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| Montana Administrative Register Notice 24-29-228 | No. 8 04/24/2008 | |
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BEFORE THE DEPARTMENT OF LABOR AND INDUSTRY STATE OF MONTANA
In the matter of the proposed amendment ) NOTICE OF PUBLIC of ARM 24.29.1402, 24.29.1404, ) HEARING ON PROPOSED 24.29.1406, 24.29.1416, 24.29.1427, ) AMENDMENT, AMENDMENT 24.29.1430, 24.29.1431, and 24.29.1522, ) AND TRANSFER, AND the proposed amendment and transfer of ) ADOPTION 24.29.1504, and the proposed adoption of ) NEW RULE I, all related to the workers' ) compensation medical fee ) schedule for facilities )
TO: All Concerned Persons
1. On May 16, 2008, at 9:00 a.m., the Department of Labor and Industry (department) will hold a public hearing to be held in Room 152, Capitol Building, Helena, Montana, to consider the proposed amendment, amendment and transfer, and adoption of the above-stated rules.
2. The department will make reasonable accommodations for persons with disabilities who wish to participate in this public hearing or need an alternative accessible format of this notice. If you require an accommodation, contact the department no later than 5:00 p.m., on May 9, 2008, to advise us of the nature of the accommodation that you need. Please contact the Workers' Compensation Regulations Bureau, Employment Relations Division, Department of Labor and Industry, Attn: Jeanne Johns, P.O. Box 8011, Helena, MT 59624-8011; telephone (406) 444-7710; fax (406) 444-3465; TDD (406) 444-5549; or e-mail jjohns@mt.gov.
3. GENERAL STATEMENT OF REASONABLE NECESSITY: The 2007 Legislature passed Chap. 330, L. 2007 (HB 738) and Chap. 117, L. 2007 (SB 108). These sections of law require the Department of Labor and Industry to establish administrative rules setting the reimbursement rates for facilities that provide medical services to injured workers. Through this notice, the department is proposing to adopt a Medicare-based fee schedule for workers' compensation reimbursement. The department proposes this approach because Medicare is a nationally recognized system that is already widely used and understood by many health care providers. Further, in comparison to the previously established fee schedule system, the Medicare fee schedule is more uniform because the methodology results in a predictable reimbursement no matter where in the state the injured worker is treated. A Medicare system also provides cost containment because it is based on costs rather than charges. Using this fee schedule would also allow comparison of workers' compensation rates to Medicare and to other commercial payer rates which also use the Medicare methodology.
The department developed proposed NEW RULE I (the Medicare-based fee schedule) following substantial consultations with a leading medical fee schedule developer, INGENIX Corp, representatives from Plan No. 1, No. 2, and No. 3 (including third-party administrators), and representatives of acute care hospitals and ambulatory surgical centers. Proposed NEW RULE I represents what the department believes is a consensus on the appropriate methodology for a facility fee schedule between the providers and the payors (insurers) as to what a new facility fee schedule should include.
In addition to proposing a Medicare-based fee schedule, the rules propose to change the terminology where needed in order to clarify that the proposed rules cover all providers that care for an injured worker including ambulatory surgery centers, known as ASCs. Previously, ASCs were not regulated by the fee schedules developed pursuant to the Workers' Compensation Act. As a result, ASCs were being reimbursed at 100 percent of billed charges, which is not comparable with hospital outpatient service medical reimbursements. The department's general requirement to set fees pursuant to Chapter 330 includes ASCs. In order to clarify that ASCs will be included in the fee schedule, the department proposes to use the term "facility" throughout because the term includes both hospitals and ASCs.
The department believes that there is reasonable necessity to amend, rather than repeal, the existing fee schedule rules despite the fact that some of the rules will be superseded by new rules for services provided on or after July 1, 2008. The department believes that disputes over medical services and fees payable sometimes linger for years, and that payment of old bills can be handled more promptly when the applicable rules are still "on the books."
The department also believes that in some cases, adoption of new rules will be less confusing than merely amending the existing rules and in other cases, amending the existing rules will suffice. Where rules are simply amended, the old version of the rule applies until the amendment takes effect and the new version applies on or after the effective date. The department notes that when new rules are adopted, each will be assigned a unique rule number, which will assist providers, insurers, and the department in making sure that the correct rule is being applied with respect to services furnished on or after the applicability date of the rule. The department believes that the adoption of the proposed new rule makes it more likely that the correct payment is made by the insurer to the provider.
