8. Describe how the proposed rules protect the health, safety, and welfare of Michigan citizens while promoting a
regulatory environment in Michigan that is the least burdensome alternative for those required to comply.
This method is least burdensome because clients would not have the hardship of arranging transportation, childcare or
time off from work to attend an in-person interview. The proposed rules would protect citizens by not having them
exposed to the flu and COVID-19, in addition to MDHHS staff by not having them exposed to illnesses that the clients
may bring into the buildings.
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.
The portion in this rule that can be rescinded is the option of the MDHHS worker to make a house call to the client.
This was only given as an option when the number of individuals were applying for assistance was low and
manageable. Also, this was before COVID-19 and other illnesses were prevalent in our community.
Fiscal Impact on the Agency
Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e. hiring additional staff,
higher contract costs, programming costs, changes in reimbursements rates, etc. over and above what is currently
expended for that function. It does not include more intangible costs for benefits, such as opportunity costs, the value of
time saved or lost, etc., unless those issues result in a measurable impact on expenditures.
10. Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential savings
for the agency promulgating the rule).
The cost to the agency is minimal and may include technical changes for the correspondence to autogenerate a
telephone interview as well as notice costs associated to changing the rule under the administrative procedures act.
11. Describe whether or not an agency appropriation has been made or a funding source provided for any
expenditures associated with the proposed rules.
As part of the DHHS annual budget, funding is appropriated to address general technical and system changes, as well
as costs associated with proper notice, to clientele.
12. Describe how the proposed rules are necessary and suitable to accomplish their purpose, in relationship to the
burden(s) the rules place on individuals. Burdens may include fiscal or administrative burdens, or duplicative
The proposed rule is necessary to keep clients and employees safe and healthy from communicable diseases such as
the flu and COVID-19, and removes the anxiety and inability for a client to get a quicker eligibility finding due to
child care, transportation, an employment hardship. The burden is minimal compared to what could arise if this
change does not take into effect.
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable
compared to the burdens.
The proposed change is needed to ensure clients have access to benefits. Telephone technology has expanded greatly
and as an additional form of communication to access needed benefits is reasonable and easily implemented. The
change also ensures clients and State employees have minimal exposure to communicable diseases such as flu or
Impact on Other State or Local Governmental Units
13. Estimate any increase or decrease in revenues to other state or local governmental units (i.e. cities, counties,
school districts) as a result of the rule. Estimate the cost increases or reductions for other state or local
governmental units (i.e. cities, counties, school districts) as a result of the rule. Include the cost of equipment,
supplies, labor, and increased administrative costs in both the initial imposition of the rule and any ongoing
There are no anticipated costs to other state or local governmental units. The minimal costs should remain internal to
DHHS and only involving change of forms as needed.
14. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school
district by the rules.
There is no program, service, duty, or responsibility imposed on any city, county, town, village, or school district.