Division of Administrative Hearings, Florida
Filed: Jul. 22, 2009
The issue is whether the guidelines set forth in the Specialty Product Administration Field Examination Policy Procedures (SPA Field Exam Policy), Viatical Settlement Provider Examination Manual (VSP Manual), Viatical Settlement Provider Examination Procedures (VSP Exam Procedures), and notice-of- examination letters constitute agency statements defined as rules but not adopted as such, in violation of Section 120.54, Florida Statutes.Petitioner did not show that Respondents' engagement letters and training manuals were unpromulgated rules.
