James D. Fraser

6.5.03

The themes in this paper are: (1) the "legislative" nature of the MIPS / EPG manuals, how that is significant in appeals to the Board, and the importance of stakeholder input before they are implemented; (2) the timing of legislated changes to MIPS / EPG manuals, and problems that can arise when changes to these manuals are officially given to manual subscribers after appeal dates have passed; and (3) interesting questions that arise from s.15 and s.16 information requests and how they fit into the scheme of a consultative process.