Transcript Highlights:

• OF RULES.
• POINT DURING THE RULE REVIEW PROCESS, UP UNTIL THE RULE IS FILED FOR ADOPTION, THE RULE IS CHALLENGED
• AND AS SUCH, RULE 4.3 OF THE RULES OF THE LEGISLATURE AUTHORIZES THE COMMITTEE TO ADOPT RULES OF PROCEDURE
• and rule amendments.
• The sunset of one rule may affect all the other rules within chapter.

Transcript Highlights:

• Rules as necessary, or permissive, the department may adopt rules as deemed necessary.
• be a rule.
• All agency rules, except emergency rules and rules exempt by statute, and forms and manuals meeting the
• notice of rule development.
• U.S. and find rules.

Summary: The committee received an informational presentation from the Joint Administrative Procedures Committee (JAPC/JAPSI) staff and Chair Representative Overdorf on how Florida administrative rulemaking is reviewed. Mr. Plant explained that JAPC is a joint legislative oversight committee that monitors agency rules under Chapter 120, focusing on whether rules stay within statutory authority, whether agencies are acting consistently with legislative intent, and how the rulemaking process works. He emphasized that agencies are creatures of statute, that rulemaking authority must be specific enough to support the rule, and that without a date certain in statute, agencies may delay rulemaking indefinitely. Members asked about how to ensure agencies actually adopt rules, how to identify rules that exceed legislative intent, and how JAPC handles internal policies and delayed rulemaking. Representative Overdorf then described JAPC’s objection process and its limits. He said the committee does not approve or disapprove rules or direct agencies to adopt them, but it can object to proposed or existing rules that enlarge, modify, or contravene enabling statutes or fail to comply with Chapter 120. He noted that if an agency does not resolve an objection, a footnote is published in the Florida Administrative Code and the committee may recommend legislation to amend, suspend, or repeal the rule. He also discussed recent committee activity, including 1,355 proposed rules, 119 emergency rules, and 1,243 incorporated materials reviewed in 2024, and said the committee filed 31 objections against one agency after repeated noncompliance. The discussion also touched on possible changes to Chapter 120, including the governor’s 2019 request that agencies include five-year sunset provisions in rules, and a proposal to instead require periodic legislative review rather than automatic expiration. Overdorf also said the committee is considering raising the current statement of estimated regulatory costs thresholds of $200,000 annually or $1 million over five years because inflation has made those limits too low. No votes were taken on legislation, and the meeting ended with adjournment.

Transcript Highlights:

• Nor are sunset provisions repeals of rules, because the rules remain in effect and fully enforceable
• In addition, even where a rule is discretionary, if that rule incorporates forms or detailed procedures
• to adopt rules, but did not say with respect to these provisions that the agency must adopt a rule.
• in the rule and have been amended since the rule was adopted without going through the formal rule amendment
• So if the question, are we following the rule, I believe we're following the rule.

Summary: The Joint Administrative Procedures Committee reviewed several agency rules and objections under Chapter 120. First, the committee revisited prior objections to Agency for Health Care Administration rules containing sunset provisions. AHCA’s general counsel said the agency amended 26 of the objected rules but declined to amend five others, arguing sunset provisions are lawful, are not themselves rules, and were consistent with a 2019 gubernatorial directive. Committee members questioned that position, especially for licensing and certificate-of-need rules, and urged the agency to consider legislative changes; no formal action was taken on that item during the discussion. The committee then considered an objection to Department of Management Services Rule 60G-1.001 defining the Governor’s Mansion grounds. Committee staff argued the rule is vague and improperly refers to future land acquisitions without updating the rule since 1998. DMS defended the rule as a general definition tied to publicly recorded property and a master lease, but said it would not object if the Legislature chose to codify the definition in statute. After discussion, the committee voted to file the objection. Members also received informational updates from the Department of Environmental Protection on the Solaris state lands inventory system, and from the Florida Gaming Control Commission on its response to the Tampa Bay Downs unadopted-rule litigation, in which the commission said it has stopped relying on the prior tax interpretation and will not promulgate a rule on that issue. The Department of Business and Professional Regulation said it would remove an unsupported cigar wholesale dealer permit reference, repeal an obsolete excise-tax deduction rule, and amend penalty guidelines and an affirmation in its alcohol, beverage, and tobacco rules. Finally, the Division of Administrative Hearings’ interim director discussed case-processing times, possible changes to ALJ status, and whether the Florida Rules of Evidence should apply in administrative proceedings, emphasizing the need to weigh costs, independence, and impacts on pro se litigants. The chair noted this was likely the committee’s final meeting of the year.

Transcript Highlights:

• what budget rules are not.
• what budget rules are not.
• what budget rules are not.
• rules.
• </c><01:01:36.039><c> but</c><01:01:36.160><c> maybe</c> rule the rule does continue but maybe rule the

Committee: Senate Finance

Transcript Highlights:

• All right, a minute, as the rules filed by the rules filed by the Item E, as the rules filed by the various
• those into this rule.
• The third rule I have for you is a follow-up permanent rule to a previously approved rule through emergency
• The first rule I have today is the rule concerning adverse decisions. This rule is pursuant to...
• And my last rule today... ...this rule is reviewed and approved.

