At issue in this action brought pursuant to the Patient’s Right to Independent Review Act (PRIRA), MCL 550.1901 et seq., is whether the Commissioner of the Office of Financial and Insurance Services (OFIS)1 is bound by the recommendations of an independent review organization (IRO) on issues of medical necessity and clinical review. We conclude that the act provides that the commissioner is not bound by such recommendations. Accordingly, we reverse the judgment of the Court of Appeals and the order of the trial court that held to the contrary and remand this matter to the trial court for further proceedings consistent with this opinion.

I. FACTUAL BACKGROUND AND PROCEDURAL POSTURE

Douglas Ross was covered under the health maintenance organization (HMO) health plan of respondent *156Blue Care Network of Michigan (BCN). The certificate of coverage excluded out-of-network services that were not preauthorized.2 However, it did provide coverage for medically necessary services without prior authorization in cases of immediate and unforeseen medical emergency, but only until such time as it became medically feasible to transfer the person covered under the health plan to an in-network provider.3

*157In March 2002, Ross contracted an acute form of multiple myeloma. Ross was referred to the University of Michigan Medical Center, an in-network provider, which in a May 28, 2002, letter recommended to Dr. Stephen Goldfarb, one of Ross’s oncologists, that Ross receive a stem-cell transplant and advised that it had given Ross information on bone-marrow transplants and instructed Ross to discuss this option with Dr. Goldfarb. According to Desiree Ross (petitioner), who is Ross’s wife and the personal representative of his estate, Ross’s condition began to spiral out of control toward the end of June 2002, Ross’s oncologist told him that he was no longer eligible for treatment at the University of Michigan Medical Center because the cancer had spread to his soft tissue, and Ross was consigned to palliative treatment. She also claimed that Dr. Ronald Lutsic, a radiation oncologist, told her in June 2002 that Ross’s prognosis was dismal and that if he were Ross, he would go to the Myeloma Institute in Little Rock, Arkansas (the facility), one of two facilities in the world at the forefront of treating multiple myeloma.

Petitioner called Ross’s primary care physician (PCP), Dr. Michael Silverstone, to ask for a referral to the facility, which was not a BCN in-network provider. BCN advised that it needed to review the facility’s treatment plan and that it would take 10 to 14 days to review the request. The facility said that it could not provide a treatment plan without first evaluating Ross.

On July 2, 2002, Ross went to Arkansas and began an evaluation at the facility without BCN’s approval. On July 8, 2002, Dr. Frits van Rhee, the evaluating doctor, admitted Ross to the hospital, noting that without *158aggressive intervention, Ross had only about seven days to live. Ross was hospitalized from July 8, 2002, to July 23, 2002. The July 23, 2002, discharge summary indicated that Ross was “stable for discharge and outpatient followup . . ..” In the meantime, Ross had received notices from BCN on July 9, July 15, and July 16 denying coverage for treatment at the facility because either the services were available in-network or there was no referral from his PCIJ and advising Ross to contact his PCP for a referral to an in-network provider.

Although petitioner claimed that BCN never informed her of any in-network providers that could treat Ross’s condition, she did not indicate that she had contacted Ross’s PCP as advised by BCN for such a referral, and she did not present any evidence that the University of Michigan Medical Center was unable to administer the same treatment Ross received at the facility. Ross continued with both outpatient and inpatient treatment at the facility without BCN’s authorization until March 2003. He died on April 6, 2003. BCN refused to cover any evaluation or treatment at the facility.

On December 18, 2002, pursuant to BCN’s internal procedures, petitioner initiated a “step one” appeal of the denial of coverage for Ross’s treatment at the facility that had begun on June 30, 2002. BCN denied the appeal on January 9, 2003, because (1) the PCP had not referred Ross, (2) BCN had not authorized the services and there was no indication that the services were not available in-network, and (3) BCN considered the facility’s services to be experimental. On February 6, 2003, petitioner filed a “step two” internal appeal, which BCN denied. On April 28, 2003, petitioner appealed to OFIS under PRIRA. The commissioner accepted the request and assigned the case to an IRO.

*159The IRO’s initial report, dated May 16, 2003, indicated that “this must be considered an emergency evaluation and admission in the mind of a prudent patient,” that attempts were made to use in-network providers, that Ross was not offered a reasonable alternative plan of care that would address his condition, and that the treatment he received at the facility should not have been considered experimental. After receiving the initial report, the commissioner repeatedly sought to compel the IRO to apply the contractual and statutory standards rather than the IRO-imposed prudent-patient standard for evaluating an emergency,4 sending *160the IRO three requests for clarification whether the June 30, 2002, outpatient consultation, the July 8, 2002, to July 23, 2002, inpatient admission, the August 1, 2002, to August 2, 2002, inpatient admission, and the *161September 9, 2002, to November 17, 2002, follow-up testing constituted emergency care, which would be covered under the certificate of coverage, as well as under MCL 500.3406k,5 and whether Ross became stabilized at any point so as to make it medically feasible to transfer him to an in-network facility.

