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There are no additional costs of any legal, consulting, or accounting services that small businesses would incur in
complying with the proposed rules.
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without
adversely affecting competition in the marketplace.
There are no additional costs small businesses have to absorb thereby causing economic harm to them as a result of
these rule changes.
25. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser
standards for compliance by small businesses.
There are no additional costs to the agency because the agency did not and cannot establish differing compliance or
enforcement requirements for small businesses. There is neither statutory authority, nor any practical way, to make
such a distinction.
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small
businesses.
These rules apply to all businesses no matter the type or size and none are exempt so it is difficult to identify what
might happen with lesser standards.
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.
A special committee of the State Bar, Workers’ Compensation Section, with counsel representing all stakeholders,
was convened, and provided bi-partisan input in the drafting of rules.
A. If small businesses were involved in the development of the rules, please identify the business(es).
No specific businesses were identified. Rather, counsel representing various businesses participated in the committee.
Cost-Benefit Analysis of Rules (independent of statutory impact)
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.
No additional estimated compliance costs due to the amendments are anticipated.
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the
proposed rules.
Attorneys; claims adjusters; carriers; self-insured employers and third-party administrators.
B. What additional costs will be imposed on businesses and other groups as a result of these proposed rules (i.e.
new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and number of businesses
and groups. Be sure to quantify how each entity will be affected.
These rules are meant to provide simplified case preparation and more efficient resolution of disputes thereby
benefiting all parties in the hearings process. No additional costs will be imposed on businesses or other groups as a
result of these proposed rules.
29. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or
the public). Include the costs of education, training, application fees, examination fees, license fees, new
equipment, supplies, labor, accounting, or recordkeeping.
No additional compliance costs are expected with the new rules.
A. How many and what category of individuals will be affected by the rules?
As of this writing, there are some 7,000 cases pending before the Board of Magistrates and 40 before the Appeals
Commission. Each case typically has one plaintiff and one employer. There may, however, in any given case,
multiple dependents on the employee side of the case and, in some instances, multiple employers on the other. Law
firms representing both sides, typically handle numerous cases so it is impossible to identify how many total
individuals will be involved.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
These rules are meant to provide simplified case preparation and more efficient resolution of disputes thereby
benefiting all parties in the appeals process.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
There should not be any significant cost reductions to businesses or government units as a result of these proposed
rules.
MCL 24.245(3)