Committee: All ALC-ADMINISTRATIVE RULES

Summary: The Arkansas Administrative Rules Subcommittee met to review a large set of agency rules and reports. Early items were routine filings: emergency-rule reports, subcommittee review reports, and administrative directive reports were filed without objection. One rule from the Department of Agriculture on maternal health providers and remote monitoring was noted as pulled by the agency and not considered. The committee then reviewed and approved several Agriculture rules, including repeal of equine ID-chip rules after Act 703 of 2025, updates to finance rules adding a new water and sewer treatment facilities grant and consolidating revolving-fund rules, and a pesticide rule creating a Class J pesticide category for feral hog toxicant use. It also approved a Commerce/Insurance rule removing duplicative workers’ compensation plan provisions, and a Corrections rule creating a unified visitation rule for correctional facilities and community correction centers. A member asked about prison visitation hours during COVID, and staff said they would check on that. The committee next approved multiple Department of Human Services rules. These included marketing rules for provider-led organizations under Act 301 of 2025, a comprehensive revision of the DCFS policy manual, changes to Medicaid eligibility to include fictive kin placements and to expand ABLE account eligibility under Act 875, presumptive eligibility changes for pregnant women to align with federal rules, and a follow-up SNAP/TEA/Work Pays rule with updated work requirements, mandatory employment and training, alien eligibility changes, and job-search requirements for certain applicants. DHS also presented a rule implementing federal coverage for certain incarcerated youth before and after release, and the committee approved it. Another DHS rule updated nurse aide training requirements to match federal CNA hour standards and moved criminal-records-check procedures to the agency website. The most extended discussion involved DHS Division of Medical Services’ dental rate rule under Act 1025. The agency explained that it was increasing pediatric dental rates and certain oral-surgery-related rates, but not orthodontic rates or a broader special-needs benefit limit because CMS would not approve a diagnosis-based limit. Members debated whether the statutory language was intended to cover general dentists performing oral surgery procedures, with legislators, the Dental Association, and DHS discussing legislative intent, fiscal impact, and whether a future fix or emergency rule might be needed. Despite the disagreement, the committee approved the rule. The committee also approved other DHS medical rules: adverse-decision appeal changes and prior-authorization posting requirements, an increased RSV administration fee for children, expanded emergency treat/triage/transport ambulance authority, and clinic-based physical and occupational therapy coverage. Later, the committee approved permanent rules for the new state insurance program under Shared Administrative Services, procurement rule revisions recommended after an ACASO review, and commodity-management rule updates including a new revenue distribution model. Under Act 595 of 2021, the committee granted two Department of Commerce/Insurance requests to be excluded from rulemaking requirements: one for Act 772 on forced organ harvesting, and one for restorative reproductive medicine, with the department saying it would promulgate rules later when clinical guidelines are available. Finally, the committee accepted a recommendation to keep and extend the Department of Education, Division of Career and Technical Education rules, filed outstanding rulemaking updates, and adjourned without further business.

Transcript Highlights:

• This rule will be reviewed and approved. This rule will be reviewed and approved.
• The third rule I have for you is a follow-up permanent rule to a previously approved rule through emergency
• The first rule I have today is the rule concerning adverse decisions. This rule is pursuant to...
• The first rule I have today is the rule concerning adverse decisions. This rule is pursuant to.
• Thank you. ...on which to base some rules, we will indeed promulgate rules.

Committee: All ALC-ADMINISTRATIVE RULES

Transcript Highlights:

• All right, a minute, as the rules filed by the rules filed by the...
• those into this rule.
• The third rule I have for you is a follow-up permanent rule to a previously approved rule through emergency
• The first rule I have today is the rule concerning adverse decisions.
• Rule D is another rule that was passed pursuant to 2025 legislation, Act 5856.

Committee: All ALC-ADMINISTRATIVE RULES

Summary: The Arkansas Administrative Rules Subcommittee met to review a large slate of agency rules and related reports. The chair announced that several items were stricken from the agenda and that the maternal health providers and remote monitoring rules were pulled by the agency. The committee filed reports on emergency rules, ALC subcommittee rule reviews, and administrative directives, then moved through agency rules from the Department of Agriculture, Department of Commerce/Insurance, Department of Corrections, and multiple divisions of the Department of Human Services. Most rules were explained as technical updates or implementations of 2025 legislation and were approved without objection. Examples included repeal of obsolete equine ID-chip rules, updates to agriculture financing and pesticide rules, removal of duplicative workers’ compensation plan language, a unified visitation rule for correctional facilities, DHS marketing rules for PASS programs, a comprehensive DCFS policy manual revision, Medicaid-related changes for fictive kin, ABLE accounts, presumptive eligibility for pregnant women, SNAP work requirements and alien eligibility, coverage for certain incarcerated youth, nurse aide training updates, and permanent rules for state employee insurance and procurement. The committee also approved requests to exclude the Insurance Department from rulemaking requirements for Act 772 on forced organ harvesting and for restorative reproductive medicine, with the department saying it would issue rules later when more guidance is available. The most extended discussion concerned DHS’s dental Medicaid rate rule under Act 1025. Members and witnesses debated whether the statute’s language covered only oral surgeons or also general dentists performing oral surgery procedures, and whether the rate increase should apply more broadly to the services rather than the provider title. DHS said it was following the black-letter language of the law and could not confirm a broader interpretation without further approvals and funding, while legislators and a Dental Association representative said the intent was to increase payment for the services, especially in rural areas. Members also discussed the possibility of fixing the language in a future session or through a new rule if approvals and CMS review allow. Despite the concerns, the committee approved the rule. The meeting ended with approval of rule review reports and monthly updates, and the committee adjourned.

Transcript Highlights:

• review of their rules.
• review of their rules.
• So this rule is new.
• The first rule I have for you today is a rule regarding content..."
• , or EVV, rule.

Committee: All ALC-ADMINISTRATIVE RULES

Summary: The Administrative Rules Subcommittee met to review a large slate of agency rules and reports. Early agenda items included filing reports from ALC subcommittees and approving quarterly administrative directives, with no new directives from Corrections or the Post-Prison Transfer Board. The committee also noted that RDOT utility accommodations rules and one solid waste district rule had been pulled at the agencies’ request. Most agency rules were reviewed and approved without objection, including rules from the Department of Transportation on oversized/overweight vehicle permits and automatic license plate readers, the Insurance Department on vision plan coverage, the Department of Education on course choice, restroom access for athletic personnel, and school district consolidation/detachment, and several Department of Health and DHS rules covering controlled substances, acupuncture, physician assistant delegation, personal care, Medicaid eligibility, continuous glucose monitors, maternal health services, PACE, EVV, substance use disorder treatment, and hospital reimbursement. The committee also approved rules from Labor and Licensing, Parks, Heritage, and Tourism, Shared Administrative Services, the 529 Plan Review Committee, and the Treasurer’s Office, and it voted to continue the Office of Early Childhood’s rules and to accept outstanding rulemaking responses from several agencies. Two items drew notable discussion. The committee held the DHS hospital reimbursement rule for further review after concerns were raised about whether acute hospitals, especially Children’s Hospital, could legally and economically provide the newly reimbursable lower level of care; the committee first voted to hold it, then expunged that vote and instead held the item until the next day’s full ALC meeting for further discussion. The committee also denied the Arkansas Towing and Recovery Board rule after a motion that it did not match legislative intent, with concerns focused on proof of insurance and vague language about future financial responsibility. All other reviewed rules were approved.

