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Rural Area Flexibility Analysis of Proposed Amendment
of 12 NYCRR 300.2 (IME Regulation)


  1. Types and estimated numbers of rural areas:

    This rule applies to all claimants, carriers, employers, self-insured employers, independent medical examiners and entities deriving income from independent medical examinations, in all areas of the state.
  2. Reporting, recordkeeping and other compliance requirements; and professional services:

    All regulated parties will have additional time to file their reports. No specialized/professional services will be needed in order to comply with this proposed amendment.
  3. Costs:

    This proposal will not impose any compliance costs on rural areas. It is the Board's best estimate that the overall savings that could be achieved through the implementation of this regulation with respect to reduction in duplicate filing of medical records could range between $1.2 million and $1.6 million per year or $300,000 - $400,000 per quarter. This was determined by adding the number of IME-3 forms to the number of attachments submitted with the IME-3, and then multiplying the result by 32.999 cents per page. 32.999 cents per page is the cost of scanning a single page into the Board's electronic case folder as charged under the current vendor
  4. Minimizing adverse impact:

    These proposed amendments to the rule are designed to minimize adverse impact for all businesses and local government regardless of geographic location. There is no difference between the impact on rural areas and other more densely populated areas of the state.
  5. Rural area participation:

    The Board received input from a number of entities who derive income from independent medical examinations as well as providers of independent medical examinations. Not only did the Board receive written communication but met with IME entities and spoke with some examiners.

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