The IRO responded that Ross was admitted to the facility on an emergency basis and that it was not appropriate to transfer him to an in-network facility for treatment or follow-up because the in-network facility was not involved in Ross’s treatment. In the IRO’s last two responses, it stated that it was not medically feasible to transfer Ross from July 8, 2002, to July 23, *1622002, and that it was inappropriate to unbundle the remaining care provided. The only time the IRO stated that it was not medically feasible to transfer Ross was in response to the commissioner’s question regarding the July 8, 2002, to July 23, 2002, admission. The IRO recommended on three separate occasions that BCN’s denial of petitioner’s claim be overturned.

The commissioner found that only the inpatient admission to the facility from July 8, 2002, to July 23, 2002, was a medical emergency under the definition of “emergency care” in BCN’s health plan. She upheld the denial regarding the remainder of the services on the grounds that (1) out-of-network services were not covered, (2) BCN did not approve the out-of-network services, (3) there was no evidence that treatment was unavailable within the network, given that Ross’s PCP had referred him to the University of Michigan Medical Center, a multidisciplinary cancer treatment center, and (4) other than the July 8, 2002, to July 23, 2002, hospitalization, the care was not emergency care under the policy or Michigan law.

Petitioner appealed the commissioner’s decision in the circuit court, arguing alternatively (1) that it was not medically feasible to transfer Ross to an in-network facility because of the emergency nature of his condition, (2) that Ross had a referral from his PCR so the services did not need to constitute emergency medical care, and (3) that the services were not available in-network. Focusing on the argument that the services were emergency services, the circuit court reversed the part of the commissioner’s decision that upheld BCN’s denial of coverage, reasoning that the commissioner’s conclusion — that some but not all of the facility’s services were emergency services — was not authorized by law.

*163The Court of Appeals granted BCN’s application for leave to appeal and affirmed with respect to the services provided through November 17, 2002. Ross v Blue Care Network of Michigan, 271 Mich App 358; 722 NW2d 223 (2006). It reasoned that the commissioner had failed to comply with the requirements of PRIRA and exceeded her authority when she discounted the IRO’s medical recommendations and replaced them with her own independent determinations. Id. at 371. The panel concluded that the statement in English v Blue Cross Blue Shield of Michigan, 263 Mich App 449, 464; 688 NW2d 523 (2004) — that an IRO’s recommendation was not binding on the commissioner — was merely dictum because the English panel was never actually presented with the question whether an IRO’s recommendation is binding on the commissioner. Ross, supra at 373-375.

Alternatively, the Court concluded that even if the statement in English were binding on the Court, the English panel had recognized that the commissioner’s independent review of the IRO’s recommendation under MCL 550.1911(15) was limited to confirming that the recommendation did not contradict the health-plan provisions. Id. at 375. However, the Ross panel agreed with BCN that the circuit court erroneously required it to pay for evaluation and treatment after November 17, 2002, because the commissioner had not considered the care Ross received after that date. Id. at 380-381.

BCN applied for leave to appeal in this Court. We ordered oral argument on the application and specifically directed the parties to address whether the Court of Appeals paid sufficient attention to the provisions of PRIRA that require an IRO to provide a “recommendation” to the commissioner, and whether the Court of Appeals properly characterized as dictum the statement *164in English that indicated that the IRO’s recommendation was not binding on the commissioner. 477 Mich 960 (2006). The commissioner has filed an amicus curiae brief in support of BCN’s application.

II. STANDARD OF REVIEW

The interpretation of statutes presents an issue of law, which is reviewed de novo. Lapeer Co Clerk v Lapeer Circuit Judges, 465 Mich 559, 566; 640 NW2d 567 (2002). Decisions of an administrative agency or officer, in cases in which no hearing is required, are reviewed to determine whether the decisions are authorized by law. Const 1963, art 6, § 28.

III. ANALYSIS

PRIRA is a relatively recent addition to our state’s laws. Enacted in 2000 as part of the Legislature’s across-the-board attempt to regulate HMOs and other insurance providers consistently,6 PRIRA was intended *165to standardize the external review process designed to resolve disputes over covered benefits, establish IRO qualifications, and provide for penalties in cases of wrongful denial of benefits.

