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:  
Andria Ditschman  
Phone number of person filling out RIS:  
517-290-3361  
E-mail of person filling out RIS:  
DitschmanA@michigan.gov  
Rule Set Information:  
ARD assigned rule set number:  
2020-29 LR  
Title of proposed rule set:  
Pharmacy Technicians  
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.  
Each state establishes its own requirements with respect to pharmacy technicians, so there are no federal rules or  
standards set by a national or state agency that the proposed rules can be compared to.  
A. Are these rules required by state law or federal mandate?  
Yes, the Department of Licensing and Regulatory Affairs (Department) in consultation with the Board of Pharmacy  
(Board) is required to promulgate rules as follows: to include training standards for identifying victims of human  
trafficking, pursuant to MCL 333.16148; to complete continuing education (CE) hours in pain and symptom  
management for an applicant for licensure renewal, if continuing education is a condition for renewal, pursuant to  
MCL 333.16204; and to require applicants for license renewal to complete hours in pain and symptom management,  
pursuant to MCL 333.17731.  
The following provisions authorize rule making: MCL 333.16145, MCL 333.16148, MCL 333.16174, MCL  
333.16175, MCL 333.16178, MCL 333.16182, MCL 333.16186, MCL 333.16204, MCL 333.17731, MCL 333.17739,  
MCL 333.17739a, MCL 338.3501, MCL 445.2001, MCL 445.2011, and MCL 445.2030.  
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.  
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  
The proposed rules are consistent with the standards required by the Public Health Code (Code) and are largely  
consistent with the requirements of other states in the Great Lakes region.  
R 338.3651, R 338.3652, R 338.3653, and R 338.3657: The proposed rules pertain to the requirements for pharmacy  
technician licensure, temporary licensure, licensure by endorsement, and relicensure. The licensure requirements in  
the proposed rules are similar to the standards and requirements in other states in the Great Lakes Region. Illinois,  
Indiana, and Ohio require certification. Only New York and Pennsylvania do not license or register pharmacy  
technicians. Minnesota, Ohio, and Wisconsin register their pharmacy technicians.  
R 338.3654: The proposed rule pertains to the examination requirements for licensure. Indiana, Minnesota, New York,  
Pennsylvania, and Wisconsin do not require an examination.  
R 338.3655: The proposed rule pertains to Board-approved pharmacy technician educational programs and the  
process for approval. Although graduation from a pharmacy technician educational program is not a requirement for  
licensure, attendance in a program allows a student to participate in the activities of a pharmacy technician without a  
license while he or she is in the training programs included in this proposed rule. The proposed rule requires all Board  
-approved pharmacy technician programs to be accredited by an accrediting body recognized by the U.S. Department  
of Education or American Society of Health-System Pharmacists/Accreditation Council for Pharmacy Education  
Pharmacy Technician Accreditation Commission (ASHP/ACPE). Most states in the Great Lakes Region require  
training for pharmacy technicians.  
R 338.3661, R 338.3662, and R 338.3663: The proposed rules pertain to the license renewal and continuing education  
(CE) requirements. Minnesota and Ohio require CE.  
R 338.3665: The proposed rule pertains to the functions that may be performed by a pharmacy technician. Unlike  
Michigan, none of the other states in the Great Lakes Region have pharmacy technicians check the work of other  
pharmacy technicians.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of  
the deviation.  
The standards pertaining to licensure, examinations, educational training programs, relicensure, renewal, CE, and  
duties differ from state to state. Overall, the standards in the proposed rules do not exceed those of the other states in  
the Great Lakes Region.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed  
rules.  
Public Act 4 of 2020 authorized the Department to license a remote pharmacy that operates under a parent pharmacy  
through a telepharmacy system. Public Act 4 of 2020 established the term “qualified pharmacy technician.” A  
qualified pharmacy technician must meet all of the following requirements: hold a pharmacy technician license other  
than a temporary license or limited license; accumulate at least 1,000 hours of experience working in a pharmacy after  
being granted a temporary, limited, or full license; and hold a national certification as a pharmacy technician from an  
organization approved by the Board. Although, under the Public Health Code a pharmacy technician must be under  
the personal charge of a pharmacist, which means that the pharmacist is supervising the pharmacy technician in  
person under direct supervision. In a remote pharmacy, a qualified pharmacy technician may be overseen by a  
pharmacist in charge and staffed by a qualified pharmacy technician through a surveillance system and telepharmacy  
system.  
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.  
Except in a remote pharmacy, which has been excepted in the rules, as it is fully authorized in the Public Health Code,  
no coordination is needed because there are no other applicable laws that are inconsistent with the regulations in the  
proposed rules.  
MCL 24.245(3)  
RIS-Page 3  
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.  
There is no applicable federally mandated standard. Consequently, MCL 24.232(8) is not applicable.  
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.  
There is no applicable federal standard.  
Purpose and Objectives of the Rule(s)  
6. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
The proposed rules are designed to alter the following behavior: reducing the confusion of applicants who desire to  
apply as a pharmacy technician but do not understand the process; eliminating the inconsistency in Board-approved  
pharmacy technician programs by requiring that they be accredited; allowing a pharmacy technician program student  
to perform pharmacy technician duties indefinitely without being fully licensed; allowing pharmacy technician  
employer programs and examinations to continue indefinitely without further review by the Board; relicensing an  
applicant after he or she has allowed a license to lapse without showing good moral character or submitting  
fingerprints; licensing an individual who has not taken the human trafficking required training; allowing continuing  
education to be met by taking a proficiency examination that the licensee may have taken in the past; reducing the  
confusion regarding the type of continuing education that is accepted by the Department; and limiting a pharmacy  
technician from assisting in the final product verification.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
The proposed rules are expected to alter the frequency of the targeted behavior as follows: the Department expects  
minimal requests from applicants regarding program and examination requirements; the proposed rules will eliminate  
the inconsistency in Board-approved pharmacy technician programs by requiring that they be accredited; a pharmacy  
technician will be limited to performing pharmacy technician duties for only two years from beginning a program  
without being fully licensed; pharmacy technician employer programs and examinations will be reviewed every 5  
years; all applicants for relicensure will be required to show good moral character and submit their fingerprints; all  
applicants will take the human trafficking training; for all applicants renewing one year after the effective date of the  
rules, continuing education may no longer be met by taking a proficiency examination; and pharmacy technicians who  
meet the requirements in the rules will be authorized to assist in the final product verification.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
The difference between current behavior and desired behavior is as follows: it is expected that there will be less  
confusion and questions from employer program applicants and licensure applicants regarding program and  
examination requirements. Requiring employer programs to be accredited will provide a more consistent education  
across all programs and benefit the applicants and public. Instead of allowing a pharmacy technician program student  
to perform pharmacy technician duties indefinitely without being fully licensed, a pharmacy technician student will be  
limited to performing pharmacy technician duties for only two years from beginning a program without being fully  
licensed. Instead of allowing pharmacy technician employer programs and examinations to continue indefinitely  
without further review by the Board, pharmacy technician employer programs and examinations will be reviewed  
every 5 years. Previously, applicants for licensure were not always required to show good moral character, submit  
their fingerprints, and take the human trafficking training. The proposed rules will require all applicants to comply  
with those requirements. The requirements for continuing education could be met by taking a proficiency  
examination, but the proposed rules no longer allow taking a proficiency examination and will require the licensee to  
meet other continuing education requirements. Lastly, pharmacy technicians who meet the requirements in the  
proposed rules will be authorized to assist in final product verification.  
C. What is the desired outcome?  
MCL 24.245(3)  
RIS-Page 4  
The desired outcome of the proposed rules is that the Department expects minimal requests from applicants regarding  
program and examination requirements; the proposed rules will eliminate the inconsistency in Board-approved  
pharmacy technician programs and result in a higher level of education for pharmacy technicians if programs are  
accredited; a pharmacy technician will be limited to performing pharmacy technician duties for only two years from the  
beginning of a program without being fully licensed which will reduce the time that a student may practice without  
being fully licensed; pharmacy technician employer programs and examinations will be reviewed every 5 years so that  
programs and examinations are up to date and those that are no longer offered can be taken off of the list kept by the  
Department; all applicants for relicensure will be required to show good moral character and submit their fingerprints  
which is in the best interest of the public that they serve; all applicants will take the human trafficking training so that  
they can spot a person being trafficked; continuing education may no longer be met by taking a proficiency  
examination; and pharmacy technicians that meet the requirements in the rules will be authorized to assist in the final  
product verification.  
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.  
The proposed rules are designed to alter the following harm: reduce the confusion of applicants who desire to apply as  
a pharmacy technician but do not understand the process; eliminate the inconsistency in Board-approved pharmacy  
technician programs by requiring that they be accredited; allowing a pharmacy technician program student to perform  
pharmacy technician duties indefinitely without being fully licensed; allowing pharmacy technician employer  
programs and examinations to continue indefinitely without further review by the Board; relicensing an applicant after  
he or she has allowed a license to lapse without showing good moral character or submitting fingerprints; licensing an  
individual who has not taken the human trafficking required training; allowing continuing education to be met by  
taking a proficiency examination that the licensee may have taken in the past; reduce the confusion regarding the type  
of continuing education that is accepted by the Department; and limiting a pharmacy technician from assisting in the  
final product verification.  
