determination of liability regarding the underlying claim, and directs the parties to mediation and the Workers' Compensation Court for resolution of the liability dispute.
In reviewing NEW RULE III(6) in response to the comments, the department has concluded that the phrase "rebuttable presumption" might be deemed to inappropriately imply a particular legal standard. Accordingly, the department has made minor changes to the wording used in the lead-in sentence for (6).
Comment 14: Commenters stated that the petition forms should be placed on the department web site for review and comment as part of the rulemaking process. Response 14: The department placed the draft petition forms on its web site during the public comment period. As noted in Response 15, the petition forms are being revised in response to comments made during the rulemaking process.
Comment 15: Commenters objected to provisions in the rules requiring that a petition be submitted on a department-approved form. The commenters suggested that any written request for reopening of closed medical benefits should be treated as a petition. The same commenters also stated that petitions not be rejected because of a failure to supply certain information. Response 15: In developing the internal business process for the reopening of medical benefits closed by operation of law and in drafting of these rules, the department considered what information was the minimum necessary to start the review process. The department decided that certain minimum information, identifying the injured worker (along with contact information) and the particular claim in question, is necessary to start the review process. In addition, the petition form contains an authorization for release of information for the purposes of the medical review process. The petition form developed by the department is a simple one page, "fill in the blanks" document, and is designed to be user-friendly. The department concludes that without sufficient identification of the injured worker and the claim (and therefore which insurer is on the risk), and a signed authorization for release of information, it is impossible to timely move forward with the review process. In response to these and related comments, however, the department has eliminated the field to describe the medical benefits requested to be reopened, and has amended the forms accordingly.
To the extent that the commenters object to using "the form" of the petition document provided by the department, the department will accept any writing that contains the required elements of information identified on the form, and an authorization, signed by the injured worker, for release of information that expressly allows the release of medical and other information for use in the medical review process. A writing which does not contain all of the required elements of information, or does not include a signed authorization for release of information will be rejected. A letter advising the injured worker of the rejection will specify the reason(s) for rejection.
Comment 16: Commenters questioned the department's ability to reject a petition, and stated that if the petition was incomplete, the missing information could be provided to the department at some point in the future. Response 16: The department notes that it has a maximum of 60 calendar days in which to review a petition and issue the medical director's report and recommendations. The 60-day clock begins to run on the date the petition is accepted. There is no statutory authority for "stopping the clock" if the petition is accepted despite it being incomplete. In order to complete the review and issue the medical director's report and recommendation, the acceptance of the petition triggers the 14-day period for medical records and other information to be provided by the insurer. Recognizing that an insurer has to be notified of the submission of the petition, it will be approximately the 17th day by which medical records and information must be submitted. While insurers and injured workers are requested to provide the information in electronic format, the department recognizes that some injured workers and some insurers might not have the capability to send documents electronically. If the department receives paper documents, they will have to be scanned into an electronic format. The department expects that by not later than the 20th day the information can be transmitted to the panel physicians for review. A panel member will have a maximum of 30 days in which to review the records and prepare a report and recommendation and return that report and recommendation to the department. The department's medical director will then have 10 days to review the three reports and prepare a consensus report and recommendations. In that 10-day period, it may be necessary to consult with the other panel members on matters that need clarification. In order to meet the statutory 60-day review period, the department concludes that it is not feasible to accept incomplete petitions.
Comment 17: Commenters stated that the department lacks authority to reject an incomplete petition if it pertains to a claim that is eligible for medical review. Response 17: The department is authorized by 39-71-203, MCA, to do all things necessary or convenient in the exercise of any power, duty, or jurisdiction conferred upon it by the Workers' Compensation Act. The department has a duty to implement the medical benefits reopening provisions contained in 39-71-717, MCA. The department believes that it has selected a reasonable method for implementing the statute, including requiring a properly completed petition form be submitted to the department, before the medical review process starts.
Comment 18: Commenters stated that there was no need for a joint petition form, and that an injured worker and an insurer were free to stipulate to continuing medical benefits. The commenters characterized the joint petition form as being "overly burdensome and oppressive" and that the department was "micromanaging" the contractual freedom of contract between the parties. Response 18: The department concludes that the commenters appear to misapprehend the purpose of NEW RULE VI and the joint petition process. As provided by NEW RULE VI(1), the filing of a joint petition is voluntary (". . . the worker and the insurer may file a joint petition for reopening.") The joint petition process is designed to provide a streamlined way for parties to enter into an agreement for the reopening of medical benefits that have closed by operation of law. The availability of the joint petition process in no way precludes an injured worker and an insurer from reaching an agreement or settlement. The reopening petition process described by NEW RULES I through IX is intended solely to implement the provisions of 39-71-717, MCA.
