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  
REGULATORY IMPACT STATEMENT  
and COST-BENEFT ANALYSIS (RIS)  
Agency Information:  
Department name:  
Licensing and Regulatory Affairs  
Bureau name:  
Bureau of Professional Licensing  
Name of person filling out RIS:  
Weston MacIntosh  
Phone number of person filling out RIS:  
517-241-9269  
E-mail of person filling out RIS:  
MacIntoshW1@michigan.gov  
Rule Set Information:  
ARD assigned rule set number:  
2020-127 LR  
Title of proposed rule set:  
Psychology - General Rules  
Comparison of Rule(s) to Federal/State/Association Standard  
1. Compare the proposed rules to parallel federal rules or standards set by a state or national licensing agency or  
accreditation association, if any exist.  
There are no parallel federal rules or standards set by a state or national licensing agency or accreditation association.  
A. Are these rules required by state law or federal mandate?  
Promulgation of the rules must occur under state law, including MCL 333.16145, 333.16148, 333.18201, 333.18223,  
and 333.18233 as well as Executive Reorganization Nos. 1991-9, 1996-2, 2003-1 and 2011-4, MCL 338.3501,  
445.2001, 445.2011, and 445.2030.  
No federal mandate demands the rules.  
B. If these rules exceed a federal standard, please identify the federal standard or citation, describe why it is  
necessary that the proposed rules exceed the federal standard or law, and specify the costs and benefits arising out  
of the deviation.  
The rules do not exceed a federal standard or law.  
2. Compare the proposed rules to standards in similarly situated states, based on geographic location, topography,  
natural resources, commonalities, or economic similarities.  
MCL 24.245(3)  
RIS-Page 2  
Licensure of psychologists is necessary in Michigan under PA 368 of 1978. The rules supply the conditions and  
requirements for education, examinations, training, and licenses for psychologists.  
When compared to other Great Lakes states (Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania, and  
Wisconsin), Michigan’s licensure requirements are similar. All seven of the other Great Lakes states have rules  
regulating the practice of psychology.  
Illinois. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited school,  
take part in supervised experience, and pass the Examination for Professional Practice in Psychology (EPPP)  
developed by the Association of State and Provincial Psychology Boards (ASPPB) prior to obtaining full licensure.  
Licensees must complete 24 hours of continuing education every two years.  
Indiana. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited school  
and pass the EPPP prior to obtaining full licensure. Psychologists must complete 40 hours of continuing education  
during every 2-year license period.  
Minnesota. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited  
school, take part in supervised experience, and pass the EPPP and a professional responsibility examination prior to  
obtaining full licensure. Licensees must complete 40 hours of continuing education every two years.  
New York. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited  
school, take part in supervised experience, and pass the EPPP prior to obtaining full licensure. Licensees must  
complete 36 hours of continuing education every three years.  
Ohio. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited school,  
take part in supervised experience, and pass the EPPP prior to obtaining full licensure. Applicants for licensure as a  
school psychologist must hold a master’s level school psychology degree from an accredited school, take part in 4  
years of school psychology experience, and pass both a school psychologist and a laws and rules examination.  
Psychologist licensees must complete 23 hours of continuing education every two years.  
Pennsylvania. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited  
school, take part in supervised experience, and pass the EPPP and a law examination prior to obtaining full licensure.  
Licensees must complete 30 hours of continuing education every two years.  
Wisconsin. Applicants for licensure must hold a doctoral level psychology degree from a qualifying or accredited  
school, take part in supervised experience, and pass the EPPP and a jurisprudence examination prior to obtaining full  
licensure. Licensees must complete 40 hours of continuing education every two years.  
When compared to other Great Lakes states, Michigan’s licensure requirements for doctoral level trained  
psychologists are like other Great Lakes states. Michigan and Ohio, however, are the only two Great Lakes states that  
also license master’s level trained psychologists, and the exception in Ohio only pertains to school psychologists.  
Continuing education requirements are like Great Lakes states where continuing education is also necessary.  
