ADOPTED REGULATORY ANALYSIS
for Repeal of
6 CCR 1015-11, Rules for Breast and Cervical Cancer Screening Program
Adopted by the Board of Health on April 16, 2014
1.A description of the classes of persons who will be affected by the proposed rule, including classes that will bear the costs of the proposed rule and classes that will benefit from the proposed rule.
The repeal of the rules benefits the breast and cervical cancer screening program by eliminating additional sources of guidelines governing the same aspects of the same program. This creates efficiencies for staff by having the focus on updating contracts and the Toolkit rather than also updating rules. Many stakeholders were not aware of these rules as they have not been relied upon in recent years. The Women’s Wellness Connection continues to exist and will continue to operate through contracts and the Toolkit.
2.To the extent practicable, a description of the probable quantitative and qualitative impact of the proposed rule, economic or otherwise, upon affected classes of persons.
Repeal of the rules will remove an additional regulatory burden as stakeholders will not need to look to contracts and rules to ensure compliance with the program requirements.
3.The probable costs to the agency and to any other agency of the implementation and enforcement of the proposed rule and any anticipated effect on state revenues.
This rulemaking repeals rules; there will be no cost to enforcing the rules as there will be no rules.
4.A comparison of the probable costs and benefits of the proposed rule to the probable costs and benefits of inaction.
Inaction continues a dual system. The cost would be additional sources of guidelines or conflicting instruction if the rules were not maintained in alignment with Department contracts. The cost of on-going upkeep of the rules is more costly than repealing the rules.
5.A determination of whether there are less costly methods or less intrusive methods for achieving the purpose of the proposed rule.
There is no other less costly or less intrusive method for achieving the purpose of this proposed amendment, which is simply to repeal the Breast and Cervical Cancer Screening Program rules.
6.Alternative Rules or Alternatives to Rulemaking Considered and Why Rejected.
The alternative method for achieving the purpose of this proposed amendment is to modify rather than repeal the rules. This method was rejected because service providers operates through contract rather than rules and staff regularly update program contracts and Toolkit to stay current and maintain a robust service delivery.
7.To the extent practicable, a quantification of the data used in the analysis; the analysis must take into account both short-term and long-term consequences.
The statutes authorizing this rule, as well as existing program documents and Executive Order 2012-002 (E.O. 12-002), served as the basis for this analysis.