Comment 19: Commenters requested that the words "review and" be deleted from NEW RULE VI(3). Response 19: The department believes that pursuant to 39-71-717(3), MCA, a petition for reopening must undergo a review by the medical director, in order for the medical director to issue a report and recommendation. The department anticipates that the review will be cursory, however, in light of the agreement of the parties in a joint petition.
Comment 20: Commenters stated that 14 days is not a long enough period for the injured worker to submit medical records and other information. Response 20: Because the injured worker controls the timing of when the petition is submitted to the department, the department concludes that 14 days after the petition is accepted is a reasonable amount of time to provide medical records and additional information. The injured worker can submit medical records and additional information with the petition, if desired. As described in Response 16, there is a short 60-day period from the submission of the petition to the time a report and recommendation is due.
Comment 21: Commenters objected to the proposed use of consultants to assist panel members in the medical review process, and stated that using a consultant constituted an improper ex parte contact and violated the rights of injured workers. Response 21: While the department disagrees that there would be anything improper about using an independent consultant in conjunction with the review process, the department concludes that the use of consultants as an aid to panel physicians does not appear to be necessary at this time. The department has amended the rules to remove the references to using consultants.
Comment 22: Commenters stated that if non-physician medical consultants are used as part of the review process, that fact and the substance of the consultation should be disclosed. Response 22: The department agrees with the comment, but as noted in Response 21, it is deleting the use of consultants from the rules.
Comment 23: A commenter asked whether the parties would automatically receive a copy of all physician or consultation reports, along with the medical director's report and recommendation. Response 23: The department does not intend to automatically send those other reports to the parties. Those "other reports" will be provided to a party upon written request, however. The department will monitor whether there are requests for "other reports" in a significant portion of reopening petition cases. If there are, the department will, as a business practice, begin providing those reports to the parties without the need for a party to make a written request. As noted above, the department is eliminating the provisions regarding consultants.
Comment 24: Commenters stated that an injured worker should be able to withdraw an election to have the medical review conducted by the medical director only (as opposed to the three-member panel). Response 24: The department concludes that the mutual agreement of an injured worker and the insurer to review by the medical director only should be given effect. Review by the medical director only is available only when the injured worker has agreed to such a review. The department concludes that given the 60-day timeline provided by 39-71-717, MCA, it is not efficient or feasible to send the medical reports and other information to two panel members after the election has been made.
Comment 25: Commenters objected to the use of the standard for reopening as being treatment needed to look for work or to continue to work as being contrary to Montana case law and public policy. Response 25: The standard that medical benefits be reopened only when injured workers' medical condition is a direct result of the compensable injury or occupational disease and "requires medical treatment in order to allow the worker to continue to work or return to work" is the exact wording used by 39-71-717(2), MCA. The department, as an executive branch agency, is bound by the statutory language, and cannot enlarge or reduce the scope of the standard. The department respectfully suggests that comments about what the public policy ought to be in this matter are more appropriately directed to the Montana legislature.
Comment 26: Commenters objected to the inclusion of the burden of proof provisions in NEW RULE VIII(3). Response 26: While the department believes that the statement regarding the burden of proof accurately reflects Montana law, the department concludes that the burden of proof provision may be removed from the rule without effect, and has amended the rule accordingly.
Comment 27: Commenters stated that it is impossible for medical reviewers to perfectly predict the future medical needs of injured workers, and specify the specific procedures, testing, and times necessary. Response 27: The department agrees with the comment. The recommendations of further medical care will necessarily be general, and will (as required by 39-71-717(8), MCA) direct that such care be consistent with Montana's utilization and treatment guidelines. The department does not expect the medical review will result in recommendations for a specific treatment or care regimen, unless the injured worker and the insurer have agreed to specific treatments, timing, or duration of care, and have submitted a joint petition.
The department does not expect that a decision to reopen medical benefits will in any way diminish the responsibility of an insurer to properly administer a claim. Disputes concerning the necessity or appropriateness of specific treatments will be subject to the dispute resolution process provided by law for disputes between injured workers and insurers concerning benefits.