The proposed rules are consistent with the rules of those states that also regulate psychologists. Under statute,  
Michigan allows the limited licensure of master’s level trained psychologists.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of  
the deviation.  
Statute demands promulgation of rules related to licensure. The rules do not exceed the licensing requirements of  
other states.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed  
rules.  
There are no federal regulations for psychologists. There are no laws, rules, or other legal requirements that duplicate,  
overlap, or conflict with the proposed rules.  
MCL 24.245(3)  
RIS-Page 3  
A. Explain how the rules have been coordinated, to the extent practicable, with other federal, state, and local laws  
applicable to the same activity or subject matter. This section should include a discussion of the efforts undertaken  
by the agency to avoid or minimize duplication.  
Review of applicable statutory law avoided unnecessary duplication in the rules.  
4. If MCL 24.232(8) applies and the proposed rules are more stringent than the applicable federally mandated  
standard, provide a statement of specific facts that establish the clear and convincing need to adopt the more  
stringent rules.  
No federal mandate demands the rules.  
5. If MCL 24.232(9) applies and the proposed rules are more stringent than the applicable federal standard,  
provide either the Michigan statute that specifically authorizes the more stringent rules OR a statement of the  
specific facts that establish the clear and convincing need to adopt the more stringent rules.  
No federal mandate demands the rules.  
Purpose and Objectives of the Rule(s)  
6. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
The specific topics that the proposed rules address, and the purpose of the proposed rules are set forth below:  
R 338.2521, R 338.2525, R 338.2529, R 338.2547, R 338.2565, R 338.2581, R 338.2583, and R 338.2585 include  
clean-up and grammatical revisions to the language in the current rules.  
R 338.2523. This rule pertains to an English language standard. Rescission of this rule will take place because a  
minimum English language standard now appears in the Public Health Code – General Rules.  
R 338.2526. This rule pertains to telehealth. The rule addition supplies conditions related to consent, scope of  
practice, and standard of care for telehealth services.  
R 338.2529. This rule pertains to adoption of standards. The rule revision supplies updates to the latest educational  
standards.  
R 338.2541. This rule pertains to adoption of standards. The rule revision supplies updates to the latest educational  
standards.  
R 338.2543. This rule pertains to applications for licensure. The rule revision supplies information about  
postdoctoral internship standards.  
R 338.2545. This rule pertains to examination. The rule revision clarifies the examination and needed passing score  
for licensure.  
R 338.2549. This rule pertains to foreign graduates of non-accredited postsecondary institutions. The rule revision  
removes the English language requirement, as this requirement now appears in the Public Health Code – General  
Rules.  
R 338.2551. This rule pertains to requirements for licensure by endorsement for psychologists. The rule revision  
incorporates the recent legislative changes that allow licensure by endorsement for individuals licensed in another  
state or a province of Canada and revises the requirements for verification of licenses held in other jurisdictions.  
R 338.2553. This rule pertains to educational limited licenses for postdoctoral experience. The rule revision clarifies  
that supervision may take place via in-person or two-way real-time interaction between the supervisor and supervisee.  
R 338.2555. This rule pertains to relicensure requirements. The rule revision allows proof of licensure in a province  
of Canada for purposes of relicensure and the requirements for verification of licenses held in other jurisdictions.  
MCL 24.245(3)  
RIS-Page 4  
R 338.2561. This rule pertains to application requirements for limited license psychologists. The rule revision  
clarifies that supervision may take place via in-person or two-way real-time interaction between the supervisor and  
supervisee.  
R 338.2563. This rule pertains to examination for limited license psychologists. The rule revision clarifies the  
examination and needed passing score for licensure.  
R 338.2567. This rule pertains to foreign graduates of non-accredited postsecondary institutions for limited licensure.  
The rule revision removes the English language requirement, as this requirement now appears in the Public Health  
Code – General Rules.  
R 338.2569. This rule pertains to temporary limited licenses. The rule revision clarifies that supervision may take  
place via in-person or two-way real-time interaction between the supervisor and supervisee.  
