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:  
Dena Marks  
Phone number of person completing this form:  
517-335-3679  
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:  
2020-16 LR  
Title of proposed rule set:  
Athletic Training - General Rules  
3. Purpose for the proposed rules and background:  
The athletic training general rules pertain to the licensure, relicensure, and license renewal for athletic  
trainers.  
The rules will be amended to provide clarity pertaining to education, training, testing requirements,  
licensure, relicensure, continuing education, renewal and telehealth services.  
4. Summary of proposed rules:  
The proposed rules will add a definition of emergency cardiac care; add a telehealth rule; remove the  
requirements of first aid, cardiopulmonary resuscitation, and automated external defibrillator training  
and add emergency cardiac care training for licensure, relicensure, and renewal; identify approved  
providers for emergency cardiac care training; remove the minimum English language rule; and  
clarify continuing education rules.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
The Flint Journal, November 5, 2020  
The Grand Rapids Press, November 5, 2020  
The Mining Journal, November 6, 2020  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
11/15/2020  
7. Date, time, and location of public hearing:  
11/23/2020 09:00 AM at This meeting will be held virtually via Zoom to receive public comments  
while complying with statutorily required measures designed to help prevent the spread of  
Coronavirus Disease 2019 (COVID 19). , https://us02web.zoom.us/j/89155551746?  
pwd=MTJLN1JZQW5qalFWcVVqenZPYmtLdz09, Password for video connection: 438090; Phone  
number: 888-684-8852, Conference Code for audio connection: 335451  
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:  
Kimberly Catlin, Board Support Technician, Boards and Committees Section, Bureau of Professional  
Licensing  
Andria Ditschman, Senior Policy Analyst, Boards and Committees Section, Bureau of Professional  
Licensing  
Weston McIntosh, Senior Policy Analyst, Boards and Committees Section, Bureau of Professional  
Licensing  
Kerry Przybylo, Manager, Boards and Committees Section, Bureau of Professional Licensing  
10. Persons submitting comments of support:  
Shannon Fleming, Board of Certification for the Athletic Trainer  
Kelli Wilkins, Board of Certification for the Athletic Trainer  
11. Persons submitting comments of opposition:  
None.  
12. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
Name &  
Comments made at Written  
Agency Rationale Rule number  
Organization public hearing  
Comments  
for change  
& citation  
changed  
1
Kelli Wilkins,  
Board of  
The commenter The board and  
stated that most department agreed (c)  
R 338.1309  
Certification for  
the Athletic  
Trainer  
emergency  
that the rule  
should be  
amended to  
require the  
applicant to hold a  
current emergency  
cardiac care  
cardiac care  
certifications  
expire after 2  
years and  
suggested that  
instead of  
requiring the  
training within 3  
years, that the  
requirement be  
that the applicant  
hold a current  
emergency  
certification.  
cardiac care  
certification.  
2
Kelli Wilkins,  
Board of  
The commenter The board and  
stated that most department agreed (1)(c)  
R 338.1317  
Certification for  
the Athletic  
Trainer  
emergency  
that the rule  
should be  
amended to  
require the  
applicant to hold a  
current emergency  
cardiac care  
cardiac care  
certifications  
expire after 2  
years and  
suggested that  
instead of  
requiring the  
training within 3  
years, that the  
requirement be  
that the applicant  
hold a current  
emergency  
certification.  
cardiac care  
certification.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
3
Kelli Wilkins,  
Board of  
The commenter The board and  
stated that most department agreed (1)(d)  
R 338.1321  
Certification for  
the Athletic  
Trainer  
emergency  
that the rule  
should be  
amended to  
require the  
applicant to hold a  
current emergency  
cardiac care  
cardiac care  
certifications  
expire after 2  
years and  
suggested that  
instead of  
requiring the  
training within 3  
years, that the  
requirement be  
that the applicant  
hold a current  
emergency  
certification.  
cardiac care  
certification.  
4
Kelli Wilkins,  
Board of  
The commenter The board and  
stated that most department agreed (1)(e)  
R 338.1345  
Certification for  
the Athletic  
Trainer  
emergency  
that the rule  
should be  
amended to  
require the  
applicant to hold a  
current emergency  
cardiac care  
R 338.1345  
(2)(e)  
cardiac care  
certifications  
expire after 2  
years and  
suggested that  
instead of  
requiring the  
training within 3  
years, that the  
requirement be  
that the applicant  
hold a current  
emergency  
certification.  
cardiac care  
certification.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 5  
It is presumed  
5
Kelli Wilkins,  
Board of  
Certification for  
the Athletic  
Trainer  
The board and  
R 338.1349  
that Ms. Wilkins department agreed (1)(a)  
intended for the that an applicant  
cardiac care  
certification  
requirement to  
must hold a  
current emergency  
cardiac care  
consistently apply certification when  
to all applicants applying for  
regardless of how license renewal,  
the license is  
obtained and  
merely neglected  
to comment  
specifically on  
rule 49.  
relicensure, or  
licensure.  
6
Kelli Wilkins,  
Board of  
Certification for  
the Athletic  
Trainer  
The commenter The board and the R 338.1355  
stated that the  
guideline  
department agreed (2)  
that the American  
Heart Association  
Guidelines  
referenced was  
updated in  
October 2020.  
published in  
October 2020  
should be adopted  
by reference.  
7
Shannon  
The commenter The board and the R 338.1357  
Fleming, Board  
of Certification  
for the Athletic  
Trainer  
stated that the  
“Practice  
Analysis, 8th  
Edition” would  
be effective in  
January 2024.  
department agreed (3)  
that the most  
recent standards  
should be adopted  
by reference.  
13.Date report completed:  
3/4/2021  
MCL 24.242 and 24.245  
;