DEEN, Presiding Judge.
These appeals involve at bottom the Cardiac Surgery Rule (CSR), which was adopted by the State Health Planning Agency (agency) pursuant to its rule-making authority. OCGA § 31-6-21 (b). The CSR provides: "Adult cardiac surgery services and pediatric cardiac catherization and surgical services are reasonably available and distributed in the State consistent with the need for such services. Absent major population changes, the availability...
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