R 338.2571. This rule revision pertains to supervision requirements for limited license psychologists. The rule  
revision clarifies that supervision may take place via in-person or two-way real-time interaction between the  
supervisor and supervisee.  
R 338.2573. This rule pertains to relicensure requirements for limited license psychologists. The rule revises the  
requirements for verification of licenses held in other jurisdictions.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
Promulgation of rules related to licensure is necessary under statute. This supplies a regulatory framework for the  
practice of psychology. The proposed changes supply greater clarity to licensees and aid in understanding the  
requirements of the rules.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
Statute regulates the practice of psychology. This mandates licensure for provision of those services. Adding  
clarifications on points that may have been ambiguous under prior rules will make compliance easier for applicants  
and licensees.  
C. What is the desired outcome?  
Regulation is necessary for individuals who wish to practice as psychologists. By improving and clarifying the rules,  
applicants and licensees should find compliance easier. This should result in fewer questions, fewer regulatory  
problems, and greater safety and protection of the public.  
7. Identify the harm resulting from the behavior that the proposed rules are designed to alter and the likelihood  
that the harm will occur in the absence of the rule.  
MCL 24.245(3)  
RIS-Page 5  
The proposed rule set updates the previously adopted rules. Specifically, changes include the following:  
R 338.2526 pertains to telehealth. The new rule protects patients by outlining the conditions for telehealth services.  
R 338.2529 pertains to adoption of standards. The rule revision ensures educational programs satisfy updated  
educational requirements.  
R 338.2541 pertains to adoption of standards. The rule revision ensures educational programs satisfy updated  
educational requirements.  
R 338.2543 pertains to applications for licensure. The rule revision supplies better guidance about postdoctoral  
internship standards.  
R 338.2545 and R 338.2563 pertains to examination. The rule revision articulates the specific examination  
requirements an applicant must satisfy.  
R 338.2551 pertains to requirements for licensure by endorsement for psychologists. The rule revision clarifies the  
conditions that an applicant must satisfy to qualify for licensure by endorsement, to align with recent corresponding  
legislative changes.  
R 338.2553 pertains to educational limited licenses for postdoctoral experience. The rule revision allows more ways  
for supervision to take place, allowing more opportunities and flexibility for patient care.  
R 338.2555 and R 338.2573 pertains to requirements for relicensure. The rule revision clarifies the proof  
requirements an applicant licensed in another jurisdiction must satisfy for verification of a license.  
R 338.2561 pertains to application requirements for limited license psychologists. The rule revision allows more ways  
for supervision to take place, allowing more opportunities and flexibility for patient care.  
R 338.2569 pertains to temporary limited licenses. The rule revision allows more ways for supervision to take place,  
allowing more opportunities and flexibility for patient care.  
R 338.2571 pertains to supervision requirements for limited license psychologists. The rule revision allows more  
ways for supervision to take place, allowing more opportunities and flexibility for patient care.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
The proposed rule set supplies clarity to all rules on licensure.  
8. Describe how the proposed rules protect the health, safety, and welfare of Michigan citizens while promoting a  
regulatory environment in Michigan that is the least burdensome alternative for those required to comply.  
The proposed rules supply a regulatory mechanism for the practice of psychology. To protect the health, safety, and  
welfare of Michigan’s citizens, it is important that members of the profession adhere to educational and professional  
standards.  
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
R 338.2523. This rule pertains to an English language standard. Rescission of this rule will take place because a  
minimum English language standard now appears in the Public Health Code – General Rules.  
Fiscal Impact on the Agency  
Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e. hiring additional staff,  
higher contract costs, programming costs, changes in reimbursements rates, etc. over and above what is currently  
expended for that function. It does not include more intangible costs for benefits, such as opportunity costs, the value of  
time saved or lost, etc., unless those issues result in a measurable impact on expenditures.  
MCL 24.245(3)  
RIS-Page 6  
10. Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential savings  
for the agency promulgating the rule).  
There is no expected fiscal impact on the agency for promulgating the proposed rules.  
11. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
There has been no agency appropriation for the proposed rules because there are no expected agency expenditures  
associated with the proposed rules.  
12. Describe how the proposed rules are necessary and suitable to accomplish their purpose, in relationship to the  
burden(s) the rules place on individuals. Burdens may include fiscal or administrative burdens, or duplicative  
acts.  
The proposed rules supply a mechanism for the licensing and regulation of individuals in this state, as mandated by  
statute. Applicants and licensees will continue to have a cost related burden associated with licensing, renewal, or  
relicensure. The cost of licensure for a Master’s Ed. Ltd. (T.L.L.P.) is $102.65. The cost of licensure of a Master’s  
Ltd. Psychologist is $200.05. The cost of licensure of a Master’s Ltd. – Relicensure is $220.05. The cost of licensure  
of a Doctoral Ed. Ltd. (T.L.L.P.) is $102.65. The cost of licensure of a Doctoral Ed. Ltd. (Postdoctoral) is $97.25.  
The cost of licensure of a Doctoral Ed. Ltd. – Relicensure is $117.25. The cost of licensure of a Psychologist is  
$264.95. The cost of licensure of a Psychologist – Relicensure is $284.95.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable  
compared to the burdens.  
The rules are necessary to supply a mechanism for licensing and regulation of the profession. The rules are not more  
restrictive than allowed by statute. Despite the cost related burden of licensing, the rules and regulations are  
necessary to supply a framework of standards for educational and licensure requirements.  
Impact on Other State or Local Governmental Units  
13. Estimate any increase or decrease in revenues to other state or local governmental units (i.e. cities, counties,  
school districts) as a result of the rule. Estimate the cost increases or reductions for other state or local  
governmental units (i.e. cities, counties, school districts) as a result of the rule. Include the cost of equipment,  
supplies, labor, and increased administrative costs in both the initial imposition of the rule and any ongoing  
monitoring.  
There is no expected increase or decrease in revenues to other state or local government units, nor are there cost  
increases or reductions on other state or local government units expected because of the proposed rules. There is no  
expected increase or decrease in revenues to other state or local government units, nor are there cost increases or  
reductions on other state or local government units expected because of the proposed rules.  
14. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
The proposed rules do not impose any program, service, duty, or responsibility upon any city, county, town, village,  
or school district.  
A. Describe any actions that governmental units must take to be in compliance with the rules. This section should  
include items such as record keeping and reporting requirements or changing operational practices.  
No action is necessary for governmental units to follow the rule(s).  
15. Describe whether or not an appropriation to state or local governmental units has been made or a funding  
source provided for any additional expenditures associated with the proposed rules.  
State and local government units will incur no added expenditures because of implementing the proposed rules.  
Therefore, no appropriation or funding source is necessary.  
Rural Impact  
16. In general, what impact will the rules have on rural areas?  
There is no expected disparate impact on rural areas because of the proposed rules.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
There is no expected disparate impact of public or private interests in rural areas because of the proposed rules.  
MCL 24.245(3)  
RIS-Page 7  
Environmental Impact  
17. Do the proposed rules have any impact on the environment? If yes, please explain.  
No, the proposed rules will have no impact on the environment.  
Small Business Impact Statement  
18. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
The public health code authorizes the board and the department to regulate individuals with psychology licenses, not  
small businesses. Even if a licensee’s practice qualified as a small business, the department could not exempt the  
licensee’s small business because it would create disparity in the regulation of the profession.  
19. If small businesses are not exempt, describe (a) the manner in which the agency reduced the economic impact  
of the proposed rules on small businesses, including a detailed recitation of the efforts of the agency to comply  
with the mandate to reduce the disproportionate impact of the rules upon small businesses as described below (in  
accordance with MCL 24.240(1)(a-d)), or (b) the reasons such a reduction was not lawful or feasible.  
There is no expected economic impact on small businesses because of the proposed rules. The proposed rules affect  
individual licensees rather than small businesses.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on  
small businesses.  
The department does not collect or have access to information that would allow it to find and estimate the potentially  
affected number of small businesses. It is impossible to estimate the number of small businesses affected by the  
proposed rules. The only small businesses affected by these rules are health practitioners practicing in small business  
settings. The department does not track or have access to this type of information since it is not a data repository.  