Comment 28: Commenters stated that any delay in providing needed medical benefits worked to the advantage of the insurer and to the detriment of the injured worker. The commenters stated that the rules should not reference the nature, extent, or scope of the medical benefits being reopened, and that medical benefits should be reopened, period. Response 28: Pursuant to 39-71-717(8), MCA, the medical report "must state the extent to which the benefits must be reopened consistent with the utilization and treatment guidelines." In addition, the benefits reopened "remain open for 2 years or until maximum medical improvement is achieved following surgery or the recommended medical treatment, whichever occurs first." The department concludes that its rules appropriately implement the statutory provisions established by the Legislature.
Comment 29: Commenters suggested that specifying the nature and extent of the benefits to be reopened would cause injured workers to need to repeatedly file petitions as the injured worker's medical condition changed or deteriorated. Response 29: The department again concludes that the commenters appear to misapprehend what will be recommended by the medical report. It is impossible for the medical reviewer to forecast with precision the future medical needs of an injured worker. Absent a general agreement by the injured worker and the insurer as to what medical benefits should be reopened, and the extent and duration of those benefits, the medical report will recommend that if medical benefits should be reopened, that the benefits are reopened for the purposes provided by statute (to enable the injured worker to return to work or remain at work), and that those medical benefits be provided as needed, in a manner consistent with the utilization and treatment guidelines. See also Response 27. Accordingly, the department believes that it will not be necessary for injured workers to need to file multiple petitions for reopening.
Comment 30: A commenter questioned, in regards to NEW RULE III(2)(b)(ii), whether an injured worker could submit a second or subsequent petition for reopening. Response 30: No. The department believes that 39-71-717, MCA, does not contemplate successive petitions being considered. The department is aware that the underlying legislation was designed to "close claims" after 5 years from the date of injury. The department notes that the injured worker controls the timing of the submission of the petition for reopening, and has more than a 5-year window to request reopening. The department believes that in that light, it is not rational or efficient to have a system that allows multiple petitions for reopening, or for an injured worker to request reopening of medical benefits "just in case" they might be needed at some point in the future. The department therefore concludes that multiple petitions are not consistent with the legislative intent regarding closure of medical benefits by operation of law.
Comment 31: Commenters stated that 39-71-717, MCA, was likely unconstitutional, and that therefore, any rules implementing the statute would also be unconstitutional. The commenters stated that state agencies have the ability to not fully implement unconstitutional statutes. The commenters asked the department to revise its rules so as not to violate injured workers' constitutional rights. Response 31: The department notes that as an executive branch agency, it cannot usurp the authority of the judicial branch to declare that a statute is unconstitutional, nor can it substitute its judgment for the Legislature's judgment, as to appropriateness of the public policy expressed in statute. The department believes that the rules as proposed do not violate an injured worker's constitutional rights.
Comment 32: Commenters asserted that the proposed medical review process, including the use of consultations, constitutes an unlawful ex parte communication with medical providers, and violates the various rights of injured workers. Response 32: Because the department is not communicating with any of the health care providers furnishing treatment to the injured worker, the department concludes that there is no prohibited ex parte communication. The department's reopening rules implement the requirements of 39-71-717, MCA, which require that independent physicians review the medical records and other information concerning the injured worker in order to make a recommendation concerning the reopening of medical benefits that have closed by operation of law. In addition, the department rejects any implication that, like an insurer, it has any financial or other adverse interest to an injured worker. The department concludes that the proposed reopening process does not violate the rights of injured workers due to its contact with independent medical reviewers.
Comment 33: Commenters generally asserted that the rules and petition forms demonstrated an "inherent bias" and created additional barriers to injured workers obtaining the quid pro quo of the Workers' Compensation Act. Response 33: The department respectfully suggests that insofar as the commenters believe that the Workers' Compensation Act is inherently biased against the rights of workers, and unduly favors the rights of employers and insurers, the commenters should direct their concerns and arguments to the legislative branch of government. The department lacks the authority to revise the Workers' Compensation Act to make systemic changes which the commenters believe are appropriate and necessary for the protection of injured workers.
