Michigan Office of Administrative Hearings and Rules  
AGENCY REPORT TO THE  
JOINT COMMITEE ON ADMNINISTRATIVE RULES (JCAR)  
1. Agency Information  
Agency name:  
Licensing and Regulatory Affairs  
Division/Bureau/Office:  
Bureau of Community and Health Systems  
Name of person completing this form:  
Tammy Bagby  
Phone number of person completing this form:  
517-243-9351  
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:  
2021-90 LR  
Title of proposed rule set:  
Substance Use Disorder Service Programs  
3. Purpose for the proposed rules and background:  
The Substance Use Disorder Programs Administrative Rules provide for the regulation of substance  
use disorder programs. Additional requirements have been identified that need further clarifications  
or corrections that were not addressed previously.  
4. Summary of proposed rules:  
The proposed SUD administrative rules add regulations for branch offices, allows for mobile units to  
be licensed under a parent location with specific criteria, require facility protocol for offering  
naloxone kits, expand in-service education categories, deregulate screening and assessment, referral,  
follow up services (SARF), expand the types of counselors that can provide outpatient counseling and  
residential program counseling, remove the Medication Assisted Treatment (MAT) subcategories of  
MAT-Buprenorphine and MAT-Naltrexone but maintain the MAT subcategory of Methadone and the  
requisite program requirements, and adds clinically managed and medically monitored subcategories  
for withdrawal management services (detoxification).  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
8/04/2022 Marquette Mining Journal  
8/09/2022 Flint Journal  
8/10/2022 Grand Rapids Press  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
8/15/2022  
7. Date, time, and location of public hearing:  
8/31/2022 09:00 AM at Williams Building, 1st Floor Auditorium , 525 West Ottawa Street, Lansing,  
MI 48933  
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) who attended the public hearing:  
Larry Horvath, Director of the Bureau of Community and Health Systems  
Matt Jordan, Manager of the Non- Long-Term Care State Licensing Section  
Jim Hoyt, Regulation Officer, Non-Long-Term Care State Licensing Section  
Kelly Moore, Analyst, Non-Long-Term Care State Licensing Section  
10. Persons submitting comments of support:  
Julie Rwan, Vital Strategies Overdose Prevention Program  
Renee Smiddy, Michigan Health & Hospital Association  
Dr. Cara Poland, Michigan Society of Addiction Medicine  
11. Persons submitting comments of opposition:  
No comments of opposition.  
12. Persons submitting other comments:  
Jessica Moreno  
Sam Price, SUD Sub-committee of Provider Alliance  
Sam Price, Ten16 Recovery Network  
Greg Toutant, Great Lakes Recovery Centers  
Douglas Apple, Ascension Michigan  
Paula Nelson, Sacred Heart  
Kanzoni Asabigi, Detroit Recovery Project, Inc.  
Emmy Ellis, Arbor Circle  
Colleen Lane, BHSH System, Spectrum Health West Michigan  
David Blankenship, MATOD/Victory Clinic  
Peter Bucci, Harbor Hill  
Lucila Ryder, Star Center/MATOD  
Deidre Goldsmith, Therapeutics  
Matthew Ryder, Star Center  
Dayna Shock, Mid-Michigan Community Health Services  
Senator McBroom, Senator Bumstead, Representative Luke Meerman  
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 3  
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
14.Date report completed:  
5/3/2023  
MCL 24.242 and 24.245  
;