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:  
MarksD1@michigan.gov  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2021-74 LR  
Title of proposed rule set:  
Public Health Code – General Rules  
3. Purpose for the proposed rules and background:  
The Public Health Code General Rules provides general rules applicable to all professionals regulated  
under Article 15 of the Public Health Code.  
The rule set also establishes the specific dates that a license or registration renewal period begins or  
ends for licenses and registrations regulated by the Public Health Code.  
The department is implementing a new licensing system and the renewal dates for some licenses and  
registrations have changed to the date that the initial license or registration was issued. The  
applicability of the implicit bias training rule will be clarified, and all rules will be reviewed and, if  
needed, revised for clarity.  
4. Summary of proposed rules:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
Amendments will be made to the biennial and triennial license and registration renewal rules, and the  
date of renewal for occupational therapy, physical therapy, respiratory therapy, counseling, and social  
work will be changed to the date of the year when the licensee’s initial license or the registrant’s  
initial registration was issued. Amendments will be made to the rule providing the minimum English  
language standard to clarify that the International English Language Testing System Academic test  
and the Test of English as a Foreign Language Internet-Based Test must be taken within 2 years of the  
date of application for licensure or registration because test scores cannot be verified after 2 years.  
The rule pertaining to the Stark Law will be updated, and the rule pertaining to implicit bias training  
will be revised to clarify that it applies to all applicants, including those for relicensure or  
reregistration.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Flint Journal, November 2, 2021  
The Grand Rapids Press, November 2, 2021  
The Mining Journal, November 5, 2021  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
11/15/2021  
7. Date, time, and location of public hearing:  
11/22/2021 09:00 AM at Ottawa Building, UL Conference Room C-4 , 611 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=1332  
9. List of the name and title of agency representative(s) attending public hearing:  
Dena Marks, Senior Policy Analyst, Boards and Committees Section, Bureau of Professional  
Licensing  
Kerry Przybylo, Manager, Boards and Committees Section, Bureau of Professional Licensing  
Stephanie Wysack, Board support Technician, Boards and Committees Section, Bureau of  
Professional Licensing  
10. Persons submitting comments of support:  
None.  
11. Persons submitting comments of opposition:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
James K. Cantwil, D.D.S. submitted comments opposing the current requirements of R 338.7004.  
Susan Moon submitted comments opposing the current requirements of and proposed changes to R  
338.7004.  
Julie Novak, Michigan State Medical Society, submitted comments opposing the current requirements  
of R 338.7004.  
Milan Sata, D.D.S. submitted comments opposing the current requirements of and proposed changes  
to R 338.7004.  
Niman Shukairy, D.D.S. submitted comments opposing the current requirements of R 338.7004.  
Kimberlydawn Wisdom, M.D., Henry Ford Health System, submitted comments opposing the current  
requirements of R 338.7004.  
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  
None.  
1
None.  
None.  
None.  
13.Date report completed:  
12/14/2021  
MCL 24.242 and 24.245  
;