B. Are the rules mandated by any applicable constitutional or statutory provision? If so, please
MCL 333.18107(1)(b) requires the department in consultation with the board to promulgate rules
to establish standards to approve qualified programs under Part 181 (Counselors) of the Public
Health Code for licensure of professional counselors. MCL 333.18111(1)(b) requires the
department in consultation with the board to establish standards to approve qualified programs
under Part 181 (Counselors) of the Public Health Code for licensure of limited licensed
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.
The rules incorporate the changes that came about as a result of 2019 PA 96, which amended MCL
333.18101, MCL 333.18107, MCL 333.18111, and MCL 333.18115, and added MCL 333.18106,
MCL 333.18112, MCL 333.18114, and MCL 333.18116, and became effective January 27, 2020.
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 2016. 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.