The department is proposing that the amendments and NEW RULE I will apply to services that are rendered on and after July 1, 2008. The department recognizes that depending on the comments received during the public comment process, a July 1, 2008, applicability date may not be feasible, and that a somewhat later applicability date may be appropriate. The department reserves the right, in light of comments, to adjust the applicability dates in the proposed rule amendments and NEW RULE I so that facilities and payors have a reasonable time in which to prepare for implementation of the final version of the amendments and new rule.
This general statement applies to all the proposed rules changes, with specific or additional rationales included for each rule.
4. The rules proposed to be amended provide as follows, stricken material interlined, new material underlined:
24.29.1402 PAYMENT OF MEDICAL CLAIMS (1) Payment of medical claims (2) through (7) remain the same.
AUTH: 39-71-203, MCA IMP: 39-71-203, 39-71-510, 39-71-704, MCA
REASON: There is reasonable necessity to change the terminology in the rule from "nonhospital medical fees and hospital rates" to "facility and nonfacility medical fees" due to the changes enacted by Chapter 330. The proposed change in terminology clarifies that ASCs will be covered by the new rules. For any services provided before the effective date of the amended rule, ASCs will continue to be reimbursed at 100 percent of charges. Following the effective date of the amendments, ASCs will be reimbursed according to the proposed fee schedule. The department is proposing that the amendments will take effect on July 1, 2008.
24.29.1404 DISPUTED MEDICAL CLAIMS (1) and (2) remain the same. (3) (4) remains the same.
AUTH: 39-71-203, MCA IMP: 39-71-203, 39-71-704, MCA
REASON: There is reasonable necessity to change the terminology in the rule due to the changes enacted by Chapter 330. The proposed amendments change the reference from "hospital" records to "facility" records, thereby clarifying the terminology to include not only hospital services, but services provided by an ASC. Because the change is minor and straightforward, the department does not believe it is necessary to propose a new rule with a beginning date to address the issue of including ASCs in the rule's requirements.
24.29.1406 (2) To the extent possible, electronic billing must be utilized by both providers and payers in the billing and reimbursement process to facilitate the rapid transmission of data, lessen the opportunity for errors, and lessen system costs. (3) It is the responsibility of the facility to use the proper service codes on any bills submitted for payment. The failure of a provider to do so, however, does not relieve the insurer's obligation to pay the bill, but it may justify delays in payment until proper coding of the services provided is received by the insurer. (4) Insurers must make timely payments of facility bills. In cases where there is no dispute over liability, the insurer must, within 30 days of receipt of a facility's charges, pay the charges according to the rates established by these rules. (5) Insurer-initiated medical necessity review, claim audits, and other administrative review procedures must be conducted on a post-payment basis.
AUTH: 39-71-203, MCA IMP: 39-71-105, 39-71-107, 39-71-203, 39-71-704, MCA
REASON: There is reasonable necessity to amend this rule to implement changes enacted by Chapter 330. The proposed changes clarify the terminology to include not only hospital services, but services provided by an ASC. In addition, because ARM 24.29.1427 is proposed to have a specific ending date for its applicability, language in (4) which is based on ARM 24.29.1427 is proposed to be added here because it will continue to apply to all services provided. This language naturally falls within the subject of the payment process used for submission and payment of facility bills. In addition, the rule requires the electronic submission of bills to the extent possible to lessen the errors in the system that have been reported to the department. Finally, regarding (5), the rates proposed by the department assume that prompt payment is made by the insurer to the health care provider because of the time value of money. Numerous providers have indicated to the department that payment is often delayed by insurers. The proposed rules clarify that insurers may continue to dispute medical necessity and conduct other claim audits, but those activities must be conducted on a post-payment basis.
24.29.1416 APPLICABILITY OF DATE OF INJURY, DATE OF SERVICE (1) The amounts of the following types of payments are determined according to the specific department rates in effect on the date the medical service or services are (a) remains the same. (b) (c) remains the same. (d) (2) When services, procedures, or supplies are bundled for purposes of billing and the bundling covers more than one day, the first date a service, procedure, or supply is furnished must be used as the date provided for purposes of this rule.