The harm that will result from the behavior that the proposed rules are designed to alter will continue in the absence of  
the proposed rules.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
The harm that will result from the behavior that the proposed rules are designed to alter will continue in the absence  
of the proposed rules.  
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 provide a regulatory mechanism for the practice pharmacy technicians. To protect the health and  
safety of Michigan’s citizens, it is important that members of the profession adhere to minimal educational and  
professional standards.  
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
There are no rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
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.  
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).  
The proposed rules are not expected to have a fiscal impact on the agency.  
11. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
No agency appropriation has been made nor has a funding source been provided for expenditures associated with  
implementing these rules.  
MCL 24.245(3)  
RIS-Page 5  
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 estimated cost for submitting fingerprints for a background check by applicants is $30.00. The estimated cost for  
human trafficking training is zero as the training may be found online. The background check and training will  
benefit Michigan citizens by requiring an applicant for licensure to demonstrate that he or she is of good moral  
character and knowledgeable about human trafficking.  
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 required to provide a mechanism for licensing and regulation of the profession. The rules are not any  
more restrictive than is allowed by statute. Despite the cost-related burden of licensing, the rules and regulations are  
necessary in order to provide a framework of standards for educational, licensure, and CE 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 are no anticipated increases or decreases in revenues to state or local governmental units as a result 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.  
There are no anticipated or intended programs, services, duties, or responsibilities imposed on any city, county,  
township, village, or school district as a result of these proposed rules.  
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.  
There are no anticipated actions that a governmental unit must take to comply with these proposed rules.  
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.  
No appropriations have been made to any governmental units as a result of these rules. No additional expenditures  
are anticipated or intended with the proposed rules.  
Rural Impact  
16. In general, what impact will the rules have on rural areas?  
The proposed rules are not expected to impact rural areas. The proposed rules apply to an individual licensed under  
the public health code as a pharmacy technician, regardless of his or her location.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
No disparate impact of public or private interests is anticipated on rural areas because of the proposed rules.  
Environmental Impact  
17. Do the proposed rules have any impact on the environment? If yes, please explain.  
The proposed rules do not have an environmental impact.  
Small Business Impact Statement  
18. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
MCL 24.245(3)  
RIS-Page 6  
The proposed rules impose requirements on individual licensees. Even if a licensee’s workplace qualifies as a small  
business, the Department could not exempt his or her business because it would create a disparity in the regulation of  
the profession.  
The proposed rules will also require Board approved pharmacy technician programs to be accredited by July 1, 2022.  
The goal of the proposed rule requiring accreditation is to require consistency and a high level of education in the  
Board approved programs, exempting some programs would defeat the goal of the proposed rule.  
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.  
The licensing rules regulate individual licensees. While a licensee may work independently or as part of a small  
business, the law does not allow the rules to exempt these individuals from the requirements of the rules.  
The proposed rules will also require Board approved pharmacy technician programs to be accredited by July 1, 2022.  
The goal of the proposed rule requiring accreditation is to require consistency and a high level of education in the  
programs, exempting some programs would defeat the goal of the proposed rule. Programs are offered at large and  
small pharmacies as well as proprietary schools licensed in Michigan.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on  
small businesses.  
There are approximately 15,231 pharmacy technicians and 1,346 limited pharmacy technicians in Michigan. There  
are 69 pharmacies that have been approved by the Board to offer a pharmacy technician employer-based training  
program and examination. In addition, employers such as Meijer, Walgreens, Walmart and Sam’s Club, Kroger  
Company, Rite Aid, Costco, and CVS Drugs offer programs at multiple locations. There are seven proprietary  
schools offering a pharmacy technician program.  
A licensee may work in a small business, but no matter what type of business environment the licensee works in, he  
or she will have to comply with the proposed rules. The rules do not impact small businesses differently than any  
other entity that desires to offer a pharmacy technician training program and examination.  
The probable effect on entities that offer a training program and examination is that they must have the program  
accredited or they will no longer be able to offer the program after July 1, 2022.  
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.  
The agency did not establish separate compliance or reporting requirements for small businesses. The proposed rules  
will apply to all licensed pharmacy technicians and entities that offer a pharmacy technician training program and  
examination. The rules were drafted to be the least burdensome on all affected licensees and programs.  
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 agency did not consolidate or simplify compliance and reporting requirements in the proposed rules.  