Transcript Highlights:

• There being 27 ayes and 4 nays, the rule is suspended. The rules are suspended.
• The 3-day rule is suspended.
• Is the rule suspended?
• The three-day rule is submitted.
• There being 31 ayes and 0 nays, the rule is suspended. The rule is suspended.

Bills: HB4 , HB20 , HB40 , HB46 , HB 101 , HB 112 , HB 117 , HB 121 , HB 127 , HB146 , HB150 , HB186 , HB229 , HB426 , HB521 , HB541 , HB549 , HB632 , HB713 , HB796 , HB 1052 , HB 1106 , HB 1135 , HB 1234 , HB 1306 , HB1403 , HB1523 , HB1532 , HB1690 , HB1960 , HB2035 , HB2217 , HB2399 , HB2488 , HB2517 , HB2594 , HB2655 , HB2686 , HB2731 , HB2757 , HB2820 , HB2963 , HB3005 , HB3053 , HB3073 , HB3225 , HB3320 , HB3333 , HB3336 , HB3441 , HB3483 , HB3516 , HB3520 , HB3697 , HB3748 , HB3793 , HB3848 , HB4099 , HB4134 , HB4144 , HB4158 , HB4233 , HB4236 , HB4285 , HB4350 , HB4359 , HB4464 , HB4580 , HB4690 , HB4730 , HB4848 , HB4904 , HB4995 , HB5196 , HB5294 , HB5381 , HB5435 , HB5437 , HB5509 , HB5606 , HB5646 , HB5658 , HB5661 , HB5663 , HB5666 , HB5672 , HCR40 , HCR59 , SB867 , SB2919 , SJR5 , SJR27 , SB4 , SB6 , SB7 , SB9 , SB13 , SB15 , SB23 , SB27 , SB30 , SB40 , SB57 , SB66 , SB140 , SB268 , SB293 , SB331 , SB413 , SB447 , SB457 , SB467 , SB506 , SB510 , SB512 , SB571 , SB650 , SB763 , SB777 , SB785 , SB800 , SB850 , SB863 , SB865 , SB973 , SB974 , SB1191 , SB1281 , SB1300 , SB1362 , SB1494 , SB1522 , SB1540 , SB1567 , SB1579 , SB1580 , SB1610 , SB1660 , SB1723 , SB1760 , SB1838 , SB1923 , SB1946 , SB1957 , SB1964 , SB2018 , SB2024 , SB2121 , SB2167 , SB2217 , SB2221 , SB2321 , SB2337 , SB2368 , SB2373 , SB2407 , SB2431 , SB2477 , SB2587 , SB2615 , SB2753 , SB2807 , SB2900 , SB2965 , SB2972 , SB2986 , SB3039 , SB3047 , SB3059 , SB3070 , SB1 , SB17 , SB21 , SB260 , SB379 , SB509 , SB1198 , SB1405 , SB1506 , SB1637 , SB1833 , SB2155 , SB2308 , SB2601 , SB2778 , HB300 , HB2011 , HB2525 , HB5246 , HB 100 , HB 101 , HB 119 , HB227 , HB252 , HB322 , HB346 , HB654 , HB705 , HB718 , HB721 , HB824 , HB 1094 , HB 1234 , HB 1306 , HB1506 , HB1523 , HB1629 , HB1690 , HB1868 , HB1960 , HB1973 , HB2012 , HB2035 , HB2037 , HB2078 , HB2128 , HB2213 , HB2240 , HB2348 , HB2520 , HB2598 , HB2686 , HB2694 , HB2820 , HB3005 , HB3057 , HB3092 , HB3112 , HB3171 , HB3181 , HB3185 , HB3333 , HB3388 , HB3516 , HB3546 , HB3619 , HB3623 , HB3629 , HB3642 , HB3686 , HB3697 , HB3749 , HB3793 , HB3812 , HB3815 , HB3848 , HB3909 , HB4081 , HB4145 , HB4157 , HB4158 , HB4170 , HB4202 , HB4211 , HB4214 , HB4233 , HB4285 , HB4350 , HB4361 , HB4463 , HB4464 , HB4466 , HB4559 , HB4630 , HB4748 , HB4765 , HB4848 , HB4894 , HB4904 , HB4995 , HB5093 , HB5196 , HB5320 , HB5437 , HB5624 , HB5650 , HB5651 , HB5652 , HB5654 , HB5655 , HB5656 , HB5658 , HB5661 , HB5662 , HB5664 , HB5665 , HB5666 , HB5670 , HB5672 , HB5674 , HB5677 , HB5679 , HB5682 , HB5689 , HB5690 , HB5694 , HB5695 , HB5698 , HB5699 , HCR46 , HCR76 , HCR81 , HCR83 , HCR84 , HCR111 , HB748 , HB5652 , HB3395 , HB180 , HB 1306 , HB5650 , HB4894 , HB1629 , HB5698 , HB3171 , HB2694 , HB5664 , HB4690 , HB4464 , HB3623 , HB2520 , HB2213 , HB252 , HB146 , HB5596 , HB3619 , HB5320 , HB5651 , HB5670 , HB5665 , HB5437 , HB5679 , HB5661 , HB5662 , HB5654 , HB5672 , HB5656 , HB2035 , HB721 , HB346 , HB5695 , HB5694 , HB5674 , HB3185 , HB2348 , HB 1135 , HB 101 , HB5666 , HB5677 , HB5682 , HB5658 , HB4144 , HB3642 , HB3815 , HB2686 , HB2012 , HB1960 , HB227 , HB654 , HB4158 , HB4630 , HB1523 , HB1973 , HB3333 , HB3697 , HB3546 , HB3225 , HB2820 , HB186 , HB 119 , HB4466 , HB4170 , HB3909 , HB4081 , HB4145 , HB4285 , HB4463 , HB4995 , HB5624 , HB1449 , HB2598 , HB3629 , HB4361 , HB824 , HB1868 , HB4848 , HB40 , HB 117 , HB3686 , HB3793 , HB 112 , HB 104 , HB718 , HB4904 , HB4202 , HB4765 , HB4559 , HB4350 , HB4214 , HB3388 , HB3112 , HB5196 , HB3516 , HB3092 , HB4233 , HB 1094 , HB2037 , HB3005 , HB3848 , HB 121 , HB3336 , HB5294 , HB5646 , HB4236 , HB 1052 , HB5509 , HB5435 , HB3520 , HB3320 , HB2517 , HB2488 , HB5663 , HB2731 , HB3073 , HB2655 , HB2399 , HB541 , HB4099 , HB 111 , HB1532 , HB3483 , HB2963 , HB4580 , HB3748 , HB713 , HB632 , HB426 , HB4730 , HB 127 , HB5690 , HB5689 , HB5655 , HB3385 , HB2757 , HB4359 , HB5381 , HB20 , HB 123 , HB549 , HB5606 , HB2217 , HB2594 , HB796 , HB 1057 , HB3664 , HCR141 , HCR40 , HCR59 , HCR76 , HCR81 , HCR46 , HCR111 , HCR83 , HCR84 , SJR36 , SJR50 , SJR63 , SCR12 , SCR39 , SB2023 , SB62 , SB666 , SB847 , SB284 , SB854 , SB810 , SB1505 , SB583 , SB507 , SB1434 , SB1772 , SB2016 , SB1122 , SB731 , SB397 , SB508 , SB1436 , SB287 , SB1882 , SB393 , SB1791 , SB209 , SB2429 , SB1085 , SB1975 , SB2717 , SB1262 , SB636 , SB2056 , SB884 , SB1200 , SB1845 , SB2458 , SB801 , SB3014 , SB3013 , SB758 , SB2797 , SB2076 , SB2876 , SB1640 , SB1449 , SB1181 , SB1234 , SB2926 , SB2841 , SB1528 , SB1854 , SB317 , SB1250 , SB2082 , SB1237 , SB2819 , SB629 , SB2608 , SB1602 , SB2009 , SB867 , SB640 , SB1698 , SB2680 , SB913 , SB1071 , SB1086 , SB1087 , SB1483 , SB1444 , SB1553 , SB1556 , SB1703 , SB2133 , SB2297 , SB2298 , SB2622 , SB2955 , SB2334 , SB1367 , SB2044 , SB2363 , SB2565 , SB1888 , SB3036 , SB3057 , SB3043 , SB3063 , SB3035 , SB203 , SB2688 , SB2522 , SB2459 , SB2655 , SB2251 , SB1884 , SB2928 , SB2566 , SB2549 , SB2553 , SB2919 , SB1944 , SB1232 , SB1798 , SB2603 , SB2607 , SB2683 , SB1319 , SB3045 , SB3071 , HB40 , HB 117 , HB 121 , HB426 , HB541 , HB713 , HB 1052 , HB1532 , HB2217 , HB2488 , HB2517 , HB2655 , HB2757 , HB2963 , HB3073 , HB3697 , HB4099 , HB4144 , HB4158 , HB4236 , HB4285 , HB4848 , HB5435 , HB5437 , HB5509 , HB5646 , HB5666 , HB14 , HB 1240 , HB796 , HB1523 , HB5294 , SR559 , SR587 , SR614 , SCR53 , SJR59 , SB10 , SB22 , SB25 , SB34 , SB36 , SB38 , SB261 , SB777 , SB924 , SB1188 , SB1318 , SB1333 , SB1398 , SB1448 , SB1621 , SB1862 , SB2405 , SB2406 , SB8 , SB12 , SB37 , SB441 , SB1566 , SB2878 , HB300 , HB2011 , HB5246 , HB 101 , HB 119 , HB227 , HB252 , HB346 , HB654 , HB718 , HB721 , HB824 , HB 1306 , HB1629 , HB1868 , HB1960 , HB1973 , HB2012 , HB2035 , HB2037 , HB2213 , HB2348 , HB2520 , HB2598 , HB2686 , HB2694 , HB2820 , HB3005 , HB3092 , HB3112 , HB3185 , HB3333 , HB3388 , HB3516 , HB3546 , HB3619 , HB3623 , HB3629 , HB3642 , HB3686 , HB3815 , HB3848 , HB3909 , HB4081 , HB4145 , HB4170 , HB4202 , HB4214 , HB4350 , HB4361 , HB4463 , HB4464 , HB4466 , HB4559 , HB4630 , HB4765 , HB4894 , HB4904 , HB4995 , HB5196 , HB5320 , HB5624 , HB5650 , HB5651 , HB5652 , HB5654 , HB5655 , HB5656 , HB5658 , HB5661 , HB5662 , HB5664 , HB5665 , HB5670 , HB5672 , HB5674 , HB5677 , HB5679 , HB5682 , HB5695 , HB5698 , HCR46 , HCR76 , HCR81 , HCR83 , HCR84 , HCR111 , HB 1094 , HB3171 , HB3793 , HB4233 , HB5689 , HB5690 , HB5694

