This can be confusing. Moreover, the argument can be made that such a de facto administrative standard should be in rule form. Similarly, the manual does not always distinguish between the law and the information the Division requires from employers to do the wage audits. This has led some to believe the 90-day standard refers to the injured employe which, again, can be confusing. Finally, the manual has been rewritten by audit clerks who, because they know so much, tend to leave out a lot.
Documents written by experts for experts can often confuse the occasional user.
It is better to rewrite 102.11 than to write a rule. A statutory approach will be clearer and simpler. Mr. Smith emphasized that his handouts were intended to illustrate concepts and directions and were very preliminary. He said attorneys and insurers, among others, would be requested to participate in the wage codification process before anything more conclusive is presented to the Council. DVR changes in certification for retraining under s. 102.61.