Michigan Office of Administrative Hearings and Rules  
611 W. Ottawa Street  
Lansing, MI 48909  
Phone: 517-335-8658 Fax: 517-335-9512  
AGENCY REPORT TO THE  
JOINT COMMITEE ON ADMNINISTRATIVE RULES (JCAR)  
1. Agency Information  
Agency name:  
Licensing and Regulatory Affairs  
Division/Bureau/Office:  
Bureau of Professional Licensing  
Name of person completing this form:  
Weston MacIntosh  
Phone number of person completing this form:  
517-241.9269  
E-mail of person completing this form:  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2019-84 LR  
Title of proposed rule set:  
Chiropractic – General Rules  
3. Purpose for the proposed rules and background:  
The general purpose of these rules is to provide educational, licensure, and continuing education  
requirements for this profession. The proposed updates include typographical revisions, as well as  
substantive changes to continuing education requirements.  
4. Summary of proposed rules:  
The proposed rules will clarify terms used in the rule set, adopt by reference accreditation standards  
for chiropractic educational programs; include a requirement that acceptable continuing education  
must be approved or offered by the Michigan Association of Chiropractors (MAC), with the  
exception of a course or courses related to the practice of chiropractic which are offered on campus  
by an approved chiropractic school or initial presentation of a continuing education program related  
to the practice of chiropractic to a state, regional, national, or international organization; and rescind  
the rule allowing a proposed sponsor of continuing education to seek approval from the board to offer  
continuing education courses since proposed continuing education providers will now have to seek  
approval from the MAC.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Flint Journal, January 5, 2021  
The Grand Rapids Press, January 5, 2021  
The Mining Journal, January 5, 2021  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
1/15/2021  
7. Date, time, and location of public hearing:  
1/19/2021 01:00 PM at The public hearing will be held virtually via Zoom to receive public  
comments while complying with measures designed to help prevent the spread of Coronavirus  
pwd=R0ZmOGhNUmw5Z24xZ3g4a2UveGx4dz09 Password for video connection: 759646 Phone  
number: 877-336-1831 Conference Code for audio connection: 486917  
8. Provide the link the agency used to post the regulatory impact statement and cost-benefit  
analysis on its website:  
9. List of the name and title of agency representative(s) attending public hearing:  
Weston MacIntosh, Senior Policy Analyst, Bureau of Professional Licensing  
Kerry Przybylo, Manager, Boards and Committees, Bureau of Professional Licensing,  
Andria Ditschman, Senior Policy Analyst, Bureau of professional Licensing  
Stephanie Wysack, Departmental Technician, Bureau of Professional Licensing  
10. Persons submitting comments of support:  
Michigan Association of Chiropractors/Kristine Dowell  
Eric DiMartino  
Tim Gaughan  
Lisa Olszewski  
Robyn Peake  
Donald Reno  
Lewis Squires  
11. Persons submitting comments of opposition:  
Garth Aamodt  
James Agrusa  
Anna Albers  
Ted Arkfeld  
Brian Arnold  
Donald Atkins  
David Batton  
Janet Bednarz  
Linda Berry  
Beverly Blas  
David Bogart  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
Kyra Bolden  
Martin Brown  
Steven Brown  
Riachard Burke  
Darlene Button  
Jessica Cohen  
Mark Cohen  
Peter Costantino  
Kelly Cromarty  
Thomas Czarnecki  
James Darrach  
Robert Ducharme  
Barbara Dumbrigue  
William Easton  
David Estefan  
Robert Fenell  
Kris Fetterman  
Stacey Francis  
Michael Gasiewicz  
Thomas Gerou  
Rita Goines-McClain  
Denise Goodwin  
Timothy Grondin  
Joel Hack  
Daniel Halaberda  
Robert Hallett  
Royann Hassinger  
Sharon Havis  
Kirk Hilborn  
Chelsea Jaques  
Alexander Jeffrey  
Karl Johnson  
Richard Johnson  
Larry Kaplan  
Robert Korn  
Charmaine Lanjopoulos  
Raymond Lanjopoulos  
Kenneth Large  
Richard Larned  
Natalie Lawrin  
Lawrence Lee  
Gary Loiselle  
Macomb County Chiropractic Association/Martin Brown  
Robert Manela  
Larry Manteuffel  
Mark Manteuffel  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
Ron Manteuffel  
Elaine Margolis  
Gregory McFarland  
Allen Mehler  
Jean Mikula  
Richard Mirowski  
Dale Morgan  
Jennifer Morgan  
Reena Pathak  
Theresa Pigott  
Regina Roberts  
Martin Rudick  
Jeremy Rudkin  
Paula Ruffin  
Craig Shaeffer  
Martha Schneider  
Kenneth Schultz  
Brian Seefeldt  
Bruce Serven  
Ronda Shallow  
Nate Shannon  
Gary Shoemaker  
Craig Stephenson  
Larry Sutherland  
Stephen Thompson  
Jaime Vande Veegaete  
Arthur VanHoutteghem  
William Vecchioni  
Lawrence Weiss  
Leighia Wells  
Stephanie Witte-Mason  
Richard Woolman  
Mark Wrobel  
Kim Zell  
12. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
Name &  
Comments made at Written  
Agency Rationale Rule number  
Organization public hearing  
Comments  
for change  
& citation  
changed  
R 338.12036  
(2)  
1
Michigan  
Prior to the re-  
write of the Rules agrees with the  
that was  
completed in  
2019, all  
The Department  
Association of  
Chiropractors/K  
ristine Dowell  
requested change,  
as it would ease  
the burden for  
Eric DiMartino  
applicants for  
those applicants  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 5  
Tim Gaughan  
relicensure were seeking  
Lisa Olszewski  
required to satisfy relicensure.  
