Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
MOAHR-Rules@michigan.gov  
REQUEST FOR RULEMAKING (RFR)  
1. Department:  
Health and Human Services  
2. Bureau:  
Bureau Of Epidemiology And Population Health  
3. Promulgation type:  
Full Process  
4. Title of proposed rule set:  
EMS Life Support Agencies and Medical Control  
5. Rule numbers or rule set range of numbers:  
R 325.22101 - R 325.22218  
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:  
517-242-9634  
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 for emergency medical services (EMS) life support  
agencies and medical control authorities (MCA). Since the introduction of these rules in 2004,  
there has not been a complete 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 last change to this rule set was in 2018 and it was  
R 325.22181. In addition, the Certificate of Need for air ambulance services Section 22215 of Act  
No. 368 of the Public acts of 1978 as amended and sections 7 and 8 of Act No. 306 of the Public  
Acts of 1969, as amended, MCL 333.22215, 24.207 and 24.208 are being discontinued due to the  
Airline Deregulation Act. There is no longer the requirement for the Certificate of Need for air  
ambulances. However, this necessitates ensuring that appropriate portions of those statutes that  
address medical care requirements for air ambulances are contained in these proposed rules.  
8. Please cite the specific promulgation authority for the rules (i.e. department director,  
commission, board, etc.).  
The Director of the Department of Health and Human Services.  
A. Please list all applicable statutory references (MCLs, Executive Orders, etc.).  
Sections 20910 and 20975 of 1978 PA 368 of 1978, MCL 333.20910, 333.20975 and Section 2233  
of 1978 PA 368, MCL 333.2233.  
MCL 24.239  
RFR-Page 2  
B. Are the rules mandated by any applicable constitutional or statutory provision? If so, please  
explain.  
The rules are mandated under MCL 333.20910(f) and (m).  
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, duplicative similar rules or compliance requirements adopted at the  
state, regional, or federal level 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?  
There are manuals and licensure applications that may need to be revised based on the new rules.  
They include such documents as: Life Support Agency Licensure and Inspection Manual, Agency  
Checklists (which lists the applicable rule number and may change with the new rule set),The  
MDCH EMS and Trauma Systems Section and Office of Legal Affairs and FOIA document  
referencing the Authority to Collect Data will be updated, the Medical Control Authority  
Handbook will be updated, as will the MCA Orientation Presentation.  
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed  
for the current year?  
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 were 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  
While there have been a few changes over the years, there has not been a complete evaluation of  
the rule set since 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 and currently, in 2020, EMS  
agency licensure is being implemented with one more quarter left in calendar year 2020. By  
January 1, 2021 all EMS agency licensure will be completed electronically. Medical Control  
Authority approvals are completed on-line, EMS protocols are now available to all EMS personnel  
online, and complaint investigations are now incorporated into the licensing modules, making it  
easier to track and report data. In addition, 100% of the EMS agencies in MI are now able to  
submit data into the Michigan Emergency Medical Services Information System (MI EMSIS).  
Data submitted is critical to development of evidence-based protocols to guide clinical care and  
for professional standards review organization activities. The COVID-19 pandemic has forced the  
department to look at some regulatory activities through a new lens. This has resulted in utilizing  
technology such as Teams, Zoom, and FaceTime to conduct remote life support vehicle  
inspections, and much of the policy and procedural inspections are also now done through the  
ImageTrend 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.  
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.  
Yes  
MCL 24.239  
;