Transcript Highlights:

• rule.
• , Building Code Rules, Temporary Rule.
• Rules of Building Safety, Building Code Rules, Temporary Rule. Mr.
• Pending Rule Docket 24-3930-2501. Rules of Building Safety, Building Code Rules. Mr.
• Motion to approve Pending Rule Docket 24-3930-2501, Rules of Building Safety, Building Code Rules.

Committee: House Business

Transcript Highlights:

• Constitutional three-day rule. So moved. Senator Nichols moves suspension of the three-day rule.
• I move to suspend the three-day rule. Senator Creighton moves to suspend the three-day rule.
• The rules are suspended. The rules are suspended.
• Hearing none, the rules are suspended. The rules are suspended.
• I'd like to recall the rule. 31 ayes, 0 nays, the rule is suspended.

Bills: SB111 , SB128 , SB203 , SB205 , SB261 , SB383 , SB393 , SB397 , SB466 , SB510 , SB705 , SB715 , SB731 , SB748 , SB801 , SB867 , SB876 , SB913 , SB945 , SB946 , SB1013 , SB1071 , SB1086 , SB1087 , SB1181 , SB1250 , SB1285 , SB1373 , SB1400 , SB1444 , SB1483 , SB1528 , SB1553 , SB1556 , SB1581 , SB1586 , SB1608 , SB1698 , SB1730 , SB1835 , SB1858 , SB1903 , SB1946 , SB1950 , SB1986 , SB2017 , SB2043 , SB2056 , SB2058 , SB2063 , SB2082 , SB2105 , SB2133 , SB2137 , SB2177 , SB2203 , SB2260 , SB2311 , SB2334 , SB2337 , SB2340 , SB2403 , SB2417 , SB2446 , SB2452 , SB2460 , SB2519 , SB2532 , SB2565 , SB2611 , SB2619 , SB2622 , SB2633 , SB2637 , SB2655 , SB2681 , SB2688 , SB2713 , SB2717 , SB2764 , SB2781 , SB2782 , SB2790 , SB2794 , SB2797 , SB2841 , SB2847 , SB2857 , SB2878 , SB2891 , SB2943 , SB2955 , SB2959 , SB2972 , SB2995 , SB3037 , SB3047 , SB3057 , SB3059 , HJR2 , HJR99 , HB26 , HB29 , HB136 , HB166 , HB206 , HB353 , HB451 , HB517 , HB1399 , HB1672 , HB2000 , HB2198 , HB2756 , HB3204 , HB3248 , SJR3 , SB5 , SB72 , SB509 , SB616 , SB963 , SB985 , SB1025 , SB1080 , SB1143 , SB1172 , SB1245 , SB1267 , SB1271 , SB1273 , SB1355 , SB1422 , SB1759 , SB1786 , SB2361 , SB1 , SB260 , SB1506 , SB1637 , SCR48 , SB375 , SB410 , SB672 , SB777 , SB1373 , SB1454 , SB1586 , SB1704 , SB1854 , SB1856 , SB2165 , SB2203 , SB2342 , SB2367 , SB2452 , SB2501 , SB2520 , SB2521 , SB2538 , SB2539 , SB2703 , SB2835 , SB2903 , SB2926 , SB2959 , SB2965 , SB3029 , HB22 , HB1392 , HB3093 , HB3096 , HCR6 , HCR12 , HCR29 , HCR50 , HCR55 , HCR56 , HCR58 , HCR70 , HCR71 , HCR74 , HCR78 , HCR80 , HCR107 , HCR116 , HCR117 , SJR36 , SJR50 , SJR63 , SCR12 , SCR39 , SCR48 , SB2023 , SB62 , SB666 , SB847 , SB284 , SB854 , SB1073 , SB810 , SB1505 , SB583 , SB507 , SB1434 , SB1772 , SB2016 , SB1163 , SB1122 , SB731 , SB397 , SB508 , SB1436 , SB287 , SB261 , SB1882 , SB393 , SB1791 , SB209 , SB2429 , SB511 , SB2309 , SB510 , SB1085 , SB1975 , SB2717 , SB1262 , SB636 , SB2056 , SB884 , SB1200 , SB1845 , SB2458 , SB801 , SB3014 , SB3013 , SB758 , SB2797 , SB2076 , SB2876 , SB1640 , SB2538 , SB1449 , SB1181 , SB1359 , SB410 , SB1234 , SB2926 , SB2972 , SB2841 , SB1856 , SB1528 , SB1373 , SB672 , SB2891 , SB1854 , SB317 , SB2539 , SB2532 , SB1250 , SB2082 , SB2203 , SB1285 , SB1454 , SB2520 , SB1237 , SB1586 , SB2819 , SB629 , SB2342 , SB2903 , SB3029 , SB375 , SB777 , SB2367 , SB2703 , SB2608 , SB2965 , SB2521 , SB2165 , SB2501 , SB2452 , SB2835 , SB1602 , SB1704 , SB1723 , SB1858 , SB1946 , SB2009 , SB2177 , SB2460 , SB2785 , SB867 , SB1608 , SB640 , SB1698 , SB705 , SB748 , SB2680 , SB2994 , SB2747 , SB1950 , SB913 , SB1071 , SB1086 , SB1087 , SB1483 , SB1444 , SB1553 , SB1556 , SB1703 , SB2133 , SB2297 , SB2298 , SB2622 , SB2955 , SB3059 , SB2637 , SB2334 , SB1861 , SB2043 , SB1367 , SB2857 , SB128 , SB3058 , SB2044 , SB2363 , SB2311 , SB1986 , SB2565 , SB2943 , SB1888 , SB2417 , SB3048 , SB3052 , SB3053 , SB3036 , SB3057 , SB3056 , SB3043 , SB3037 , SB3050 , SB3063 , SB3047 , SB3035 , SB2446 , SB466 , SB2611 , SB2794 , SB2105 , SB2017 , SB1790 , SB1778 , SB1730 , SB2995 , SB2847 , SB205 , SB2619 , SB1903 , SB203 , SB3061 , SB1581 , SB2600 , SB2799 , SB2790 , SB2688 , SB2515 , SB1230 , SB876 , SB2522 , SB2639 , SB2137 , SB2519 , SB2403 , SB2459 , SB3051 , SB2655 , SB2251 , SB2764 , SB2878 , SB1884 , SB111 , SB582 , SB2617 , SB1835 , SB2751 , SB2959 , SB2063 , SB1400 , SB2058 , SB2260 , SB2928 , SB1310 , HJR99 , HJR2 , HJR1 , HB 1109 , HB1392 , HB22 , HB3093 , HB517 , HB 1130 , HB1689 , HB2018 , HB2884 , HB1393 , HB2730 , HB1399 , HB 1244 , HB467 , HB331 , HB2559 , HB26 , HB166 , HB353 , HB2000 , HB2756 , HB3248 , HB3513 , HB3204 , HB3135 , HB3012 , HB2763 , HB2523 , HB2457 , HB2415 , HB2198 , HB2143 , HB1708 , HB1672 , HB767 , HB1327 , HB2723 , HB451 , HB140 , HB 109 , HB3096 , HB206 , HB 1238 , HB 1089 , HB2890 , HB9 , HB2081 , HB4215 , HB2970 , HCR6 , HCR12 , HCR29 , HCR50 , HCR55 , HCR56 , HCR58 , HCR70 , HCR71 , HCR74 , HCR78 , HCR80 , HCR107 , HCR116 , HCR117 , SB2566 , SB2344 , SB1897 , SB1749 , SB1361 , SB2549 , SB2553 , HB37 , HB1899 , HB3809 , HB334 , HB554 , HB1593 , HB2607 , HB3526 , HB3810 , HB5092 , HB388 , HB2809 , HB 1151 , HB913

Transcript Highlights:

• </c> use PUC rules PU uh but once the rules use PUC rules PU uh but once the rules are<00:12:07.200><
• . rules. rules.
• The rule is adopted. So this was an interim rule.
• </c> accept the rules 2635. accept the rules 2635.
• </c> The rule is adopted. The rule is adopted.

