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FW: Attention: Departmental Specialist. Implicit Bias Public Health Code Updates
Friday, July 15, 2022 10:27:58 AM
From: Breijak, Duane <dbreijak.naswmi@socialworkers.org>
Sent: Friday, July 15, 2022 10:23 AM
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>
Subject: Attention: Departmental Specialist. Implicit Bias Public Health Code Updates
Attention: Departmental Specialist
On behalf of the National Association of Social Workers - Michigan Chapter and our 5,000 + social
work members across the state, we would like to submit a proposed change to the Public Health
Code, specifically in regards to the implicit bias training requirements.
We are requesting that the language is updated to reflect that if a licensee takes an approved
continuing education course on implicit bias AND that training also satisfies the implicit bias training
requirements, the licensee could use that one training to satisfy both the CE and implicit bias
licensure requirements.
As currently written, this creates a new standard and a first-of-its-kind requirement that does not
allow licensees to count continuing education credit for a required relevant training. This
wording/rule is already causing a great deal of confusion amongst licensed professionals, schools of
social work, and organizations hosting continuing education programming.
This would fall specifically under R 338.7004, section 2.
Current wording:
Beginning June 1, 2022, and for every renewal cycle thereafter, in addition to completing any
continuing education required for renewal, reregistration, or relicensure, an applicant for license or
registration renewal, reregistration, or relicensure under article 15 of the code, MCL 333.16101 to
333.18838, except those licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall
have completed a minimum of 1 hour of implicit bias training for each year of the applicant’s license
or registration cycle.
Suggested wording:
Beginning June 1, 2022, and for every renewal cycle thereafter, in addition to completing any
continuing education required for renewal, reregistration, or relicensure, an applicant for license or
registration renewal, reregistration, or relicensure under article 15 of the code, MCL 333.16101 to
333.18838, except those licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall