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examinations, and required passing scores.
MCL 333.16148 requires training standards for identifying victims of human trafficking.
MCL 333.16204 states that if a board requires completion of continuing education as a
condition for renewal, it shall require an appropriate number of hours or courses in pain and
symptom management.
MCL 333.17731 mandates rules requiring each applicant for license renewal to complete as
part of the continuing education or proficiency examination requirement an appropriate number
of hours or courses in pain and symptom management.
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 rules will be reviewed to supply clarity on the delegation of activities and functions for pharmacy
technicians. Once the Pharmacy – General Rules are promulgated, pharmacists will have the ability
to order and administer qualified immunizations pursuant to MCL 333.17724 and order and
administer qualified laboratory tests and dispense a drug without a prescription based on the test
result pursuant to MCL 333.17724a. Therefore, a review of this rule set to address the delegation of
the administration of vaccines, COVID-19 therapeutics, and laboratory tests is anticipated.
Qualified pharmacy technicians are currently authorized to administer certain vaccines, COVID-19
therapeutics, and COVID-19 tests in accordance with the 12th Amendment to Declaration Under the
Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID-
19, 89 Fed. Reg. 99875 (Dec. 11, 2024), until December 31, 2029.
Taking into consideration the federal regulation referenced above, each state establishes its own
requirements with respect to the licensing requirements of pharmacy technicians. There are no other
known laws, rules or other legal requirements that conflict with or duplicate the proposed rules.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
No. The subject matter of these rules is not currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda.
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed for
the current year?
No. The rules are not included in the 2025-2026 Annual Regulatory Plan. However, they will be
included in the upcoming 2026-2027 Annual Regulatory Plan.
12. Will the proposed rules be promulgated under Section 44 of the administrative procedures act
of 1969, 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 rules are not expected to 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. The Department works with various associations, pharmacies, lobbyists, and members of the
public in preparing the proposed rules.
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.
The rules were last amended effective October 2, 2023. There have been no technological factors,
economic conditions or other factors that would necessitate amendment of the rules.
MCL 24.239