Summary: The committee opened with housekeeping items, approved the minutes and consent agenda, and reminded the public that JLCAR’s role is limited to determining whether agency rules are within statutory authority, not to decide policy. Testimony was to be limited, and members noted that policy concerns should be addressed through the legislature rather than the committee process. The first major item was Public Utilities Commission rule 25-215 concerning natural gas suppliers. Staff said the proposal had been postponed because the PUC appeared to lack authority to impose fines and penalties in this rule set, especially suspending or revoking registrations, and recommended either a conditional approval removing those provisions or a preliminary objection for lack of statutory authority. PUC counsel responded that the cited authority had been incorrect, that the Department of Energy now has most registration rulemaking authority, but argued the commission still has jurisdiction over mediation and dispute resolution and may still have authority over fines because natural gas suppliers are not expressly excluded from public-utility status. Committee members discussed the split between PUC and DOE authority and the possibility that the transition in authority had not been fully cleaned up in statute. The committee then voted to grant a waiver of the time limit and postpone the item for another month so the agencies could work with counsel and clarify which parts of the rule could proceed. Members also urged that any needed legislative fix be brought forward quickly, noting that the Senate was not taking up non-germane amendments and suggesting the House as the likely venue for a cleanup bill. The committee next took up Department of Energy EN900 and EN1000 rules. Staff said the EN900 net-metering rules had been postponed previously and that the main remaining issue was a retroactive requirement in EN909.03(b), which the agency agreed to revise so the language would apply only on or after the 2026 effective date of the chapter. The agency described the EN900 rules as implementing net metering authority transferred from the PUC and expanding the chapter to cover municipal group net metering and low- and moderate-income community solar projects. The EN1000 interconnection rules were described as implementing 2024 legislation requiring uniform procedures for distributed energy resources. The department said both sets of rules were developed through extensive stakeholder input and asked for approval subject to the oral amendment already discussed."}】【。json

Transcript Highlights:

• There being 31 ayes and 0 nays, the rule is suspended.
• There being 31 ayes and 0 nays, the rule is suspended.
• There being 31 ayes and 0 nays, the rule is suspended.
• There being 31 ayes and 0 nays, the rule is suspended.
• There being 31 ayes and 0 nays, the rule is suspended.

Bills: SCR37 , SB60 , SB226 , SB231 , SB264 , SB387 , SB570 , SB596 , SB651 , SB769 , SB855 , SB863 , SB991 , SB1079 , SB1085 , SB1151 , SB1191 , SB1214 , SB1243 , SB1247 , SB1314 , SB1364 , SB1372 , SB1401 , SB1409 , SB1504 , SB1522 , SB1625 , SB1662 , SB1663 , SB1728 , SB1759 , SB1762 , SB1804 , SB1818 , SB1838 , SB1839 , SB1851 , SB1855 , SB1872 , SB1873 , SB1874 , SB1877 , SB1879 , SB1901 , SB1919 , SB1921 , SB1923 , SB1936 , SB1937 , SB1968 , SB1977 , SB2034 , SB2053 , SB2066 , SB2077 , SB2124 , SB2143 , SB2166 , SB2180 , SB2204 , SB2231 , SB2237 , SB2243 , SB2321 , SB2569 , SJR39 , SJR68 , SCR29 , SCR42 , SB22 , SB30 , SB33 , SB37 , SB75 , SB217 , SB240 , SB331 , SB393 , SB505 , SB530 , SB546 , SB552 , SB584 , SB586 , SB618 , SB626 , SB636 , SB732 , SB762 , SB769 , SB825 , SB844 , SB870 , SB884 , SB926 , SB964 , SB1080 , SB1099 , SB1150 , SB1177 , SB1184 , SB1261 , SB1262 , SB1314 , SB1325 , SB1364 , SB1398 , SB1455 , SB1506 , SB1524 , SB1577 , SB1596 , SB1620 , SB1624 , SB1642 , SB1643 , SB1646 , SB1667 , SB1727 , SB1760 , SB1789 , SB1791 , SB1804 , SB1806 , SB1851 , SB1868 , SB1870 , SB1901 , SB1923 , SB1927 , SB1951 , SB1960 , SB1962 , SB2010 , SB2023 , SB2024 , SB2037 , SB2051 , SB2052 , SB2056 , SB2066 , SB2122 , SB2129 , SB2180 , SB2183 , SB2185 , SB2207 , SB2226 , SB2252 , SB2323 , SB2361 , SB2368 , SB2405 , SB2420 , SB2425 , SB2569 , SB2717 , SB2949 , SB1 , SJR36 , SJR50 , SJR39 , SJR63 , SJR68 , SCR12 , SCR39 , SCR38 , SCR37 , SCR42 , SCR29 , SB1596 , SB33 , SB505 , SB37 , SB62 , SB666 , SB847 , SB284 , SB854 , SB1073 , SB810 , SB1539 , SB1505 , SB583 , SB957 , SB1502 , SB507 , SB1026 , SB1349 , SB1433 , SB1434 , SB264 , SB1364 , SB1376 , SB1585 , SB1772 , SB2016 , SB1163 , SB619 , SB1122 , SB1877 , SB732 , SB731 , SB397 , SB508 , SB1436 , SB964 , SB287 , SB2143 , SB261 , SB1247 , SB1882 , SB618 , SB393 , SB2243 , SB2226 , SB1919 , SB1791 , SB22 , SB651 , SB1080 , SB826 , SB1079 , SB1243 , SB1504 , SB1851 , SB1879 , SB2237 , SB1257 , SB2034 , SB1522 , SB1151 , SB596 , SB1191 , SB226 , SB570 , SB870 , SB991 , SB60 , SB1401 , SB1728 , SB586 , SB529 , SB217 , SB209 , SB1923 , SB1839 , SB387 , SB1874 , SB1872 , SB1873 , SB1921 , SB1883 , SB1620 , SB1838 , SB2024 , SB2429 , SB1999 , SB511 , SB2309 , SB2166 , SB510 , SB2420 , SB1860 , SB1314 , SB1398 , SB855 , SB2425 , SB2037 , SB1759 , SB1924 , SB1818 , SB1762 , SB1968 , SB1977 , SB2077 , SB2321 , SB1662 , SB1663 , SB2124 , SB2204 , SB1855 , SB863 , SB2252 , SB1962 , SB2253 , SB825 , SB1577 , SB1184 , SB2018 , SB2206 , SB1901 , SB2368 , SB1963 , SB1960 , SB1643 , SB1625 , SB1299 , SB841 , SB668 , SB584 , SB231 , SB1085 , SB2431 , SB2231 , SB1490 , SB530 , SB1261 , SB552 , SB1099 , SB1646 , SB2180 , SB1804 , SB1937 , SB1936 , SB2569 , SB1372 , SB1506 , SB1806 , SB1868 , SB2361 , SB2314 , SB769 , SB1409 , SB2122 , SB434 , SB1214 , SB1951 , SB2183 , SB2046 , SB1667 , SB1870 , SB1727 , SB2405 , SB2127 , SB1975 , SB1760 , SB1734 , SB1335 , SB2066 , SB2129 , SB2246 , SB2439 , SB1624 , SB1244 , SB1468 , SB2717 , SB1612 , SB1262 , SB604 , SB2395 , SB2185 , SB1832 , SB1745 , SB1746 , SB2207 , SB2023 , SB1784 , SB1524 , SB626 , SB528 , SB437 , SB269 , SB1137 , SB968 , SB636 , SB747 , SB1325 , SB1789 , SB1455 , SB2056 , SB75 , SB1940 , SB2052 , SB1927 , SB2010 , SB1579 , SB2068 , SB3034 , SB844 , SB1920 , SB1177 , SB1558 , SB1236 , SB1044 , SB926 , SB884 , SB463 , SB331 , SB227 , SB240 , SB517 , SB1200 , SB1410 , SB1626 , SB1845 , SB1863 , SB2216 , SB2681 , SB1717 , SB2053 , SB546 , SB2141 , SB2949 , SB2323 , SB2200 , SB2332 , SB2199 , SB1642 , SB1150 , SB1757 , SB2050 , SB1138 , SB2051 , SB2626 , SB2458 , SB1864 , SB30 , SB2201 , SB1862 , SB1583 , SB1055 , SB2660 , SB1898 , SB2662 , SB2161 , SB2964 , SB2881 , SB1065 , SB801 , SB2743 , SB2533 , SB1413 , HJR4 , SB2073 , SB3014 , SB3013 , SB2774 , SB2702 , SB2629 , SB2443 , SB2349 , SB2167 , SB2145 , SB2121 , SB758 , SB648 , SB647 , SB512 , SB438 , SB1721 , SB2268 , SB1495 , SB2705 , SB2366 , SB1422 , SB1369 , SB1013 , SB682 , SB2692 , SB2570 , SB2797 , SB2111 , SB1896 , SB1164 , SB1020 , SB663 , SB2371 , SB1152 , SB2196 , SB2383 , SB2581 , SB2798 , SB330 , SB646 , SB843 , SB1998 , SB1418 , SB2788 , SB1169 , SB2873 , SB1754 , SB1534 , SB1718 , SB2779 , SB2004 , SB1143 , SB1756 , SB912 , SB2119 , SB2032 , SB527 , SB1580 , SB1952 , SB2601

