In Stone and Edwards Insurance Agency, Inc. v. Department of Insurance, 161 Pa. Commw. 177, 636 A.2d 293, 297 (Pa. Cmwlth.), aff'd, 538 Pa. 276, 648 A.2d 304 (1994), the Court opined that impermissible commingling exists within an administrative agency when the prosecutorial and administrative functions are not adequately separated. Due process rights not only can be violated when there is actual commingling, but even when an appearance that commingling of functions may have taken place within the agency exists. Stone. Citing Lyness, the Court opined a single administrative agency may exercise both prosecutorial and adjudicative functions if "walls of division" are constructed within an agency that clearly separate those two functions. Stone, 636 A.2d at 297. Sub-entities of administrative agencies can perform prosecutorial and adjudicative functions without commingling the two, as long as walls of division are constructed to eliminate the threat or appearance of bias.