Under PRIRA, the external review process for adverse determinations made by health carriers is governed by MCL 550.1911, which provides:

(1) Not later than 60 days after the date of receipt of a notice of an adverse determination ..., a covered person ... may file a request for an external review with the commissioner....

(2) Not later than 5 business days after the date of receipt of a request for an external review, the commissioner shall complete a preliminary review of the request to determine all of the following:

(a) Whether the individual is or was a covered person in the health benefit plan ....

(b) Whether the health care service ... reasonably appears to be a covered service under the covered person’s health benefit plan.

(c) Whether the covered person has exhausted the health carrier’s internal grievance process ....

(d) The covered person has provided all the information and forms required....

(e) Whether the health care service... appears to involve issues of medical necessity or clinical review criteria.

(3) Upon completion of the preliminary review under subsection (2), the commissioner immediately shall provide a written notice ... as to whether the request is complete and whether it has been accepted for external review.

(4) If a request is accepted for external review, the commissioner shall do both of the following:

(a) Include in the written notice under subsection (3) a statement that the covered person ... may submit to the commissioner... additional information and supporting *166documentation that the reviewing entity shall consider when conducting the external review.

(b) Immediately notify the health carrier in writing of the acceptance of the request for external review.

(5) If a request is not accepted for external review because the request is not complete, the commissioner shall inform the covered person. .. what information or materials are needed to make the request complete. If a request is not accepted for external review, the commissioner shall provide written notice ... to the covered person . .. and the health carrier of the reasons for its nonacceptance.

(6) If a request is accepted for external review and appears to involve issues of medical necessity or clinical review criteria, the commissioner shall assign an independent review organization----The assigned independent review organization shall be approved... to conduct external reviews and shall provide a written recommendation to the commissioner on whether to uphold or reverse the adverse determination ....

(7) If a request is accepted for external review, does not appear to involve issues of medical necessity or clinical review criteria, and appears to only involve purely contractual provisions of a health benefit plan, such as covered benefits or accuracy of coding, the commissioner may keep the request and conduct his or her own external review or may assign an independent review organization as provided in subsection (6). .. . Except as otherwise provided in subsection (16), if the commissioner keeps a request, he or she shall review the request and issue a decision... within the same time limits and subject to all other requirements of this act for requests assigned to an independent review organization. If at any time during the commissioner’s review of a request it is determined that a request does appear to involve issues of medical necessity or clinical review criteria, the commissioner shall immediately assign the request to an independent review organization ....

*167(8) In reaching a recommendation, the reviewing entity is not bound by any decisions or conclusions reached during the health carrier’s utilization review process or the health carrier’s internal grievance process.

(9) Not later than 7 business days after the date of the notice under subsection (4)(b), the health carrier ... shall provide ... the documents and any information considered in making the adverse determination ....

(10) Upon... notice from the assigned independent review organization that the health carrier . .. has failed to provide the documents and information within 7 business days, the commissioner may terminate the external review and make a decision to reverse the adverse determination ....

(11) The reviewing entity shall review all of the information and documents received under subsection (9) and any other information submitted ....

(13) In addition to the documents and information provided under subsection (9), the reviewing entity... shall consider the following in reaching a recommendation:

(a) The covered person’s pertinent medical records.

(b) The attending health care professional’s recommendation.

(c) Consulting reports from appropriate health care professionals and other documents submitted by the health carrier, the covered person, the covered person’s authorized representative, or the covered person’s treating provider.

(d) The terms of coverage under the covered person’s health benefit plan with the health carrier.

(e) The most appropriate practice guidelines, which may include generally accepted practice guidelines, evidence-based practice guidelines, or any other practice guidelines developed by the federal government or national or professional medical societies, boards, and associations.

*168(f) Any applicable clinical review criteria developed and used by the health carrier or its designee utilization review organization.

(14) The assigned independent review organization shall provide its recommendation to the commissioner not later than 14 days after the assignment by the commissioner of the request for an external review. The independent review organization shall include in its recommendation all of the following:

(a) A general description of the reason for the request for external review.

(b) The date the independent review organization received the assignment from the commissioner to conduct the external review.

(c) The date the external review was conducted.

(d) The date of its recommendation.

(e) The principal reason or reasons for its recommendation.

(f) The rationale for its recommendation.

(g) References to the evidence or documentation, including the practice guidelines, considered in reaching its recommendation.

(15) Upon receipt of the assigned independent review organization’s recommendation under subsection (14), the commissioner immediately shall review the recommendation to ensure that it is not contrary to the terms of coverage under the covered person’s health benefit plan with the health carrier.