The rules do not affect the operation of the small business. The probable impact on small business is small.  
B. Describe how the agency established differing compliance or reporting requirements or timetables for small  
businesses under the rules after projecting the required reporting, record-keeping, and other administrative costs.  
Because the proposed rules pertain to individuals and not small businesses, they do not have differing compliance or  
reporting requirements or timetables for small businesses. They are unnecessary for the proposed rules.  
C. Describe how the agency consolidated or simplified the compliance and reporting requirements for small  
businesses and identify the skills necessary to comply with the reporting requirements.  
The proposed rules do not impose any reporting requirements.  
D. Describe how the agency established performance standards to replace design or operation standards required  
by the proposed rules.  
The agency did not set up performance standards to replace design or operation standards.  
20. Identify any disproportionate impact the proposed rules may have on small businesses because of their size or  
geographic location.  
The proposed rules affect individual licensees rather than small businesses. Therefore, there is no expected  
disproportionate impact on small businesses based on size or geographic location because of the rules.  
21. Identify the nature of any report and the estimated cost of its preparation by small businesses required to  
comply with the proposed rules.  
The proposed rules do not need any reports.  
22. Analyze the costs of compliance for all small businesses affected by the proposed rules, including costs of  
equipment, supplies, labor, and increased administrative costs.  
There is no expectation of an effect on small businesses because of the proposed rules, nor are there any added costs,  
because the proposed rules apply to individuals and not businesses.  
23. Identify the nature and estimated cost of any legal, consulting, or accounting services that small businesses  
would incur in complying with the proposed rules.  
The proposed rules, which apply to individuals and not businesses, should not create a need for any legal, consulting,  
or accounting services for small businesses to be able to follow the proposed rules.  
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
MCL 24.245(3)  
RIS-Page 8  
Since the rules affect individual licensees rather than small businesses, there is no expected cause of economic harm  
or for the rules to adversely affect a small business’ competition in the marketplace.  
25. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser  
standards for compliance by small businesses.  
The proposed rules impose requirements on individual licensees rather than small businesses. Even if a licensee’s  
practice qualifies as a small business, the department could not exempt the licensee’s small business because it would  
create disparity in regulation of the profession. Therefore, exempting or setting lesser standards of competence for  
small businesses is not in the best interest of the public.  
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The department is not able to exempt licensees that own a small business. If the department exempted small  
businesses, it would create a disparity in the regulation of a profession and have a negative impact on public safety.  
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.  
Development of the proposed rules involved consultation with the Michigan Board of Psychology, whose members  
include small business employees.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
Development of the proposed rules involved consultation with the Michigan Board of Psychology, whose members  
include small business employees.  
Cost-Benefit Analysis of Rules (independent of statutory impact)  
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
There are no small businesses affected by the proposed rules. Those affected are individuals who are engaged in the  
practice of psychology.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the  
proposed rules.  
The licensees must follow the rules.  
B. What additional costs will be imposed on businesses and other groups as a result of these proposed rules (i.e.  
new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and number of businesses  
and groups. Be sure to quantify how each entity will be affected.  
There will be no expected added costs imposed upon licensees because of compliance with these proposed rules.  
29. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or  
the public). Include the costs of education, training, application fees, examination fees, license fees, new  
equipment, supplies, labor, accounting, or recordkeeping.  
Applicants and licensees will continue to have a cost related burden associated with licensing, renewal, or  
relicensure. The cost of licensure for a Master’s Ed. Ltd. (T.L.L.P.) is $102.65. The cost of licensure of a Master’s  
Ltd. Psychologist is $200.05. The cost of licensure of a Master’s Ltd. – Relicensure is $220.05. The cost of  
licensure of a Doctoral Ed. Ltd. (T.L.L.P.) is $102.65. The cost of licensure of a Doctoral Ed. Ltd. (Postdoctoral) is  
$97.25. The cost of licensure of a Doctoral Ed. Ltd. – Relicensure is $117.25. The cost of licensure of a  
Psychologist is $264.95. The cost of licensure of a Psychologist – Relicensure is $284.95.  
