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D. Describe how the agency established performance standards to replace design or operation standards required
by the proposed rules.
The agency did not and cannot establish differing compliance or reporting requirements for small businesses. There
is neither statutory authority, nor any practical way, to make such a distinction.
20. Identify any disproportionate impact the proposed rules may have on small businesses because of their size or
geographic location.
There is no disproportionate impact on small businesses identified.
21. Identify the nature of any report and the estimated cost of its preparation by small businesses required to
comply with the proposed rules.
Reporting is done by carriers and costs cannot be identified. There are no filing or processing fees for statutory or
regulatory filing requirements.
22. Analyze the costs of compliance for all small businesses affected by the proposed rules, including costs of
equipment, supplies, labor, and increased administrative costs.
There are no additional costs for compliance including costs for equipment, supplies, labor, and increased
administrative costs for small businesses.
23. Identify the nature and estimated cost of any legal, consulting, or accounting services that small businesses
would incur in complying with the proposed rules.
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.
The agency did not and cannot establish differing compliance or reporting requirements for small businesses. There
is neither statutory authority, nor any practical way, to make such a distinction.
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 and claimants.
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.
No additional costs anticipated.
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.
MCL 24.245(3)