Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
AGENCY REPORT TO THE  
JOINT COMMITTEE ON ADMINISTRATIVE RULES (JCAR)  
AGENCY INFORMATION:  
Agency name:  
Licensing and Regulatory Affairs  
Division/Bureau/Office:  
Bureau of Professional Licensing  
Name of person completing this form:  
Steven Sundeen  
Phone number of person completing this form:  
517-241-4064  
Email of person completing this form:  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
RULE SET INFORMATION:  
MOAHR assigned rule set number:  
2024-25 LR  
Title of the proposed rule set:  
Occupational Therapists - General Rules  
1. Purpose of the proposed rules and background:  
The purpose of the Board of Occupational Therapist – General Rules is to regulate the prelicensure education,  
licensure, licensure renewal, relicensure, and continuing education for occupational therapists and occupational  
therapy assistants.  
The proposed rules will be reviewed and amended as needed concerning the requirements for licensure. Additionally,  
continuing education rules will be reviewed and revised as needed to reflect the activities and continuing education  
providers and activities approved by the board. All rules will be reviewed and revised as needed to update rules and  
provide greater clarity.  
2. Summary of the proposed rules:  
The proposed revisions to the rules include amending definitions and the training standards for identifying victims of  
human trafficking for clarity, rescinding rules that repeat statutory provisions, rescinding rules and relocating them to  
comply with current drafting requirements and for organization and clarity, updating educational program accreditation  
standards, amending and clarifying which educational programs are approved for licensure, removing the  
jurisprudence examination requirement for all license types, amending the delegation and supervision rules for clarity,  
and clarifying which activities are approved by the board for accumulating the continuing education required for  
license renewal, and clarifying that a licensee who completes implicit bias training under R 338.7004 may also use  
that training toward fulfillment of continuing education requirements.  
3. List names of newspapers in which the notice of public hearing was published and publication  
dates:  
The Escanaba Daily Press, July 5, 2025  
The Flint Journal, June 6, 2025  
The Grand Rapids Press, June 10, 2025  
MCL 24.242 and 24.245  
Agency Report to JCAR -Page 2  
4. Date of publication of the proposed rules and notice of public hearing in the Michigan Register:  
7/15/2025  
5. Date, time, and location of the public hearing:  
7/25/2025 09:00 AM at UL-5, 611 W. Ottawa Street, Lansing, Michigan  
6. Provide the link the agency used to post the regulatory impact statement and cost-benefit analysis  
on its website:  
7. List of the name and title of agency representative(s) who attended the public hearing:  
Weston MacIntosh, Departmental Specialist, Bureau of Professional Licensing  
Kerry Przybylo, Manager, Bureau of Professional Licensing  
Steven Sundeen, Departmental Specialist, Bureau of Professional Licensing  
8. Persons submitting comments of support:  
None.  
9. Persons submitting comments of opposition:  
None  
10. Persons submitting other comments:  
Teresa Brininger, PhD, MBA, OT, representing ACOTE  
Bethany Burge, MS, OTR/L representing MIOTA  
Denise Hoffman, OTD, OTRL, BCP, FMIOTA, FAOTA, representing MIOTA  
Cathleen Johnson, OTD, OTR/L representing MIOTA  
Kristen Neville, Representing AOTA  
11. Identify any changes made to the proposed rules based on comments received during the public  
comment period:  
None.  
12. Date report completed:  
5/7/2026  
MCL 24.242 and 24.245  
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