Transcript Highlights:

• of the proposed rule.
• a proposed rule.
• rule, if the proposed rule is not ratified during the next legislative session, the emergency rule shall
• emergency rule before the emergency rule has expired.
• of the superseded rule.

Committee: Senate Governmental Oversight and Accountability

Summary: The Committee on Governmental Oversight and Accountability met for its first meeting of the session, took roll, and heard a presentation from Ken Plant of the Joint Administrative Procedures Committee on SB 108, the 2025 law overhauling Florida rulemaking. The presentation focused on new deadlines for agencies to begin and publish rules, limits on automatic sunset provisions, changes to emergency rule procedures, expanded public input on statements of estimated regulatory costs, a five-year review cycle for existing rules, and new licensing-reporting requirements. Members asked about the review timeline and emphasized the need to keep agencies accountable for meeting the new requirements. The committee then reviewed the Department of Management Services’ response to Auditor General Report 2025-1096 on fleet management. DMS said the audit found 10 issues, most of which it believes it has addressed, and described the statewide fleet system as tracking about 27,000 assets with limited staff. DMS highlighted two major improvement ideas that would require funding: an enterprise telematics system to automate vehicle data and improve tracking, and centralized fleet procurement to reduce duplication and save money. Members questioned the status of FleetWave implementation, missing vehicle records, integration with other state systems, and access controls for separated employees. DMS explained that FleetWave is fully implemented but still relies on manual data entry, that discrepancies with the state accounting system largely reflect mismatched or inconsistent entries, and that policies and procedures were updated after the audit. The department said it now works more closely with People First to deactivate access when employees leave. After discussion, no further business was raised, and the committee adjourned without objection.

Transcript Highlights:

• management rules.
• The first rule is the rules for control of ionizing radiation.
• These rules are the rules for mobile home and recreational parks.
• These rules are the rules pertaining to lead-based paint activities.
• the rules?

Committee: All ALC-ADMINISTRATIVE RULES

Summary: The Administrative Rules Subcommittee reviewed a long agenda of agency rules, with most items approved without objection after brief presentations and no public comment. Early items included Department of Energy and Environment rules on landfill post-closure trust fund spending thresholds and liquefied petroleum gas standards, DFA’s electronic odometer disclosure rule, and several Department of Health rules covering ionizing radiation, mobile home and RV parks, lead-based paint, counseling board revisions, hearing instrument dispensers, athletic training, dental examiners, nursing, pharmacy, medical board, speech-language pathology and audiology, radiologic technology, massage therapy, community health workers, doula certification, and cosmetology/body art. Most of these changes were described as updates to match recent acts, federal standards, compact participation, fee adjustments, or cleanup/clarification, and the committee repeatedly approved them without objection. A substantial portion of the meeting focused on the Arkansas State Board of Nursing’s broad set of rule changes implementing multiple 2025 acts. Those changes included creating a dialysis patient care technician registry, updating contact information requirements, expanding APRN authority to delegate certain tasks, clarifying death certificate and pronouncement authority, allowing substitution of therapeutically equivalent medications, permitting purchase of compounded products, and updating certified medication assistant rules and training standards. Members asked detailed questions about the meaning of therapeutically equivalent substitutions, delegation limits, compounded products, and how often medication lists would be updated; the board said it would review rules annually and use future rulemaking as needed. The committee also approved new nursing rules for declaratory orders and the new dialysis registry. The Department of Education’s rules drew the most discussion, especially the Arkansas Children’s Educational Freedom Account Program. The department said the revisions, based on Act 920 of 2025, were intended to add guardrails, clarify eligible expenses, and streamline approvals. Changes included defining core educational expenses, limiting sports-related spending, adding an intentional misuse standard, restricting certain technology purchases and requiring extra justification over $1,000, capping carryover funds at $8,500, and creating a reconsideration process for denied expenses. Members raised concerns about oversight, appeal timelines, sports equipment, provider credentialing, and whether the rules were too restrictive; department officials said the rules were meant to protect taxpayer funds while preserving flexibility, and they noted the program had received extensive public comment. The committee also approved Education rules for scholarships, residency classification, teacher programs, accelerated learning, and graduate medical education, as well as Labor and Licensing rules on wage and hour standards, boiler rules, motor vehicle commission requirements, professional wrestling regulation, appraiser qualifications, and military recruiting incentives.

