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Cost-Benefit Analysis of Rules (independent of statutory impact)
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.
DIFS does not collect data on compliance costs associated with health care providers, as those providers are not
regulated by DIFS. Providers may incur some negligible costs associated with providing DIFS with requisite
information submissions or insurers responding to DIFS’ inquiries pursuant to the proposed rules. However, most
insurance companies already have personnel to handle these tasks, and virtually all providers have billing personnel.
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the
proposed rules.
Health care providers and automobile insurers will be directly affected by, bear the cost of, and in some cases directly
benefit from the proposed rules. However, these impacts are negligible independent of the statutory impact.
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.
Additional costs imposed on regulated entities or healthcare providers to comply with the proposed rules will be
associated primarily with information submission. However, any such additional costs should be relatively minimal
because most providers and insurers already have personnel that handle these tasks.
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.
As noted above in response to item 28, there will likely be negligible compliance costs associated with the proposed
rules. The proposed rules will not impose costs on the general public.
A. How many and what category of individuals will be affected by the rules?
Individual health care providers providing health or medical care to those injured in motor vehicles accidents will be
most affected by the rules. DIFS does not collect specific data on how many individual health care providers practice
in Michigan. However, during the promulgation of the Department’s Utilization Review Rules, it was determined
that there are approximately 43,000 licensed allopathic and osteopathic licensed physicians in Michigan, of which
approximately 65% are active in providing patient care. This number does not include health care professionals other
than physicians.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
The proposed rules, independent of statutory impact, should have minimal qualitative and quantitative impact on
these individuals.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
There are no cost reductions to businesses, individuals, groups of individuals, or governmental units as a result of the
proposed rules, independent of statutory impact.
31. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please
provide both quantitative and qualitative information, as well as your assumptions.
The primary and direct benefit of the proposed rules is to provide a clear and consistent process to administer the fee
schedules set forth in MCL 500.3157. The proposed rules provide a process to determine eligibility for enhanced
reimbursement rates.
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.
The proposed rules, independent of statutory impact, are not expected to impact business growth and job creation or
elimination.
33. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their
industrial sector, segment of the public, business size, or geographic location.
Health care providers and automobile insurers will be disproportionately affected by the proposed rules due to the
subject matter of MCL 500.3157, which the proposed rules implement.
34. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-
benefit analysis of the proposed rules.
MCL 24.245(3)