AUTH: 39-71-203, MCA IMP: 39-71-704, 39-71-727, MCA
REASON: There is reasonable necessity to change the terminology in the rule due to the changes enacted by Chapter 330. The rule directs that payments for medical services be determined by the specific department rates in effect on the date the medical service is provided. The proposed amendments change the terminology from hospital to facility in order to include ASCs. The changes also recognize the new bundling payment methodology used with MS-DRG and APC coding. Because the change is minor and straightforward, the department does not believe it is necessary to propose a new rule with a proposed beginning date.
24.29.1427 HOSPITAL SERVICE RULES FOR (2) and (3) remain the same.
AUTH: 39-71-203, MCA IMP: 39-71-704, MCA
REASON: There is reasonable necessity to amend ARM 24.29.1427 to implement changes enacted by Chapter 330. This proposed change corrects an error in the previous adoption to specify that the rule applies to services provided during the specified timeframe rather than claims arising on or after the specified timeframe. Because NEW RULE I is proposed to direct payment of facility bills on or after July 1, 2008, the proposed changes also set an ending date.
24.29.1430 HOSPITAL RATES FROM JULY 1, 1998, THROUGH JUNE 30, 2001 (1) through (3) remain the same.
AUTH: 39-71-203, MCA IMP: 39-71-704, MCA
REASON: There is reasonable necessity to amend the catchphrase to clarify the dates of applicability of the rule. This proposed change corrects an error in the previous adoption to specify that the rule applies to services provided during the specified timeframe.
24.29.1431 HOSPITAL RATES FROM
AUTH: 39-71-203, MCA IMP: 39-71-704, MCA
REASON: There is reasonable necessity to amend ARM 24.29.1431 to implement changes enacted by Chapter 330. NEW RULE I is proposed to direct payment of facility bills on or after July 1, 2008, so the proposed change sets an ending date.
24.29.1522 MEDICAL EQUIPMENT AND SUPPLIES FOR DATES OF SERVICE ON OR AFTER JANUARY 1, 2008 (1) This rule applies to (2) Except for prescription medicines as provided by ARM 24.29.1529, reimbursement for (a) remains the same. (3) If a provider adds value to (4) remains the same.
AUTH: 39-71-203, MCA IMP: 39-71-704, MCA
REASON: There is reasonable necessity to amend the term "medical equipment and supplies" to "DME" in this rule in order to correspond with the proposed definition changes in ARM 24.29.1504. The definition is proposed to be changed from medical equipment and supplies to DME because DME is the term more commonly referred to by users of these rules.
5. The rule proposed to be amended and transferred provides as follows, stricken material interlined, new material underlined:
24.29.1504 (24.29.1401A) DEFINITIONS As used in (1) "Acute care hospital" or "hospital" means a health care facility appropriately licensed by the Department of Public Health and Human Services that provides inpatient and outpatient medical services to injured workers experiencing acute illness or trauma. Acute care hospitals are sometimes referred to as regulated hospitals. (2) "Ambulatory Payment Classification (APC)" means the reimbursement system adopted by the department for outpatient services. (3) "Ambulatory surgery center (ASC)" means a health care facility that operates primarily for the purpose of furnishing outpatient surgical services to patients. (4) "Base rate" means the dollar value which is multiplied by the relative weight of the MS-DRG or APC to determine payment. (5) "Bundling" means the practice of grouping multiple services, procedures, and supplies into one charge item instead of billing each separately. (6) "CMS" means the Centers for Medicare and Medicaid Services. (7) "Correct Coding Initiative (CCI)" means the code edits adopted by the department that are used to correct contradictory billing information.
(2) remains the same but is renumbered (9). (10) "Durable medical equipment (DME)" means durable medical appliances or devices used in the treatment or management of a condition or complaint, along with associated nondurable materials and supplies required for use in conjunction with the appliance or device. (3) and (4) remain the same but are renumbered (11) and (12).
(14) "Implantable" means an object or device that is made to replace and act as a missing biological structure that is surgically implanted, embedded, inserted, or otherwise applied. The term also includes any related equipment necessary to operate, program, and recharge the implantable. (6) remains the same but is renumbered (15). (16) "Inpatient services" means services rendered to a person who is formally admitted to a hospital and whose length of stay exceeds 23 hours.