Transcript Highlights:

• RULE IS DISCRETIONARY.
• IN ADDITION EVEN WHERE A RULE IS DISCRETIONARY, IF THAT RULE INCORPORATES FORMS OR DETAILED PROCEDURES
• SUCH THAT AN ABSENCE OF THAT RULE, THE AGENCY WOULD BE UNADOPTING THE RULE CHALLENGE SIMPLY BY DOING
• THAT THE AGENCY MUST ADOPT RULES.
• THE RULE AND HAVE BEEN AMENDED SINCE THE RULE WAS ADOPTED WITHOUT GOING THROUGH THE FORMAL RULE AMENDMENT

Transcript Highlights:

• management rules.
• The first rule is the rules for control of ionizing radiation.
• These rules are the rules for mobile home and recreational parks.
• the rules?
• the rules?

Committee: All ALC-ADMINISTRATIVE RULES

Summary: The Administrative Rules Subcommittee met to review a long agenda of agency rule changes, beginning with housekeeping on the order of business and then taking up rules from multiple state agencies. Early items included Department of Energy and Environment rules on landfill post-closure trust fund spending thresholds and liquefied petroleum gas standards, DFA’s odometer disclosure rule allowing electronic signatures and disclosures, and several Department of Health rules covering ionizing radiation, mobile home and recreational parks, lead-based paint, counseling licensure, hearing instrument dispensers, athletic training, dental specialties and compacts, nursing, pharmacy, physician assistants, medical compacts, speech-language pathology and audiology, radiologic technology, massage therapy, community health workers, doula certification, and cosmetology/body art. Most of these were described as technical updates, conformity with recent acts, federal standards, or compact participation, and nearly all were approved without objection after brief questions and, in many cases, no public comment. The committee also reviewed Department of Labor and Licensing rules on minimum wage/independent contractor standards, boiler rules, motor vehicle commission requirements for ATV/LSV dealers, professional wrestling regulation, appraiser qualifications, and military recruiting and retention programs. Testimony generally emphasized that the rules implemented recent legislation, updated fees or licensing standards, or streamlined existing processes. Members asked a few questions about fee structures, the rationale for regulating professional wrestling, and how the National Guard’s public-private partnership and incentive programs would work; the department said the recruiting incentives would be funded from existing appropriations and were intended to improve retention and force strength. These rules were also approved without objection. The most extensive discussion came on the Department of Education’s Arkansas Children’s Educational Freedom Account Program rule. The department said the revisions, based on Act 920 of 2025, were intended to add guardrails, clarify allowable expenses, and speed approval of core educational purchases. Changes included defining core educational expenses, limiting certain sports-related spending, adding an intentional misuse standard, restricting phone purchases except for disability-related needs, setting a $1,000 threshold for additional review of technology purchases, capping carryover funds at $8,500, and creating a reconsideration process for denied expenses. Members raised concerns about safeguards, appeals, sports equipment, provider credentialing, rural vendor access, and whether the department would be flexible or overly restrictive. The department said it would review every request, provide written explanations for denials, allow appeals up to the State Board, and refer suspected fraud to prosecutors if necessary. After hearing from 13 members of the public, the committee continued to discuss the rule, but the transcript ends before any final vote on the EFA rule is shown.

Transcript Highlights:

• management rules.
• The first rule is the rules for control of ionizing radiation.
• These rules are the rules for mobile home and recreational parks.
• These rules are the rules pertaining to lead-based paint activities.
• the rules?

Committee: All ALC-ADMINISTRATIVE RULES

Transcript Highlights:

• Docket 0113-2501 is both a pending rule and a temporary rule for the rules for ore processing by cyanidation
• The pending rule information begins on page 396 of the pending rules review book, and the temporary rule
• again, both the pending rule and the temporary rule.
• rule.
• Rule.

Committee: Senate Resources and Environment

Transcript Highlights:

• </c> large rule 6350. large rule 6350.
• Why didn't you finish rule making rule.
• rule is the rule comes into play and the rule is the rule applies. applies. applies.
• </c> rule, can you make that an expired rule? rule, can you make that an expired rule?
• . rule. rule.

Summary: The committee opened with routine business, including the Pledge of Allegiance, seating alternates, and approval of the minutes and consent calendar. Both were approved without opposition. The committee then moved to the regular calendar, beginning with Department of Environmental Services drinking water rules (2532). Staff noted that the final proposal deleted requirements that had been in the initial proposal, making the published notice technically inaccurate because it said there were no substantive changes. The agency responded that the requirements still exist in other rules, that regulated entities and the Water Council were notified, and that the public had notice through related hearings. After discussion about whether a new noticed hearing was needed, the committee approved the rule. The next item was Department of Administrative Services personnel rule 2510 on seniority and employee performance evaluation. Staff raised informational comments and one unclear comment about language that appeared to require a checkbox even though no form exists, and about evaluation categories that could overlap. The agency said the checkbox language should be removed, but defended the overlapping categories as part of a long-standing template used by agencies for the past 10 years. Members discussed whether the language was too ambiguous or could lead to inconsistent application, but the committee ultimately approved the rule with a condition striking the checkbox language in the affected sections. The committee then considered personnel rule 25109 on investigations, discipline, non-disciplinary communications, and non-disciplinary removal. Staff recommended clarifying language distinguishing license suspension from termination for cause, and questioned whether the sexual-harassment discipline language was too broad because the same conduct could fit multiple discipline levels. The agency agreed to add the suggested clarification for the license-suspension provision, but argued the sexual-harassment language should remain because another rule already provides the factors for determining the appropriate discipline and the agency needs discretion for fact-specific cases. The discussion included concerns about how non-verbal conduct might be treated, but the committee moved toward conditional approval with the agreed clarification and approval of the rest of the rule as written.