MSAPA - What does MSAPA stand for? The Free Dictionary
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Under section 311 of the MSAPA, agencies are required to afford those affected by a nonlegislative rule "an adequate opportunity to contest the legality or wisdom of a position taken in the document.
Requiring notice-and-comment rulemaking for any nonlegislative rules that are considered binding would produce more of a Whac-a-Mole effect than some of the more modest reforms in the MSAPA.
More modest proposals like those contained in the MSAPA and put forth by Professor Asimow (144) are less likely to lead to a game of Whac-a-Mole.