figure.” Id. at 417. Unlike the board’s vote in Rogue Flyfishers, the health policy, as applied, has a direct effect on persons other than DOC employees. It directly affects the inmate and whether the health care provider will provide medical treatment. Furthermore, there is no further action necessary, as in Rogue Flyfishers, before the health policy affects an inmate. A health care provider either provides or refuses to provide a medical procedure based on the provisions of the health policy. We therefore conclude that the health policy constitutes a rule and not an internal management directive. Therefore, the DOC should have followed rulemaking procedures in adopting the health policy. Because the DOC did not adopt the health policy as a rule, the health 844, 561 P2d 674 (1977)
holding that an employees suit against agent for denied disability benefits was preempted holding that retirement benefits are accrued benefits under erisa holding that disability benefits are not retirementtype benefits holding that the defendants internal office memorandum directing staff to deny all new applications for adult services programs was not an internal management directive because the impact on the public was direct persons seeking benefits    are denied benefits recognizing that a federal court may not review a challenge to a benefits determination of the office of workers compensation programs in the department of labor