(17) "Medicare-Severity Diagnosis Related Group (MS-DRG or DRG)" means the inpatient diagnosis classifications of circumstances where patients demonstrate similar resource consumption, length of stay patterns, and medical severity status that are adopted by the department and are used for billing purposes. (8) and (9) remain the same but are renumbered (18) and (19). (20) "Outpatient" means a patient who is not admitted for inpatient or residential care. (10) through (12) remain the same but are renumbered (21) through (23). (24) "Ratio of cost to charges (RCC)" means the computed ratio using charges and the hospital's Medicare cost report. (13) and (14) remain the same but are renumbered (25) and (26). (27) "Service or services" means procedures, services, and supplies. (28) "Status indicator (SI)" codes mean CPT codes treated in the same fashion or category, such as packaged services. (15) and (16) remain the same but are renumbered (29) and (30).
AUTH: 39-71-203, MCA IMP: 39-71-704, MCA
REASON: There is reasonable necessity to amend ARM 24.29.1504 to implement changes enacted by Chapter 330. The proposed amendments add new definitions for terms used in or required by the Medicare rate schedule being proposed in NEW RULE I for services provided by a facility, as those terms are not commonly understood but are an integral part of the proposed fee schedule. The proposed amendments also transfer the rule from subchapter 15 to 14 so that all the definitions apply to both subchapters.
6. The proposed new rule provides as follows:
NEW RULE I FACILITY SERVICE RULES AND RATES FOR SERVICES PROVIDED ON OR AFTER JULY 1, 2008 (1) The department adopts the fee schedules provided by this rule to determine the reimbursement amounts for medical services provided at a facility on or after July 1, 2008. An insurer is not obligated to pay more than the fee provided by the fee schedules for a service provided within the state of Montana. The fee schedules, available on-line via the internet at http://erd.dli.state.mt.us/wcregs/medreg.asp, are comprised of the following elements: (a) The Montana Hospital Inpatient Services MS-DRG Reimbursement Fee Schedule; (b) The Montana Hospital Outpatient and ASC Fee Schedule Organized by APC; (c) The Montana Hospital Outpatient and ASC Fee Schedule Organized by CPT/HCPCS; (d) The Montana Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Fee Schedule; (e) The Montana Ambulance Fee Schedule; (f) The Montana CCI Code Edits Listing; (g) The Montana RCC and other Montana RCC-based Calculations; (h) The base rates and conversion formulas established by the department. (2) The application of the base rate depends on the date the medical services are provided. (3) Critical access hospitals and medical assistance facilities are reimbursed at 100 percent of the usual and customary charges. (4) Any services provided by a type of facility not explicitly addressed by this rule must be paid at 75 percent of usual and customary charges. (5) Hospitals and ASCs must, on an annual basis, submit to the department data reporting Medicare, Medicaid, commercial, unrecovered, and workers' compensation claims reimbursement in a standard form supplied by the department. Hospitals and ASCs must also, on an annual basis, submit to the department copies of audited financial reports. The department may in its discretion conduct audits of any facility financial records to confirm the accuracy of submitted information. (6) Individual medical providers who furnish professional services in a hospital, ASC, or other facility setting must bill insurers directly and must be reimbursed using the nonfacility fee schedule. Those reimbursements are excluded from any calculation of outlier payments. (7) Facility pharmacy reimbursements are made as follows: (a) If a facility pharmacy dispenses prescription drugs to an individual during the course of treatment in the provider's facility, reimbursement is part of the MS-DRG or APC reimbursement. (b) If a patient's medications are not included in the MS-DRG or APC service bundle, a pharmacy or pharmacist located in a facility must be reimbursed pursuant to ARM 24.29.1529. (8) The following applies to inpatient services provided at an acute care hospital: (a) The department may establish the base rate annually. (i) Effective July 1, 2008, the base rate is $7,735. (b) Payments for inpatient acute care hospital services must be calculated using the base rate multiplied by the Montana MS-DRG weight. For example, if the MS-DRG weight is 0.5, the amount payable is $3,867.50, which is the base rate of $7,735 multiplied by 0.5. (c) The threshold for outlier payments is $50,000 plus the Montana MS-DRG payment amount. If the outlier threshold is met, the outlier payment must be the MS-DRG reimbursement amount plus the charges above the threshold multiplied by the sum of 15 percent and the specific hospital's operating RCC. The total payment for the services is the outlier payment plus the Montana MS-DRG payment. (i) For example, if the hospital submits total charges of $100,000, the MS-DRG reimbursement amount is $35,000, and the RCC is 0.50, then the resultant calculation for reimbursement is as follows: The $35,000 