Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
611 W. Ottawa Street  
Lansing, MI 48909  
Phone: 517-335-8658 Fax: 517-335-9512  
REQUEST FOR RULEMAKING (RFR)  
1. Department:  
Health and Human Services  
2. Bureau:  
Population Health and Community Services  
3. Promulgation type:  
Full Process  
4. Title of proposed rule set:  
EMS Personnel Licensing and Education  
5. Rule numbers or rule set range of numbers:  
R 325.22301 through 325.22345  
6. Estimated time frame:  
6 months  
Name of person filling out RFR:  
Mary Brennan  
E-mail of person filling out RFR:  
BrennanM@michigan.gov  
Phone number of person filling out RFR:  
517-284-4850  
Address of person filling out RFR:  
333 S. Grand Avenue, 5th Floor  
Lansing, MI 48909  
7. Describe the general purpose of these rules, including any problems the changes are intended  
to address.  
The rules address the licensing requirements and education standards for emergency medical  
services (EMS) personnel. Since the introduction of these rules in 2004, there has not been a  
review of the rules to keep up with the changes that have occurred within the EMS system since  
that time. There were redundancies in some of the rules, and other advances in evidence-based  
EMS practice that have been implemented as a result of the previous rules set that needed  
additional clarification or modifications, for example the changes in technology that have occurred  
since 2004. The titles of personnel licenses were adjusted to meet national scope of practice  
language. The new rules clarify the complaint and compliance processes for the EMS system. We  
also aligned continuing education requirements with the National Registry of Emergency Medical  
Technician (NREMT) process.  
8. Please cite the specific promulgation authority for the rules (i.e. department director,  
commission, board, etc.).  
Director/State emergency medical services coordination committee -MCL 333.20910  
A. Please list all applicable statutory references (MCLs, Executive Orders, etc.).  
MCL 24.239  
RFR-Page 2  
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  
RFR-Page 3  
These Rules have not been revised since their introduction in 2004. Since that time, there have  
been many advancements in technology, science, and economic conditions that warrant a fresh  
look at the regulations for the EMS System in Michigan. In 2016 EMS personnel licensure was  
automated to an online licensing system.  
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?  
There is a continued need for the rules. However, as the rules were carefully reviewed, it was  
discovered that some of the rules were redundant with the only language being different was the  
level of service. The various committees that worked on these rules were able to consolidate  
language that was repetitive into one comprehensive rule in many places. In addition, if the statute  
was particularly clear and definitive and then repeated word for word in a rule, these rules were  
deleted. Previous rule set had reference to specific dated standards. References to specific dated  
versions of standards were removed.  
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.  
No  
MCL 24.239  
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