Prepaid and Collections Committee,
At our meeting last week I agreed to write up a description of the issues I'm wrestling with related to novel business models for MLTS that Jolene has run across in a couple of her audits, and one based on a question from a provider. I believe our next meeting is scheduled in April, but I hope providing this to you now will give you some time to review and think about these issues. Some potential solutions to these issues are also included in the paper, but there may be better options.
If we do decide to move forward with these solutions, I believe we can implement them via rulemaking rather than legislation. It would also be a good idea to try to think of any other non-standard configurations that might give us difficulty in applying surcharges so that we can try to address those in the same rulemaking.
Thank you,