Notwithstanding the rulemaking provisions of the Administrative Procedure Act (Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code), the department may implement this chapter or Section 1418.8 of the Health and Safety Code, in whole or in part, by means of a program memo or other similar instruction.
Ca. Welf. and Inst. Code § 9285