Comment 34: Commenters suggested that the department should order an insurer to immediately begin paying medical benefits recommended as the medical director's report and recommendation, and that the insurer's duty to pay is not stayed by judicial review. Response 34: The department respectfully suggests that the commenters appear to have misapprehended the effect of the department's reopening of closed medical benefits. The department does not expect that it will provide a "laundry list" of specific treatments and treatment intervals in its recommendation. See Response 29. Instead, the department expects that it will recommend the reopening of medical benefits to the extent needed by the injured worker in order to return to work or stay at work. Insurers have a duty to act reasonably in paying benefits, and the department views reopened medical benefits as being subject to that same obligation. The department further concludes that 39-71-717, MCA, does not grant the department authority to order an insurer to pay specific benefits.
Comment 35: A commenter suggested that the department should require insurers to provide notice to injured workers of the pending closure of medical benefits 120, 90, 60, and 30 days in advance of the closure by operation of law, and at the time of closure. Response 35: The department concludes that it lacks statutory authority under 39-71-704 or 39-71-717, MCA, to require insurers to provide the notifications requested by the commenter.
Comment 36: A commenter asked whether the department would send to the injured worker a copy of all the medical records and other information submitted by the insurer. Response 36: No. Each party has a responsibility under NEW RULE V(1)(b) to send the other party any medical records or other information which the other does not have. An injured worker can get a copy of the medical records contained in the insurer's claim file by requesting them directly from the insurer.
Comment 37: Commenters stated there is no statutory basis for having the biennial medical review conducted only by the medical director, as opposed to review by a panel. Response 37: The department believes that in light of the presumption of correctness of the original medical director's report and recommendation provided for by 39-71-717, MCA, it is reasonable to have the medical director conduct the biennial review to determine if the previous recommendation is still appropriate. If the appropriateness of the previous recommendation is questioned, then a panel review will take place before any change can be made to the original recommendation. Likewise, the department believes that it is reasonable, when the parties originally agreed to a medical director only review, to continue using only the medical director for the biennial review.
4. The department has adopted the following rules as proposed, but with changes from the original proposal, new mater underlined, deleted matter interlined:
NEW RULE I (24.29. 3101) INTRODUCTION - APPLICABILITY - VOLUNTARY PAYMENTS (1) through (2)(b) remain as proposed. (c) in which the insurer did not (d) arising on or after July 1, 2011, where the injury or occupational disease results in: (i) permanent total disability; or (ii) the fitting of a prosthesis which may need to be repaired or replaced. (3) through (5) remain as proposed.
AUTH: 39-71-203, MCA IMP: 39-71-105, 39-71-107, 39-71-704, 39-71-717, MCA
NEW RULE III (24.29.3107) TIMELINES AND EXPLANATION OF STATUS CLASSIFICATIONS OF A PETITION (1) through (5) remain as proposed. (6) (a) through (7) remain as proposed.
AUTH: 39-71-203, MCA IMP: 39-71-717, MCA
NEW RULE VI (24.29.3117) JOINT PETITION FOR REOPENING (1) through (3) remain as proposed. (4) In recognition that following the filing of the worker's petition, the parties may come to a voluntary agreement as to the nature and
AUTH: 39-71-203, MCA IMP: 39-71-717, MCA
NEW RULE VII (24.29.3121) REVIEW BY MEDICAL DIRECTOR - CONSENT OF BOTH PARTIES (1) remains as proposed. (3) through (5) remain as proposed, but are renumbered (2) through (4).
AUTH: 39-71-203, MCA IMP: 39-71-717, MCA
NEW RULE VIII (24.29.3124) REVIEW BY MEDICAL REVIEW PANEL - REPORT AND RECOMMENDATIONS (1) Unless both the worker and the insurer agree to have a petition for reopening reviewed solely by the department's medical director, the petition will be reviewed by a three-member panel of physicians. (2) remains as proposed. (4) through (7) remain as proposed, but are renumbered (3) through (6).
AUTH: 39-71-203, MCA IMP: 39-71-717, MCA
5. The department has adopted the following rules as proposed: NEW RULE II (24.29.3103), NEW RULE IV (24.29.3111), NEW RULE V (24.29.3114), and NEW RULE IX (24.29.3127).
/s/ MARK CADWALLADER /s/ PAM BUCY Mark Cadwallader Pam Bucy, Commissioner Alternate Rule Reviewer DEPARTMENT OF LABOR AND INDUSTRY
Certified to the Secretary of State January 25, 2016.
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