D. Describe how the agency established performance standards to replace design or operation standards required  
by the proposed rules.  
The agency did not establish performance standards to replace design or operation standards required by these rules.  
20. Identify any disproportionate impact the proposed rules may have on small businesses because of their size or  
geographic location.  
The proposed rules impact an individual licensee as well as entities that offer a pharmacy technician training program  
and examination. There may be an impact on a small business in that it must have the program accredited, however,  
allowing a small business to offer a program of lesser quality than another program is not in the best interests of the  
public.  
21. Identify the nature of any report and the estimated cost of its preparation by small businesses required to  
comply with the proposed rules.  
MCL 24.245(3)  
RIS-Page 7  
The proposed rules affect individual licensure applications and renewals, which are already required of all licensees,  
regardless if they practice in a small business.  
An entity that offers a pharmacy technician training program and examination must apply for and meet accreditation  
standards to be approved. In addition, it must apply every five years for re-approval, which will require proof of  
accreditation. Except for maintaining the program syllabus and activities performed in the program, the proposed  
rules do not require a program to submit or maintain any additional reports that are not already required in the rules.  
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.  
For all-Board approved pharmacy technician training programs, the cost of compliance will include the cost for  
accreditation. The cost of accreditation depends on the accreditor, the type of entity being accredited, as well as the  
number of sites being accredited. The cost is estimated at $3,500.00 annually for an educational site to $10,000.00  
annually for a chain pharmacy.  
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.  
There are no expected costs for legal, consulting, or accounting services in addition to the accreditation process that a  
small business would incur in complying with 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.  
There are no expected costs to a small business that will cause economic harm to a small business or the marketplace  
as a result of the proposed rules.  
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. Even if a licensee’s practice qualifies as a small  
business, the Department could not exempt his or her business because it would create disparity in the regulation of  
the profession.  
If an entity that offers a Board approved pharmacy technician training program qualified as a small business, and the  
Department determined to set lesser standards for compliance, the cost to the Department would involve reviewing  
the applications and enforcing the standards. However, the real cost would be to the public who would be being  
served by pharmacy technicians who were trained at a lower level than pharmacy technicians educated in accredited  
programs.  
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The proposed rules impose requirements on individual licensees. Even if a licensee’s work qualifies as a small  
business, the Department could not exempt his or her business because it would create a disparity in the regulation of  
the profession.  
If an entity that offers a Board approved pharmacy technician training program qualified as a small business, and the  
Department determined to set lesser standards for compliance, the impact on the public interest would be being  
served by pharmacy technicians who were trained at a lower level than pharmacy technicians educated in accredited  
programs.  
Therefore, exempting or setting lesser standards of compliance for a small business is not in the best interest of the  
public.  
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.  
The Department worked with multiple stakeholders at work group sessions that included members from the Board of  
Pharmacy, educational institutions, large and small businesses, and other members of the public in the development  
of the proposed rules. The Board is composed of members of the profession and public members who work in small  
and large businesses in Michigan.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
MCL 24.245(3)  
RIS-Page 8  
Representatives from businesses were involved in the development of the rules. However, the Department is not  
aware if they meet the definition of a “small business.”  
Cost-Benefit Analysis of Rules (independent of statutory impact)  
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
The estimated compliance cost would be the cost of entities to have their programs accredited.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the  
proposed rules.  
There are approximately 15,231 pharmacy technicians and 1,346 limited pharmacy technicians in Michigan. There  
are 69 pharmacies that have been approved by the Board to offer a pharmacy technician employer-based training  
program and examination. In addition, employers such as Meijer, Walgreens, Walmart and Sam’s Club, Kroger  
Company, Rite Aid, Costco, and CVS Drugs offer programs at multiple locations. There are seven proprietary  
schools offering a pharmacy technician program.  
A licensee may work in a small business, but no matter what type of business environment the licensee works in, he  
or she will have to comply with the proposed rules. The rules do not impact small businesses differently than any  
other entity that desires to offer a pharmacy technician training program and examination.  
The probable effect on entities that offer a training program and examination is that they must have the program  
accredited or they will no longer be able to offer the program after July 1, 2022.  
The public will be directly affected by the proposed rules. If an entity that offers a Boar- approved pharmacy  
technician training program qualified as a small business, and the Department determined to set lesser standards for  
compliance, the impact on the public interest would be being served by pharmacy technicians who were trained at a  
lower level than pharmacy technicians educated in accredited programs.  
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.  