(16) The commissioner shall provide written notice ... to the covered person.. . and the health carrier of the decision to uphold or reverse the adverse determination ... not later than 7 business days after the date of receipt of the selected independent review organization’s recommendation. ... The commissioner shall include in a notice under this subsection all of the following:

(a) The principal... reasons for the decision ....

*169(b) If appropriate, the principal... reasons why the commissioner did not follow the assigned independent review organization’s recommendation. [Emphasis added.]

To summarize, under MCL 550.1911, the commissioner has discretion to accept or reject a request for an external review, MCL 550.1911(3). If a request is accepted, the covered person is permitted to submit “additional information and supporting documentation,” MCL 550.1911(4)(a), and the health carrier is required to submit “the documents and any information considered in making the adverse determination,” MCL 550.1911(9).

If an accepted request “involve[s] purely contractual provisions,” the commissioner has discretion to conduct his or her own external review, MCL 550.1911(7). If, however, an accepted request “involve [s] issues of medical necessity or clinical review criteria,”7 the commissioner must assign an IRO to conduct the external review, MCL 550.1911(6). IROs conduct their external reviews through clinical peer reviewers, who must be physicians or meet the requirements found in MCL 550.1919(2)8 for health-care professionals. In reaching a recommendation, the IRO is not bound by any prior *170decision or conclusion, MCL 550.1911(8). After reviewing all information, the IRO makes a recommendation concerning whether the commissioner should uphold or reverse the health carrier’s decision, MCL 550.1911(6). This recommendation must be provided within 14 days of receiving the assignment, MCL 550.1911(14).

The commissioner, who is not required to have any medical knowledge, then reviews the recommendation to ensure that it is not contrary to the terms of coverage under the covered person’s health benefit plan with the health carrier, MCL 550.1911(15). The commissioner has seven days to decide whether to uphold or reverse the health carrier’s decision, MCL 550.1911(16). The commissioner must provide the reasons for his or her decision, including the reasons why he or she decided not to follow the IRO’s recommendation, MCL 550.1911(16)(b). Finally, a party aggrieved by the commissioner’s decision may seek judicial review, MCL 550.1915(1).9

As can be seen from this statutory scheme, it is hard to imagine a more comprehensive review process. And *171this comprehensive scheme in MCL 550.1911 refers 13 times to an IRO’s recommendation.10

In its opinion, the Court of Appeals neither defined the term “recommendation” nor considered the significance of its use by the Legislature. “Recommendation” is defined as “the act of recommending.” Random House Webster’s College Dictionary (2005). “Recommending” is the gerund form of “recommend,” which is defined as “to urge or suggest as appropriate . ...” Id. “Suggest” is defined as “to mention, introduce, or propose (an idea, plan, person, etc.) for consideration, possible action, or some purpose or use.” Id. Clearly, to make a “recommendation” means to suggest or propose something; “recommendation” is not a word that connotes mandatory compliance. Nowhere in the statute does it say that the IRO’s recommendation is binding in any way, so there is nothing that would require us to impute a meaning other than the plain meaning of the term “recommendation.” Moreover, the nature of the term “recommendation” as connoting a suggestion is reinforced by MCL 550.1911(16)(b), which expressly allows the commissioner to decline to follow the IRO’s recommendation as long as the commissioner explains his or her reasons for doing so.11

*172In the only Michigan case before this one to address PRIRA, English, the Court of Appeals likewise noted that an IRO’s recommendation was not binding on the commissioner. English, supra at 464. In English, the commissioner partially reversed Blue Cross Blue Shield of Michigan’s denial of coverage for various blood tests because she found, consistently with the IRO’s recommendation, that the tests were medically necessary. Id. at 453. In response to Blue Cross’s argument that it was denied due process because it did not know the identity, and could not challenge the recommendation, of the IRO, the Court of Appeals distinguished the authority *173cited by Blue Cross because in those cases, which held that due process had been denied, the evidence was unknown to the parties, while in English, the IRO’s recommendation was not evidence, but was merely a tool to aid the commissioner, and the recommendation was not binding on the commissioner. Id. at 464.

The Court of Appeals in the instant case declared that this statement in English did not bind the Court because whether an IRO’s recommendation was binding on the commissioner was not at issue in English, given that the commissioner agreed with the IRO’s recommendation. Ross, supra at 374. In reaching this conclusion, the Court of Appeals failed to recognize or address the significance of the reason the English panel made the statement in the first place, which was to distinguish the cases cited by Blue Cross in support of its argument on denial of due process, an issue that most certainly was before the Court. The English panel held in part that PRIRA did not violate the parties’ due process rights because the IRO’s recommendation is not binding on the commissioner. Thus, its conclusion that an IRO’s recommendation is not binding on the commissioner is clearly not dictum. Instead, it was one of the reasons that the panel held that PRIRA did not violate the parties’ due process rights. When necessary to determine an issue in a case, a statement of law cannot be dictum. Wold Architects & Engineers v Strat, 474 Mich 223, 232 n 3; 713 NW2d 750 (2006).