A. How many and what category of individuals will be affected by the rules?  
The rules affect all individuals who seek licensure as psychologists.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
By improving and clarifying the rules, applicants and licensees should find compliance easier. Applicants and  
licensees will continue to have a cost related burden associated with licensing.  
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result  
of the proposed rules.  
There are no expected reductions in costs to businesses, individuals, groups of individuals, or governmental units  
because of the proposed rules.  
31. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please  
provide both quantitative and qualitative information, as well as your assumptions.  
MCL 24.245(3)  
RIS-Page 9  
The proposed rules use clear, concise language, and implement the statutory requirements for licensing. The clear,  
concise language allows the public, licensees, and schools to better understand the requirements for licensure.  
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
There is no expected significant impact on business growth, job growth, or job elimination because of the rules.  
33. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their  
industrial sector, segment of the public, business size, or geographic location.  
The department does not expect any disproportionate effect on any individuals or businesses by their industrial  
sector, segment of the public, business size, or geographical location.  
34. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the  
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-  
benefit analysis of the proposed rules.  
National Register of Health Service Psychologists  
https://www.nationalregister.org/  
American Psychological Association  
https://www.apa.org/  
Canadian Psychological Association  
https://cpa.ca/  
Psychological Clinical Science Accreditation System  
https://www.pcsas.org/  
Association of Psychology Postdoctoral and Internship Centers  
https://www.appic.org/  
Association of State and Provincial Psychology Boards  
https://www.asppb.net/default.aspx  
National Association of Credential Evaluation Services  
http://naces.org/  
Illinois  
https://www.idfpr.com/profs/psych.asp  
Indiana  
https://www.in.gov/pla/professions/indiana-state-psychology-board/  
Minnesota  
https://mn.gov/boards/psychology/  
New York  
http://www.op.nysed.gov/prof/psych/  
Ohio  
https://www.psychology.ohio.gov/  
Pennsylvania  
https://www.dos.pa.gov/ProfessionalLicensing/BoardsCommissions/Psychology/Pages/default.aspx  
Wisconsin  
https://dsps.wi.gov/pages/BoardsCouncils/Psychology/Default.aspx  
MCL 24.245(3)  
RIS-Page 10  
A. How were estimates made, and what were your assumptions? Include internal and external sources, published  
reports, information provided by associations or organizations, etc., that demonstrate a need for the proposed  
rules.  
Since statute mandates the rules, no estimate was necessary.  
Alternative to Regulation  
35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
Since statute mandates the rules, there are no reasonable alternatives to the proposed rules.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
Since statute mandates the rules, there are no reasonable alternatives to the proposed rules.  
36. Discuss the feasibility of establishing a regulatory program similar to that proposed in the rules that would  
operate through private market-based mechanisms. Please include a discussion of private market-based systems  
utilized by other states.  
Since statute mandates the rules, private market-based systems cannot serve as an alternative. The licensing and  
regulation of psychologists are state functions, so a regulatory program independent of state intervention cannot be  
set up. One could consider psychology professional associations as regulatory mechanisms that are independent of  
state intervention; however, these professional organizations would provide the public with significantly less  
protection because membership in these organizations is voluntary. This means an individual who meets the  
membership requirements, but does not join, would still be able to practice and there would be no way to ensure the  
individual’s competency or hold the individual accountable for harm done to clients.  
37. Discuss all significant alternatives the agency considered during rule development and why they were not  
incorporated into the rules. This section should include ideas considered both during internal discussions and  
discussions with stakeholders, affected parties, or advisory groups.  
Since statute mandates the rules, there are no reasonable alternatives to the proposed rules. There were no  
alternatives that the department considered to achieve the intended changes. They are necessary for the  
administration and enforcement of the licensing process.  
Additional Information  
38. As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of complying with  
the rules, if applicable.  
The rules include the instructions for compliance.  
MCL 24.245(3)  
;