For all Board-approved pharmacy technician training programs, the cost of compliance will include the cost for  
accreditation. The cost of accreditation depends on the accreditor, the type of entity being accredited, as well as the  
number of sites being accredited. The cost is estimated at $3,500.00 annually for an educational site to $10,000.00  
annually for a chain pharmacy.  
No additional costs will be imposed on any businesses or groups.  
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.  
The estimated cost for submitting fingerprints for a background check by applicants is $30.00. The estimated cost for  
human trafficking training is zero as the training may be found online. The background check and training will  
benefit Michigan citizens by requiring an applicant for licensure to demonstrate that he or she is of good moral  
character and knowledgeable about human trafficking.  
A. How many and what category of individuals will be affected by the rules?  
The individuals affected are applicants for licensure, relicensure, and renewal.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The estimated cost for submitting fingerprints for a background check by applicants is $30.00. The estimated cost for  
human trafficking training is zero as the training may be found online. The background check and training will  
benefit Michigan citizens by requiring an applicant for licensure to demonstrate that he or she is of good moral  
character and knowledgeable about human trafficking.  
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result  
of the proposed rules.  
MCL 24.245(3)  
RIS-Page 9  
There are no cost reductions for businesses, individuals, groups of individuals, or governmental units as a result 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.  
The direct benefits of the proposed rules include: reducing the confusion of applicants who desire to apply as a  
pharmacy technician but do not understand the process; eliminating calls to the Department regarding processes of  
licensure and pharmacy technician training programs; eliminating the inconsistency in Board-approved pharmacy  
technician programs by requiring that they be accredited; increasing the quality of pharmacy technician training  
programs; reducing the time that a technician training program student may perform pharmacy technician duties  
without being fully licensed; reviewing Boar- approved pharmacy technician training programs and examinations  
more frequently; increasing the licensing requirements by requiring proof of good moral character; requiring  
applicants to take the human trafficking training; prohibiting applicants from taking the proficiency examination in  
lieu of continuing education courses and activities; reducing the confusion regarding the type of continuing education  
that is accepted by the Department; and allowing a pharmacy technician to assist in the final product verification.  
The indirect benefits of the proposed rules include: maintaining a better list of active Board-approved pharmacy  
technician training programs; increasing the quality of licensees; and increasing the ability of a licensee to identify a  
human trafficking situation.  
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The rules are not expected to have an impact on business growth or job creation.  
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.  
Pharmacies will disproportionately be affected by the proposed rules. There are no other individuals or businesses  
expected to be a disproportionately affected due to industrial sector, segment of the public, business size, or  
geographic 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.  
https://www.pharmacytimes.com/publications/issue/2006/2006-12/2006-12-6154  
https://www.ashp.org/Professional-Development/Technician-Program-Accreditation/Applying-for-Accreditation  
https://www.pharmacytimes.com/news/pharmacy-technician-license-requirements-by-state  
https://nabp.pharmacy/news/news-releases/ptcb-reports-record-number-of-pharmacy-technician-certification-  
candidates/  
https://nabp.pharmacy/news/news-releases/ashp-and-acpe-announce-new-commissioners-for-the-pharmacy-  
technician-accreditation-commission/  
https://nabp.pharmacy/wp-content/uploads/2016/07/08TF_Standard_Pharm_Tech_Educ_Training.pdf  
National Association of Boards of Pharmacy 2020 - Survey of Pharmacy Law  
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.  
There were no estimates made because the rules impact an individual licensee as well as an applicant for licensure.  
Alternative to Regulation  
35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
The rules are required by statute; there is no reasonable alternative to enacting the proposed rules.  
MCL 24.245(3)  
RIS-Page 10  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
There is no reasonable alternative 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 the rules are required by statute, private market-based systems cannot serve as an alternative. States regulate  
pharmacy technicians by statute, regulation, or both. Private market-based systems are not used for licensing and  
regulation. The licensing and regulation of pharmacy technicians are state functions, so a regulatory program  
independent of state intervention cannot be established. There are professional associations that establish criteria for  
membership as a pharmacy technician, but these professional organizations would provide the public with  
significantly less protection because membership in many of these organizations is voluntary. This means an  
individual who meets the membership requirements, but does not join one of the professional organizations, would  
be able to practice and there would be no way to ensure his or her competency or hold him or her accountable.  
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 the rules are specifically required by statute, there are no alternatives to the proposed rules that the agency  
could consider. 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.  
All instructions for licensure and the applications for pharmacy technician training programs are included in the  
applications and are also on the Department’s website. The proposed rules inform an applicant of the relicensing  
requirements when his or her license has lapsed and the requirements for renewal and continuing education.  
MCL 24.245(3)  
;