EITHER of the  
following:  
• 45 hours of  
continuing  
education in the  
preceding three  
years, with all the  
outlined  
requirements, or  
• Have been  
licensed as a  
chiropractor in  
another state of  
the United States  
during the three-  
year period  
immediately  
preceding the  
application for  
relicensure.  
This was changed  
in the most recent  
re-write of the  
Rules. Now,  
doctors seeking  
Michigan  
relicensure  
after their license  
has been lapsed  
for three years or  
more are required  
to have the 45  
hours of  
continuing  
education AND  
either:  
• Have been  
licensed in  
another state for  
the three years  
preceding the  
application  
• Have passed the  
National Board of  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 6  
Chiropractic  
Examiners  
Special Purposes  
Examination for  
Chiropractic  
(SPEC)  
We feel that this  
is overly  
burdensome on  
doctors seeking  
relicensure, and  
that if a doctor  
has been  
continuously  
licensed in  
another state for  
the three years  
immediately  
preceding  
application for  
relicensure,  
has been  
following that  
state’s continuing  
education rules,  
and has no  
sanction against  
his or her license  
in that other state,  
they are  
presumed to have  
the skills to  
practice  
chiropractic in  
the state of  
Michigan.  
We also do not  
believe that  
passing the  
NBCE SPEC  
examination is  
necessary to  
establish the  
presumption of  
having the skills  
and ability to  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 7  
practice  
chiropractic in  
the state of  
Michigan. It is  
also important to  
note that if a  
doctor had never  
been licensed in  
Michigan at all,  
the process to get  
a license is much  
less cumbersome,  
but because  
someone may  
have gotten a  
Michigan license  
right out of  
school but then  
moved to another  
state to practice,  
and now wants to  
come back, they  
must follow a  
completely  
different and  
more stringent set  
of rules.  
We would like to  
see the rule re-  
written to be  
more in line with  
the Rule prior to  
the previous re-  
write,  
in which  
chiropractors  
have access to  
two methods in  
which to gain re-  
licensure:  
1. Continuing  
Education; or,  
2. Having been  
continuously  
licensed in  
another state for  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 8  
the immediate  
past three years  
We believe that  
changing the  
relicensure rule in  
this way would  
fulfill the Board’s  
duty to protect  
both the general  
public and the  
profession itself,  
while easing a  
burdensome  
requirement on  
applicants for  
relicensure whose  
license has been  
expired for three  
years or more.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 9  
2
Ted Arkfeld  
There are other  
more fair and  
reasonable  
The Department  
agrees that the  
board should  
R 338.12041  
(2) and R  
338.12042  
options that  
should be  
continue to receive  
and review  
acceptable to the proposed  
Board: All C.E. continuing  
provider  
education  
organizations  
providers under R  
should apply and 338.12041(2) and  
be reviewed by R 338.12042, and  
the state Board… that continuing  
Chiropractic  
College C.E.  
education  
programs offered  
courses should be by a chiropractic  
automatically school (regardless  
approved whether of modality)  
classes are  
offered On-  
approved under R  
338.12021 should  
campus OR Off- be considered  
campus. The  
pandemic has  
shown us that  
educational  
approved, as the  
above would give  
licensees many  
different  
diversity is valid opportunities to  
and useful. There complete the  
is no reason that continuing  
an identical  
education  
course should  
requirements  
only be approved while ensuring  
On-campus,  
forcing  
quality continuing  
educational  
Michigan’s  
Chiropractors to  
travel at added  
risk and  
programs.  
expense.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 10  
3
Macomb  
County  
Chiropractic  
Association  
Initial  
The Department  
agrees that the  
continuing  
education  
programs that  
R 338.12041  
(2)  
presentation of  
C.E. courses  
should not be  
restricted to  
A.C.A., I.C.A. or count as approved  
M.A.C. for an attendee  
presenters as ALL should also apply  
presenters of  
approved  
to those same  
programs in which  
programs put in the licensee was a  
time and effort to presenter.  
produce their  
lectures and  
should be entitled  
to the 2 hours  
C.E. credit for  
each hour of  
presentation.  
13.Date report completed:  
10/18/2021  
MCL 24.242 and 24.245