In sum, by failing to recognize the significance of the use of the term “recommendation” and declining to follow English, the Court of Appeals applied a flawed construction of the statute to conclude that

while the Legislature intended that the OFIS Commissioner would review the IRO’s recommendation for consis*174tency and compliance with the health plan itself, the Legislature did not intend that the OFIS Commissioner would review or reevaluate the IRO reviewer’s specific medical or clinical findings. Instead, the language of PRIRA indicates that the Legislature intended the OFIS Commissioner to defer to the IRO’s recommendation on medical issues that do not implicate the language of the health plan itself. [Ross, supra at 377-378.]

This construction essentially created a judicially defined bifurcated system of review in which the IRO would be the final authority on issues of medical or clinical-review criteria, while the commissioner would be the ultimate authority on purely contractual issues. Such a construction was not supported by the plain and unambiguous language of the act itself. Given the all-encompassing, comprehensive scheme set forth in PRIRA, the absence of such a bifurcated review process in the statute convincingly demonstrates that the Legislature did not intend that the review authority be bifurcated. In fact, as previously noted, the opposite intent is demonstrated by the frequent use of the term “recommendation,” as well as by MCL 550.1911(16)(b), which provides that the commissioner must give the principal reasons why he or she did not follow the IRO’s recommendation.

Furthermore, the Legislature has contemplated in MCL 550.1911(7) that there may be situations involving purely contractual issues over which the commissioner has sole authority. Similarly, the Legislature has treated medical issues as implicating contractual matters also and has not established that the commissioner’s authority is different. That is, the commissioner has identical authority over both contractual and medical issues. The Court of Appeals failed to recognize this and erred in concluding that “medical issues” were to *175be treated differently. The act provides for no such bifurcation. Rather, when the Legislature charged the commissioner with ensuring that the IRO’s recommendation was consistent with the terms of coverage, it necessarily authorized the commissioner to review issues of medical necessity pertaining to those terms of coverage.

In any event, the commissioner’s determination was consistent with the IRO’s recommendation to the extent that the recommendation did not contradict the policy provisions or MCL 500.3406k.12 The only period for which the IRO stated that it was not medically *176feasible — the standard required in the policy — to move Ross to an in-network facility was the period from July 8, 2002, to July 23, 2002, and it was for services provided during this period that the commissioner reversed BCN’s denial of coverage.13 The IRO’s finding that it was “inappropriate” to move Ross to another *177facility after July 23, 2002, was not based on a standard set forth in either the policy or the statute. Those standards were that it be medically feasible to move the patient or that the patient be stabilized before being moved, respectively. Thus, the IRO’s error was one that involved contractual and statutory construction — error that the commissioner correctly rectified.

IV CONCLUSION

Under the PRIRA provisions for an independent external review of an adverse determination regarding coverage, an IRO’s recommendation concerning whether to uphold or reverse a health carrier’s adverse determination is merely a recommendation and is not binding on the commissioner. We reverse the judgments of the trial court and the Court of Appeals, which held otherwise, and remand the case to the trial court for further proceedings.

Reversed and remanded to the trial court.

(dissenting). The majority correctly frames the issue. It is “whether the Commissioner of the Office of Financial and Insurance Services (OFIS) is bound by the recommendations of an independent review organization (IRO) on issues of medical necessity and clinical review.”1 But the majority errs by deciding that the commissioner is never bound by such recommendations.

I conclude that the commissioner’s review is limited to ensuring that an IRO’s recommendations are not *178contrary to the terms of coverage under the covered person’s health-benefit plan.2 In this case, the IRO’s recommendation that respondent Blue Care Network of Michigan be required to pay for services provided before November 17, 2002, was consistent with the terms of coverage. Therefore, I would affirm the well-reasoned decision of the Court of Appeals.

FACTS

Respondent insured petitioner’s decedent, Douglas Ross. In February 2002, Ross began experiencing back and leg pain. By April, he could no longer walk or stand. He was diagnosed as suffering from numerous conditions, the most serious being a severe form of multiple myeloma.3

Ross underwent a variety of treatments, including chemotherapy, to combat the disease. In May 2002, he was advised to seek treatment from the Bone Marrow Transplant Clinic at the University of Michigan (U of M). Unfortunately, he was unable to begin treatment at the U of M immediately because his blood-sugar level was elevated.

By early June, Ross’s multiple myeloma had become increasingly severe and resulted in tumors in his leg, neck, and eye. Ross was advised by his treating physicians that he had an extremely aggressive strain of the disease. Dr. Lutsic, his radiation oncologist, characterized his condition as the most severe form of the disease he had ever seen. As a result of his deterioration, Ross was told that he was no longer a candidate for a *179bone-marrow transplant and that the U of M would no longer treat him. He was advised that the only remaining course of treatment was medication to handle the pain as he died.

In a final effort to prolong Ross’s life, petitioner contacted the University of Arkansas for Medical Sciences (UAMS), a leader in the treatment of myeloma. Dr. Lutsic had told petitioner that he would pursue this option if he were in the same position as Ross. UAMS advised petitioner that it had successfully treated the condition Ross had, but, if he were to have any chance of survival, he would have to start treatment promptly. Ross immediately requested a referral to UAMS, which was not an in-network provider. Respondent told Ross that it needed time to review UAMS’s treatment plan before it took action. However, UAMS stated that it could not provide a treatment plan without first evaluating Ross.

On June 30, 2002, Ross traveled to UAMS for an evaluation. The doctors at UAMS found Ross to be close to death and decided that, without aggressive treatment, he would die very soon. On July 9, 2002, Dr. van Rhee of UAMS provided respondent with an explanation of Ross’s condition and the proposed treatment. Dr. van Rhee informed respondent that, without treatment, Ross had only days to live. Ross’s certificate of coverage included medically necessary services without prior authorization in cases of immediate and unforeseen medical emergency. This coverage was available until it became medically feasible to transfer the covered person to an in-network provider. Nonetheless, respondent informed UAMS that it intended to deny coverage. And, ultimately, it did refuse to pay for any services provided by UAMS.

The treatment administered at UAMS immediately showed marked success. On July 23, 2002, Ross was *180discharged. Ross continued outpatient treatment with UAMS, and he was also readmitted on numerous occasions. On December 23, 2002, Ross was admitted to UAMS for the last time. He remained an inpatient until March 2003. He died on April 6,2003, at 46 years of age.

In regard to Ross’s insurance claims, respondent categorized UAMS’s services into four periods: (1) outpatient facility services commencing on June 30, 2002, (2) inpatient admission from July 8 through July 23, 2002, (3) inpatient admission on August 1 and 2, 2002, and (4) follow-up testing from September 9 to November 17, 2002. On December 18, 2002, Ross initiated an internal appeal with respondent. When respondent denied the appeal, Ross took the second step in the internal appeal process. Respondent upheld its denial. On April 28, 2003, petitioner filed a request for external review with the Office of Financial and Insurance Services (OFIS)4 under the Patient’s Right to Independent Review Act (PRIRA).5

The Commissioner of OFIS6 accepted the request and assigned the case to Permidion, an independent review organization. The IRO submitted its initial decision on May 16, 2003. It concluded that Ross’s evaluation and admission to UAMS was an emergency and that it would have been inappropriate for Ross to have received care elsewhere. The IRO also concluded that the treatment provided was not experimental or investigational.

The commissioner asked the IRO for clarification in July 2003. She asked the IRO to consider four periods of care: (1) the June 30, 2002, outpatient consultation, (2) *181the July 8 to July 23, 2002, inpatient admission, (3) the August 1 to August 2, 2002, inpatient admission, and (4) the September 9 to November 17, 2002, follow-up testing. The IRO recognized that the commissioner had specifically asked it to review “whether each of the ... four episodes meet[s] the criteria for emergency care under the insured’s policy, and at what point, if any, would the patient have been stabilized to make it ‘medically feasible’ to transfer care to an in-network facility.”

The IRO determined that it did not have the information required to offer an opinion about the August 1 and 2 treatment. But the IRO concluded that, with respect to the other periods, the treatment was appropriate. The IRO concluded that the initial consultation was emergency care and that it would have been improper to have transferred Ross to another facility because the “patient required ongoing treatment for a period of time under the supervision of his treating physician and it would have been inappropriate for the patient to receive treatment elsewhere.” Accordingly, the IRO recommended that respondent’s denial be reversed.

The commissioner requested even more review in October 2004. The October 2004 request was almost identical to the July 2003 request, and the IRO responded in kind. Specifically, the IRO reiterated its conclusion that the initial treatment constituted emergency services due to lack of a reasonable alternative at an in-network facility. It also again concluded that Ross “required ongoing treatment for his condition at a center that was familiar with his condition under the supervision of his treating physician.”

