Michigan Office of Administrative Hearings and Rules  
MOAHR-Rules@michigan.gov  
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:  
MacIntoshW1@michigan.gov  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2021-44 LR  
Title of proposed rule set:  
Medicine - General Rules  
3. Purpose for the proposed rules and background:  
The Medicine – General Rules pertain to definitions, telehealth, prescribing of drugs, training,  
accreditation standards, licensure, educational limited licenses, examination, clinical academic  
limited licenses, relicensure, renewal, and continuing education, for medical doctors.  
Amendment of the rules will take place to supply necessary revisions on definitions, telehealth,  
prescribing of drugs, training, accreditation standards, licensure, educational limited licenses,  
examination, clinical academic limited licenses, relicensure, renewal, and continuing education, for  
medical doctors.  
4. Summary of proposed rules:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
The proposed revisions to the rules clarify the meaning of terms used in the set; update accreditation  
standards; incorporate recent legislative changes that allow licensure by endorsement for individuals  
licensed in another state or a province of Canada, including allowing Part I of the Medical Council of  
Canada Qualifying Examination (MCCQE) to function as a substitute for passing all steps of the  
USMLE; revise the requirements for verification of licenses held in other jurisdictions; clarify that  
foreign applicants for educational limited licenses must pass step 1 and step 2 clinical knowledge  
(CK) of the USMLE; change the three-attempt limitation to the USMLE and follows the 4 attempt  
policy that the Federation of State Medical Boards allows on the USMLE; clarify that applicants for a  
clinical academic license must either show proof of graduation from a medical school that satisfies  
the requirements of R 338.2421(1) or provide a certification from the ECFMG that the applicant  
graduated from a medical school listed in the World Directory of Medical Schools and received  
passing scores on step 1 and step 2 CK of the USMLE; allow proof of licensure in another province  
of Canada as a pathway to relicensure; and remove certain activities for achieving continuing  
education credit, as they no longer apply.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Flint Journal, May 22, 2022  
The Grand Rapids Press, May 19, 2022  
The Mining Journal, May 27, 2022  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
6/15/2022  
7. Date, time, and location of public hearing:  
6/17/2022 09:00 AM at G. Mennen Williams Building Auditorium , 525 W. Ottawa Street, Lansing,  
Michigan  
8. Provide the link the agency used to post the regulatory impact statement and cost-benefit  
analysis on its website:  
https://ARS.apps.lara.state.mi.us/Transaction/RFRTransaction?TransactionID=1302  
9. List of the name and title of agency representative(s) attending public hearing:  
Weston MacIntosh, Departmental Specialist, Bureau of Professional Licensing  
Stephanie Wysack, Departmental Technician, Bureau of Professional Licensing  
10. Persons submitting comments of support:  
Stephanie Ottenwess  
11. Persons submitting comments of opposition:  
Nwonukwuru Amadi  
Bernard Hardy  
Felicia Randolph  
Christopher Salazar-Fields  
Eman Talia  
12. Persons submitting other comments:  
None.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
13. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
Name &  
Organization public hearing  
Comments made at Written  
Agency Rationale Rule number  
for Rule Change & citation  
and Description changed  
of Change(s)  
Comments  
Made  
1
Eman Talia  
“I am emailing  
you to give my  
The Board of  
Medicine approves (d), R  
R 338.2423  
comments about the requested  
changing the change from a  
338.2425(d),  
and R  
requirement for minimum  
full licensing for requirement of  
physician to have two years of  
MD to be allowed postgraduate  
338.2427(1)  
(e)  
to obtain full  
licensing after  
completing one  
year of residency  
instead of two  
years. Doing so  
will have it fair  
and equal to the  
fellow physician  
who have a DO  
degree. I urge the  
board of  
clinical training to  
one year.  
medicine to look  
into this and  
hopefully make  
the right decision  
to make DO and  
MD have the  
same  
requirements  
especially now  
they both have  
merged together  
and work side to  
side in  
residencies,  
hospitals and  
clinics.”  
14.Date report completed:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
9/21/2022  
MCL 24.242 and 24.245  
;