is added to the threshold amount ($50,000) and the difference between the sum ($85,000) and the charges ($100,000) of $15,000 would be multiplied by .65 (the RCC of .5 plus .15) to obtain the outlier payment of $9,750. The total payment to the hospital in this example would be $35,000 + $9,750 = $44,750. (ii) The department may establish the inpatient outlier amount annually. (d) Where an implantable exceeds $10,000 in cost, hospitals may seek additional reimbursement beyond the normal MS-DRG payment. For invoiced items, reimbursement is set at the actual amount paid plus 15 percent. If an item is not invoiced, the payment must be 75 percent of charges. When a hospital seeks additional reimbursement pursuant to this rule, the implantable charge is excluded from any calculation for an outlier payment. Handling and freight charges must be included in the facility's invoiced cost and are not to be reimbursed separately. (e) All services provided during an uninterrupted patient encounter leading to an inpatient admittance must be included in the inpatient stay. (f) The following applies to facility transfers when a patient is transferred for continuation of medical treatment between two acute care hospitals: (i) A hospital transferring a patient is paid as follows: The MS-DRG reimbursement amount is divided by the number of days duration listed for the DRG; the resultant per diem amount is then multiplied by two for the first day of stay at the transferring hospital; the per diem amount is multiplied by one for each subsequent day of stay at the transferring hospital; and the amounts for each day of stay at the transferring hospital are totaled. If the result is greater than the MS-DRG reimbursement amount, the transferring hospital is paid the MS-DRG reimbursement amount. Associated outliers and add-ons are then added to the payment. (ii) A hospital discharging a patient is paid the full MS-DRG payment plus any appropriate outliers and add-ons. (iii) Facility transfers do not include costs related to transportation of a patient to obtain medical care. Such reimbursements are covered by ARM 24.29.1409. (g) Readmissions to inpatient care that occur for the same diagnosis within two weeks of discharge may be subject to medical review and may result in the two claims being combined to yield a single payment. (9) The following applies to outpatient services provided at an acute care hospital or an ASC: (a) The department may establish the base rate for outpatient service at an acute care hospital annually. (i) Effective July 1, 2008, the base rate for hospital outpatient services is $105. (b) The department may establish the base rate for ASCs annually. (i) Effective July 1, 2008, the base rate for ASCs is $79, which is 75 percent of the hospital base rate. (c) Payments for outpatient services in a hospital or an ASC are based on the Montana APC system. The payment must be calculated by multiplying the base rate times the APC weight. If the APC weight is not listed or if the APC weight is listed as null, reimbursement must be paid at 75 percent of usual and customary charges. (d) Billing for outpatient surgical services rendered by a hospital or an ASC must be submitted on a CMS Uniform Billing (UB-04) form or CMS 1500 form. (e) CCI code edits must be used to determine bundling and unbundling of charges. (f) Outpatient medical services include observation in an outpatient status. (g) The threshold for outlier payments is $2,500 per CPT code plus the APC reimbursement amount. If the outlier threshold is met, the outlier payment must be the APC reimbursement amount, plus the charges above the threshold multiplied by 65 percent. (i) For example, if the hospital or ASC submits total charges per CPT code of $15,000 and the APC reimbursement amount is $10,000, then the resultant calculation process is as follows: The $10,000 is added to the threshold amount ($2,500) and the difference between the sum ($12,500) and the charges ($15,000) of $2,500 is multiplied by .65 to obtain the outlier payment of $1,625. The total payment to the hospital or ASC in this example would be $10,000 + $1,625=$11,625. (ii) The department may establish the outpatient outlier amount annually. (h) Where an implantable exceeds $5,000 in cost, hospitals or ASCs may seek additional reimbursement beyond the normal APC payment. For invoiced items, reimbursement is set at the actual amount paid plus 15 percent. If an item is not invoiced, the payment must be 75 percent of charges. When an ASC or hospital seeks additional reimbursement pursuant to this rule, the implantable charge is excluded from any calculation for an outlier payment. Handling and freight charges must be included in the facility's invoiced cost and are not to be reimbursed separately. (i) The following applies to patient transfers from an ASC to an acute care hospital: (i) An ASC transferring a patient is paid the APC reimbursement. (ii) The acute care hospital is paid the MS-DRG reimbursement. (iii) Facility transfers do not include costs related to transportation of a patient to obtain medical care. Such reimbursements are covered by ARM 24.29.1409. (j) "Q" status indicator codes will not be discounted.
