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Statement in lieu of Job Impact Statement for amendments
to Subchapters C, D and E of Title 12 NYCRR


Statement explaining why Revised Job Impact Statement is not required for amendments to Subchapters C, D and E of Title 12 of the NYCRR

A Revised Job Impact Statement is not required for the non-substantial changes to 12 NYCRR Sections 325-1.5 and 326-1.1. The proposed consensus rule making did not have a substantial impact on jobs and employment opportunities since the proposed changes:

  1. correct typographical, grammatical and punctuation errors;
  2. update addresses, telephone numbers and form numbers;
  3. correct gender based language and other minor inaccuracies;
  4. conform regulatory requirements to statutory language; and
  5. made procedural changes which participating parties are already aware of and are in compliance.

The non-substantial revisions make similar changes. The revision to Section 325-1.5 merely rewords a portion of sentence to make it clear that a claimant's choice of specialist is limited to the extent the claimant is required to obtain diagnostic tests from a provider network or networks with which the employer or carrier contracts. The meaning of the provision was not changed, merely the words used to express the meaning of the provision. The revisions to Section 326-1.1 merely amend the language to correctly represent that a doctor of osteopathy is a licensed physician with a degree of doctor of osteopathic medicine and to correctly identify the State association of osteopaths as the New York State Osteopathic Medical Society, Inc. The proposed text incorrectly named the organization as the New York State Osteopathic Society, Inc. Therefore, just as the proposed consensus rule making did not have a substantial impact on jobs and employment opportunities, neither do the non-substantial changes.


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