Since implementation of the rule, the MPI management team has discussed every sanction to be imposed and has found some scenarios where the amount of the fines far exceeds what was expected. As the intent of the rule is to encourage compliance (those providers who aren’t going to come into compliance or need more severe “punishment” will be recommended for other administrative action), MPI believes several areas need to have a “cap” on fines. The rule is being amended to implement these “caps”. Additionally, several changes have been prepared in response to the issues that were raised in the rule challenge (and as a part of the settlement in that matter). Also, MPI found issues that needed to be changed (either due to error or for clarity) while conducting training for implementation; these changes are incorporated in the amended rule. Finally, MPI believed it was important to clarify in the rule some items that are a part of the bureau protocols but were not clarified in the rule. This will ensure continued consistency in its application.