The commissioner made a final request for clarification in January 2005. She asked the IRO to again *182consider whether Ross had been in an acute medical state in June 2002 and to clarify when Ross had been stabilized for transfer. The IRO responded by noting that Ross was one week away from death when he arrived at UAMS. The IRO also attached its response to the October 2004 request for review, in which it had concluded that it would have been inappropriate to have transferred Ross to another facility. Ultimately, the IRO again recommended that respondent’s denial of coverage be overturned for the periods at issue.

On March 30, 2005, nearly two years after petitioner requested external review, the commissioner issued her decision. She disregarded the IRO’s conclusions and found that only Ross’s July 8 through July 23, 2002, inpatient admission was covered treatment. She decided that this treatment alone constituted emergency care. Accordingly, the commissioner upheld respondent’s denial of coverage with respect to the remainder of UAMS’s services.

Petitioner filed an appeal in the Wayne Circuit Court. The circuit court reversed the commissioner’s decision and ordered respondent to pay for all the services rendered by UAMS. The circuit court reasoned that, because the commissioner had concluded that the July 8 to July 23 hospitalization constituted emergency services, all the services that UAMS provided were emergency services.

Respondent filed an application for leave to appeal in the Court of Appeals. The Court granted leave to appeal and, in a published opinion, affirmed in part and reversed in part the circuit court’s order.7 The Court of Appeals reversed the decision requiring respondent to pay for services rendered after November 17, 2002, *183because the commissioner had not addressed these services.8 But the Court affirmed with respect to services provided before November 17, 2002.9 It held that the commissioner had erred by discounting the IRO’s medical recommendations and replacing them with her own independent conclusions.10

THE PATIENT’S RIGHT TO INDEPENDENT REVIEW ACT

This case requires us to consider the final decision of an administrative agency and the correct interpretation of a statute. Issues of statutory interpretation are reviewed de novo.11 In cases where no hearing is required, final decisions of administrative agencies are reviewed to determine whether the decision was authorized by law.12 “[A]n agency’s decision that ‘is in violation of statute [or constitution], in excess of the statutory authority or jurisdiction of the agency, made upon unlawful procedures resulting in material prejudice, or is arbitrary and capricious,’ is a decision that is not authorized by law.”13

We have been asked to interpret the Patient’s Right to Independent Review Act. Under PRIRA, when an individual believes that a health-care coverage determination is incorrect, he or she has the right to request an independent review.14 When the commissioner accepts a *184request for external review and the review involves questions of medical necessity or clinical review, the commissioner is required to appoint an IRO to assess the services.15 The IRO is directed to consider the relevant materials and recommend either upholding or reversing the earlier determination.16 Upon receipt of the recommendation, the commissioner is authorized to review the IRO’s recommendation “to ensure that it is not contrary to the terms of coverage under the covered person’s health benefit plan with the health carrier.”17

Accordingly, under PRIRA, if a case accepted for external review involves an issue of medical necessity, an IRO must be appointed to make a recommendation. The commissioner, however, has the power to review the IRO’s recommendation. But that power is not unlimited. The issue here is whether the commissioner exceeds her power when she substitutes her opinion for the conclusion of the IRO on issues that require the exercise of medical judgment.

For many years, this Court has recognized the maxim expressio unius est exclusio alterius.18 This maxim says that the “express mention in a statute of one thing implies the exclusion of other similar things.”19 So well established is this maxim that it can be assumed that legislators are fully aware the courts will utilize it when construing their words. Accordingly, by expressly giving the commissioner the authority to review the recommendation to “ensure that it is not contrary to the *185terms of coverage,” the Legislature implicitly barred the commissioner from reviewing the recommendation for any other purpose. As explained by the Court of Appeals:

[Wlhile the Legislature intended that the OFIS Commissioner would review the IRO’s recommendation for consistency and compliance with the health plan itself, the Legislature did not intend that the OFIS Commissioner would review or reevaluate the IRO reviewer’s specific medical or clinical findings. Instead, the language of PRIRA indicates that the Legislature intended the OFIS Commissioner to defer to the IRO’s recommendation on medical issues that do not implicate the language of the health plan itself.[20]

Thus, the commissioner is specifically authorized to review the IRO’s recommendation to ensure that it is not contrary to the “terms of coverage.” In this respect, the recommendation is not binding. But the commissioner is not allowed to substitute her lay opinion for the medical conclusions of the IRO.21 Therefore, in *186order to determine whether the commissioner exceeded the scope of her powers in this case, it is necessary to examine the “terms of coverage.”