AUTH: 39-71-203, MCA IMP: 39-71-203, 39-71-704, MCA
REASON: There is reasonable necessity to adopt NEW RULE I to implement changes enacted by Chapter 117 and Chapter 330 directing reimbursement for medical services provided to a workers' compensation patient at a facility. NEW RULE I is proposed to establish payments for services provided by facilities on or after July 1, 2008, by adopting specific fee schedules designed by Medicare. However, due to the prohibition contained in 2-4-307(3), MCA, the department cannot adopt the Medicare systems updates as they are made. Under the Montana Administrative Procedure Act, in order to adopt those updates the department is required to undertake additional formal rulemaking before those changes can be incorporated into the facility fee schedule. Accordingly, the department is proposing to adopt the Medicare schedules fixed at a certain point in time as indicated by the rule. The schedules chosen are proposed to be called the Montana fee schedules and will be posted on the department's web site.
In addition, there is reasonable necessity to adopt the provisions of NEW RULE I(5) that require providers to report certain cost information to the department. The department believes that such information is needed in order to make sure that the fee schedules do not unfairly cost-shift reimbursement rates, thus resulting in the underpayment or overpayment by workers' compensation insurers of costs. The department notes that although similar information has historically been collected by the department of public health and human services, collection of that information has recently ceased, and thus there appears to be no other source of the information other than directly from the hospitals and ASCs. The department also notes that the reporting form for hospitals and ASCs will include information directing the provider to identify any information that the provider considers to be a "trade secret" which is protected from public disclosure under Montana law.
7. Concerned persons may present their data, views, or arguments, either orally or in writing, at the hearing. Written data, views, or arguments may also be submitted to: Jeanne Johns, Workers' Compensation Regulation Section Supervisor, Workers' Compensation Regulation Bureau, Employment Relations Division, Department of Labor and Industry, P.O. Box 8011, Helena, MT 59624-8011; by facsimile to (406) 444-3465; or by e-mail to jjohns@mt.gov, and must be received no later than 5:00 p.m., May 23, 2008.
8. An electronic copy of this Notice of Public Hearing is available through the department's web site at http://dli.mt.gov/events/calendar.asp, under the Calendar of Events, Administrative Rules Hearings Section. The department strives to make the electronic copy of this Notice of Public Hearing conform to the official version of the Notice, as printed in the Montana Administrative Register, but advises all concerned persons that in the event of a discrepancy between the official printed text of the Notice and the electronic version of the Notice, only the official printed text will be considered. In addition, although the department strives to keep its web site accessible at all times, concerned persons should be aware that the web site may be unavailable during some periods, due to system maintenance or technical problems, and that a person's difficulties in sending an e-mail do not excuse late submission of comments.
9. The department maintains a list of interested persons who wish to receive notices of rulemaking actions proposed by this agency. Persons who wish to have their name added to the list shall make a written request, which includes the name and mailing address of the person to receive notices and specifies that the person wishes to receive notices regarding all Department of Labor and Industry administrative rulemaking proceedings or other administrative proceedings. Such written request may be mailed or delivered to the Department of Labor and Industry, attention: Mark Cadwallader, 1327 Lockey Avenue, P.O. Box 1728, Helena, Montana 59624-1728, faxed to the department at (406) 444-1394, e-mailed to mcadwallader@mt.gov, or may be made by completing a request form at any rules hearing held by the agency.
10. The bill sponsor notice requirements of 2-4-302, MCA, apply and have been fulfilled. The primary sponsor of House Bill 738 was notified on May 17, 2007, by regular mail. The primary sponsor of Senate Bill 108 was notified on May 17, 2007, by regular mail.
11. The department's Hearings Bureau has been designated to preside over and conduct this hearing.
/s/ MARK CADWALLADER /s/ KEITH KELLY Mark Cadwallader Keith Kelly, Commissioner Rule Reviewer DEPARTMENT OF LABOR AND INDUSTRY
Certified to the Secretary of State April 14, 2008 |
A directory of state agencies is available online at http://www.mt.gov/govt/agencylisting.asp.
For questions about the organization of the ARM or this web site, contact sosarm@mt.gov.
