In Ohio State Chiropractic Assoc. v. Ohio Bur. of Workers' Comp. (Jan. 21, 1993), Franklin App. No. 92AP-874, 1993 Ohio App, the appellees filed an action against the bureau seeking an injunction against the enforcement of Chapter 13 of the bureau's provider billing and reimbursement manual, which was promulgated through provider bulletins, and seeking a declaratory judgment that Chapter 13 was invalid because the bureau had not complied with the rule-making requirements of R.C. 119 in promulgating it. Chapter 13 contained information about the standards and eligibility requirements for the payment of physical medicine fee bills. The bureau claimed that Chapter 13 was not a set of rules, but, rather, a set of guidelines that it could adopt without the R.C. 119 procedure, pursuant to a prior version of R.C. 4121.32 that did not include current subsection (D). The trial court in Ohio State Chiropractic granted summary judgment to the appellees, finding that Chapter 13 contained rules and was subject to the rule-making requirements in R.C. 119. On appeal, this court affirmed the trial court. The Court found that, although former R.C. 4121.32(A), (B), and (C) provided an exemption for rule-making by allowing the supplementation of rules via operating manuals, the exemption found in subsections (A), (B), and (C) referred specifically to "employees" and "operating procedures." The Court stated that the guidelines discussed in these provisions related only to employees and were designed to help the employees perform their functions and direct them regarding operating procedures and decision making. Thus, any manuals and guidelines adopted, pursuant to R.C. 4121.32, were not subject to the rule-making requirements of R.C. 119.01(C), which specifically excludes from the definition of "rules" internal management regulations for employees that do not affect private rights. However, the Court concluded that Chapter 13 in Ohio State Chiropractic was a "rule" that did not fall within the rule-making exemption in R.C. 4121.32 because it concerned eligibility for payment and reasonable medical charges that affected the private rights of third parties and was not related to internal management to assist employees in performing their functions. The Court also noted R.C. 4121.32 contained no language specifically excluding the agency from compliance with R.C. 119 in adopting "rules," as defined by R.C. 119.01(C).