My client, the employment security department (ESD), disallowed some costs of a local workforce development council (WDC). The WDC has requested a hearing. The applicable CFR requiring the state to provide a hearing appears to be 20 CFR 667.600(d). ESD has not promulgated any rules of procedure for this type of hearing and this would be the first one. If we look to our state administrative procedure act, the hearing would be held by a state administrative law judge and appeal from the final agency decision would be to our state court system as in other APA appeals. Am I missing anything in the federal rules related to process, such as appeal from the state ALJ to USDOL as in job service system appeals? Bruce Turcott Assistant Attorney General Licensing and Administrative Law Division (360) 586-2738