Interview with Steven Dow: Rules are rules
Note: In September, the Attorney General’s office issued a letter addressing whether the Oklahoma Commission for Human Services had acted improperly in approving changes to the state’s child care subsidy program at a June meeting without going through the official rulemaking process. The letter was prompted by concerns raised by DHS Commissioner Steven Dow. I spoke with Commissioner Dow (who is my former employer and a former Oklahoma Policy Institute Board member) on September 30th; this is an edited transcript of our conversation.
David Blatt: Could you describe the concerns that gave rise to the Attorney General’s letter?
Steven Dow: Well, the concerns were not related to the wisdom of the policy but rather to the question of whether or not procedurally the DHS Commission was acting properly in revising the child care eligibility and co-payment schedule. It was my understanding that according to Oklahoma law, in order to change the eligibility standards and the co-pay schedule, we were required to follow the Administrative Procedures Act . So that question was posed to the Attorney General’s office, not in the form of an actual binding AG’s opinion but to get their ‘advice’.
David: What did the AG determine? Read the rest of this entry »





