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2019-11-27_REVISION - C1981041
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2019-11-27_REVISION - C1981041
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Last modified
12/27/2024 2:48:39 PM
Creation date
12/2/2019 9:21:59 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
11/27/2019
Doc Name
Response to Board Order
From
Law Offices of John R. Henderson
To
DRMS
Type & Sequence
SL11
Email Name
CCW
JDM
Media Type
D
Archive
No
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B. Rule 3.03.2(6)(a)does not change,modify,or conflict with the Act. <br /> Snowcap argues that Rule 3.03.2(6)(a) is without legal effect because it "changes, <br /> modifies, and conflicts with the Act[.]"(Mot. at 7-8.)This argument fails. <br /> Snowcap strips its primary authority to assert that "administrative rules and regulations <br /> are without force and effect if they add to, change, modify, or conflict with an existing statute[,]" <br /> Adams v. Colo. Dept. of Social Services, 824 P.2d 83, 86 (Colo. App. 1991), of its context. A <br /> close analysis of this case illustrates why the Rule 3.03.2(6)(a)is not in conflict with the Act. <br /> In Adams, the Colorado Department of Social Services implemented a new regulation <br /> that fundamentally changed eligibility requirements for State Home Care Allowance ("HCA") <br /> benefits. 824 P.2d at 85. This resulted in hundreds of HCA beneficiaries being forced into <br /> nursing homes, in direct conflict with what the court determined to be the General Assembly's <br /> intent in passing the relevant enabling statutes—to keep HCA recipients independent and prevent <br /> their placement in nursing homes.Id. at 87-88. <br /> This case is very different. As a threshold matter, Snowcap offers no explanation for how <br /> the regulation can conflict with an undefined term in the Act. The Act's use of"issuance" is <br /> ambiguous. People v. McEntee, 2019 COA 139, ¶ 13 (holding a statute is ambiguous when"the <br /> words chosen do not inexorably lead to a single result[.]" (quoting State v. Nieto, 993 P.2d 493, <br /> 501 (Colo. 2000))).To conclude that the Board's interpretation of an ambiguous term in a statute <br /> conflicts with the statute is absurd and must be rejected. <br /> Further, the regulation is not at odds with the General Assembly's clear intent in the <br /> pertinent provision of the Act—to give persons affected by a proposed decision of the Office the <br /> chance for an adjudicatory hearing before the Board. Rather, the regulation brings needed clarity <br /> to when such a request must be made. Nor is the regulation inconsistent with the text of the Act <br /> itself. Like section § 34-33-125(6), C.R.S., Rule 3.03.2(6)(a) still requires that a request for an <br /> 4 <br />
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