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:  
Andria Ditschman  
Phone number of person completing this form:  
517-290-3361  
E-mail of person completing this form:  
DitschmanA@michigan.gov  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2021-51 LR  
Title of proposed rule set:  
Pharmacy - Pharmacist Continuing Education  
3. Purpose for the proposed rules and background:  
The purpose of the Pharmacy – Pharmacist Continuing Education rules is to regulate the license  
renewal process and continuing education requirements for pharmacists. The proposed rules will  
clarify the continuing education requirements, including the requirement for 1 hour of continuing  
education in pharmacy ethics and jurisprudence.  
4. Summary of proposed rules:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
The proposed rules include the following modifications: licensees will be able to submit and earn  
continuing education for renewal, during the 60-day grace period, up to the date the licensee applies  
for renewal; licensees may earn 1 hour in ethics and pharmacy law by completing more than one  
course; licensees may earn 10 hours of live courses by attending in-person or virtual continuing  
education, as long as there is an opportunity for direct interaction between faculty and participants;  
licensees may submit ACPE courses that are designated as live towards their 10 hours of required live  
courses; licensees may receive continuing education credit and training credit during the same  
renewal cycle for human trafficking training, opioid and controlled substances awareness training,  
and implicit bias training; applications for continuing education courses and programs will be  
submitted 70 days before the course or program is conducted; a continuing education course may be  
relevant to health care services, pharmacy operations, or advancement of pharmacy education;  
applicants for continuing education approval will be required to submit less support documentation;  
programs and courses may be offered more frequently as additional dates during a term of approval  
do not need review; the only modifications that require review during the approved term are  
modifications to the title, number of continuing education hours, or learning objectives; and  
continuing education credit will be given for attendance at a full board meeting, disciplinary meeting,  
and rules committee work group meeting.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Flint Journal: September 15, 2022  
The Grand Rapids Press: September 15, 2022  
The Mining Journal: October 5, 2022  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
10/15/2022  
7. Date, time, and location of public hearing:  
10/24/2022 09:00 AM at Location: G. Mennen Williams Building Auditorium 525 W. Ottawa Street,  
Lansing, Michigan , 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=1309  
9. List of the name and title of agency representative(s) who attended the public hearing:  
Andria Ditschman, Departmental Specialist, Bureau of Professional Licensing  
Weston MacIntosh, Departmental Specialist, Bureau of Professional Licensing  
10. Persons submitting comments of support:  
No persons submitted comments of support.  
11. Persons submitting comments of opposition:  
Rose Baran and Charlie Mollien submitted comments in opposition.  
12. Persons submitting other comments:  
Rose Baran and Charlie Mollien submitted comments with suggested changes to the rules.  
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:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
Name &  
Organization public hearing  
Comments made at Written  
Agency Rationale Rule number  
for Rule Change & citation  
and Description changed  
of Change(s)  
Comments  
Made  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 5  
1
Rose Baran  
Rule 338.3044(h) The Board agrees R 338.3044  
appears to allow a with the comment (h)  
licensee  
that the rule  
presenting a  
continuing  
education  
should be  
modified to limit a  
licensee to only  
receive 2 hours of  
program under  
(h) at 5 different continuing  
times in a  
education credit  
renewal period  
and obtain 10  
hours of  
continuing  
education for  
presenting the  
for presenting a  
continuing  
education program  
approved by the  
board under R  
338.3043 or  
same continuing subdivision (a) of  
education  
program. This  
this rule that is not  
a part of the  
would appear to licensee’s regular  
conflict with Rule job description  
338.3042(2) “An once during a  
applicant for  
license renewal  
may not earn  
continuing  
license cycle.  
education credit  
for a program or  
activity that is  
identical to a  
program or  
activity an  
applicant has  
already earned  
credit for during  
that renewal  
period.”  
However, if that  
is the intent, to  
allow up to 10  
hours for  
presenting the  
same program in  
the same renewal  
period than no  
change is needed.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 6  
14.Date report completed:  
5/2/2023  
MCL 24.242 and 24.245  
;