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Russell Friedman & Associates submitted the following comments to the Proposed Ninth Amendment to Regulation 68

The implementation of the Proposed Ninth Amendment to Regulation 68 (“The Proposed Amendment”) would give the no-fault insurer the option to void the AOB when the no-fault insurer issues a denial for the patient’s failure to attend either an IME or an EUO. This would create a climate of extreme uncertainty that would detrimentally impact the patient, the healthcare provider, and the liability portion of the automobile policy in ways not yet perceived by the Department of Financial Services. The Firm believes that the extremely detrimental, albeit unintended, consequences of the Proposed Amendment outweigh any potential benefit gained therefrom. Based on this belief, the Firm submitted the following comments opposing the enactment of the Proposed Amendment.