Under MCL 333.18223, the department, in consultation with the board, shall promulgate rules on
the requirements for licensure. Under MCL 333.18233, the board shall promulgate rules requiring
continuing education, including continuing education specifically in the area of pain and symptom
9. Please describe the extent to which the rules conflict with or duplicate similar rules,
compliance requirements, or other standards adopted at the state, regional, or federal level.
The proposed rules do not duplicate or conflict with other federal or state regulations.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
No guideline, manual, handbook, instructional bulletin, form with instructions, or operational
memo covers the subject matter of the rules.
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed
for the current year?
12. Will the proposed rules be promulgated under Section 44 of the Administrative Procedures
Act, 1969 PA 306, MCL 24.244, or under the full rulemaking process?
13. Please describe the extent to which the rules exceed similar regulations, compliance
requirements, or other standards adopted at the state, regional, or federal level.
The proposed rules do not exceed other federal or state regulations.
14. Do the rules incorporate the recommendations received from the public regarding any
complaints or comments regarding the rules? If yes, please explain.
15. If amending an existing rule set, please provide the date of the last evaluation of the rules
and the degree, if any, to which technology, economic conditions, or other factors have changed
the regulatory activity covered by the rules since the last evaluation.
Amendment of the rules last took place in 2019. No technological factors, economic conditions,
or other factors make amendment of the rules necessary.
16. Are there any changes or developments since implementation that demonstrate there is no
continued need for the rules, or any portion of the rules?
17. Is there an applicable decision record (as defined in MCL 24.203(6) and required by MCL
24.239(2))? If so, please attach the decision record.