REGULATORY ANALYSIS
FOR AMENDMENTS OF RULES 16 AND 18
OF THE WORKERS' COMPENSATION RULES OF PROCEDURE
7 CCR 1101-3

1.	Description of classes of persons who will be affected by the rules, including classes that will bear the costs of the rules and classes that will benefit from the rules.

The classes of persons affected by the rules are all persons and entities involved in the Colorado Workers’ Compensation system.  This includes, but is not limited to, injured workers, health care providers, insurance carriers, third party administrators and employers.

2.	Description of the probable quantitative and qualitative impact of the proposed rules, economic or otherwise, upon the classes of affected persons.

The rule creates a requirement effective 2022 for medical interpreters to become certified in order to be reimbursed for services.  It also requires that non-certified interpreters meet minimum standards to be deemed qualified.  

3.	Probable costs to the agency and other agencies of the implementation and enforcement of the proposed rules and any anticipated effect on state revenues.

No impact on costs or revenues is anticipated as a result of the rule changes.  

4.	Comparison of the probable costs and benefits of the proposed rules to the probable costs and benefits of inaction. 

Insurers are already required to provide interpretation services to facilitate access to medical care.  The adopted rule creates standards to ensure quality medical interpretation.  Failure to act would allow for non-qualified interpreters to continue to receive reimbursement while not facilitating medical treatment.  

5.	Determination of whether there are less costly or less intrusive methods for achieving the purpose of the rules.

There are no known less costly or less intrusive means.  

6.	Description of any alternative methods for achieving the purpose of the proposed rules that were seriously considered by the agency and the reasons they were rejected in favor of the proposed rules.

The two alternatives considered were maintain the status quo and imposing a shorter timeline for interpreters to become certified.  The status quo was rejected as failing to ensure quality interpretative services, permitting the use of minor children and family members and creating ambiguity surrounding the requirements.  The imposition of a shorter timeframe for certification was rejected to ensure a suitable number of certified interpreters are available.  

Copies of the Notice of Public Hearing were provided to the:

Colorado Association of School Boards
Colorado Counties, Inc.
Colorado Municipal League
Special District Association of Colorado
Colorado Hospital Association
Colorado Association of Commerce and Industry
Mountain States Employers Council
Colorado Self-Insurers Association
				   Colorado Medical Society