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Sections 2233, 20910 and 20975 of 1978 PA 368, MCL 333.2233, 333.20910, 333.20975; and
Executive Reorganization Order 2015-01, MCL 400.227.
B. Are the rules mandated by any applicable constitutional or statutory provision? If so, please
explain.
MCL 333.20910 provides that the Department promulgate rules to establish the requirements for
licensure of life support agencies, vehicles, and individuals licensed under this part to provide
emergency medical services and other rules necessary to implement the legislation and to
promulgate rules to establish and maintain standards for and regulate the use of descriptive words,
phrases, symbols, or emblems that represent or denote that an ambulance operation, non-transport
prehospital life support operation, or medical first response service is or may be provided.
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.
There are no known conflicts with state or federal government rules or regulations involving the
proposed revisions.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
Yes, revisions will have to be made to forms and policies as a result of changes to the rules,
including, but not limited to: EMS education applications, out of state license verification form,
reciprocity application, continuing education record form, and FAQs.
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed
for the current year?
Yes, the rules are listed on the department's annual regulatory plan 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?
Full 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 rule revisions will bring the rules in line with current standards in the EMS System. They do
not exceed similar regulations, compliance requirements, or other standards adopted at the state,
regional, or federal level.
14. Do the rules incorporate the recommendations received from the public regarding any
complaints or comments regarding the rules? If yes, please explain.
Yes. This rule set has gone through an extensive and transparent review process over the past two
years with the State appointed Emergency Medical Services Coordination Committee (EMSCC)
which consists of stakeholders from all levels of the EMS system and associated professional
organizations, and their various subcommittees. The EMSCC and subcommittees consist of a
broad range of stakeholders within the EMS System. The full EMSCC was provided with the final
sets of recommended rules at the July 2020 meeting. The EMSCC unanimously voted to approve
moving these rules forward as written.
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.
MCL 24.239