Here, the IRO’s recommendation was consistent with the terms of coverage. Ross’s health-benefit plan covered services in cases of immediate and unforeseen medical emergency until such time as it was medically feasible to transfer him to an in-network provider. The IRO concluded that Ross’s initial treatment was a medical emergency. It also found that Ross “required ongoing treatment for a period of time under the supervision of his treating physician and it would have been inappropriate for [Ross] to receive treatment elsewhere.”

Also, as recognized by the Court of Appeals,

[respondent’s] schedule of benefits provides that respondent will provide treatment for “medical emergencies].” The schedule of benefits also provides coverage for related medically necessary services and related ancillary services. The IRO specifically concluded that Ross’s initial evaluation from June 30, 2002, until July 7, 2002, and his hospitalization of July 8 to 23, 2002, both constituted emergency services.

Further, as recognized by the OFIS Commissioner in her final opinion and order, Michigan law requires a health maintenance organization certificate, which otherwise provides coverage for emergency health services, to

“provide coverage for medically necessary services provided to an insured for the sudden onset of a medical condition that manifests itself by signs and symptoms of *187sufficient severity, including severe pain, such that the absence of immediate medical attention could reasonably be expected to result in serious jeopardy to the individual’s health[,] ... serious impairment to bodily functions, or serious dysfunction of any bodily organ or part. An insurer shall not require a physician to transfer a patient before the physician determines that the patient has reached the point of stabilization. An insurer shall not deny payment for emergency health services up to the point of stabilization provided to an insured under this subsection because of either of the following:

“(a) The final diagnosis.

“(b) Prior authorization was not given by the insurer before emergency health services were provided. [MCL 500.3406k(l).]”

MCL 500.3406k(l) goes on to define “stabilization” as “the point at which no material deterioration of a condition is likely, within reasonable medical probability, to result from or occur during transfer of the patient.” The IRO reviewer in this case specifically concluded that it would not have been medically feasible to transfer Ross at any time before November 17, 2002, because his condition had not been sufficiently stabilized and because his follow-up treatments at the Arkansas facilities were medically necessary.[22]

In summary, the plan covered medical emergencies up to the point where it was medically feasible to transfer the patient to an in-network facility. Michigan law also requires coverage for emergency health services until stabilization. The IRO determined that (1) the initial treatment was a medical emergency, (2) it was not appropriate to transfer Ross to an in-network facility, and (3) Ross was not stabilized before November 17, 2002.23 Therefore, the IRO’s recommendation that respondent be ordered to pay for the services was *188consistent with the terms of coverage.24 For this reason, the commissioner’s decision to ignore the IRO’s recommendation was not authorized by law.

Aside from this inconsistency with the statutory language, an additional reason exists for not allowing the commissioner to substitute her opinion for the *189conclusions of the IRO on issues requiring medical judgment. The commissioner is not a physician.25 Her expertise is banking. By contrast, for an IRO to be approved, the IRO and its physicians must meet certain standards designed to ensure quality and credentials.26 The commissioner is not a doctor, whereas the IRO is made up of very well-qualified doctors. I do not see how the commissioner’s decision to reject the IRO’s medical conclusions in favor of her own uneducated opinion is anything other than arbitrary and capricious. And a decision that is arbitrary and capricious is not authorized by law.27

In this case, the IRO’s physician, who is board-certified in internal medicine, medical oncology, and hematology, concluded that Ross’s initial evaluation constituted emergency services. The physician also concluded that it was not appropriate to transfer Ross to another facility before November 17, 2002. And Ross’s condition had not stabilized to the point where he could have been transferred to an in-network facility. Ross’s health plan covered medical emergencies until it was medically feasible to transfer him to an in-network provider. Michigan law also provides that “[a]n insurer shall not deny payment for emergency health services up to the point of stabilization . .. ,”28 It follows that respondent was required to pay for the services provided through November 17, 2002.29

*190Yet the commissioner found that only the July 8 to July 23, 2002, services were covered. In so doing, she necessarily rejected the medical findings of the IRO in favor of her own uneducated opinion. Not only was there no medical evidence supporting her decision, she is completely unqualified to offer a medical opinion. There could be no clearer example of an arbitrary and capricious decision.30

CONCLUSION

As the Court of Appeals recognized, the commissioner exceeds the scope of her power when she substitutes her opinion for the conclusion of an IRO on issues that require the exercise of medical judgment. This result is not only mandated by the statutory language, it is also necessary to avoid allowing the commissioner, a banker, to make medical decisions. Accordingly, I dissent. I would affirm the judgment of the Court of Appeals.