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:

Dena Marks

Phone number of person filling out RIS:

517-335-3679

E-mail of person filling out RIS:

MarksD1@michigan.gov

Rule Set Information:

ARD assigned rule set number:

2021-30 LR

Title of proposed rule set:

Veterinary Technician – 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.

Each state establishes its own requirements with respect to veterinary 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?

MCL 333.16145 requires the board to promulgate rules to specify the requirements for licenses, renewals,

examinations, and required passing scores.

The rules are not mandated by any constitutional provision.

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 proposed 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.

The proposed rules are consistent with the standards required by the Michigan Public Health Code, and the rules are

largely consistent with the requirements of other states in the Great Lakes region. Every state in the Great Lakes

region, except Minnesota, provides for the regulation of this profession.

A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of

the deviation.

Overall, the standards in the proposed rules do not exceed those of the other states in the Great Lakes region that

regulate the profession.

MCL 24.245(3)

RIS-Page 2

3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed

rules.

There are no other laws, rules, or other legal requirements that may duplicate, overlap, or conflict with these proposed

rules.

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.

No coordination is needed because there are no other applicable laws that regulate the areas addressed in the proposed

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.

MCL 24.232(8) does not apply.

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.

MCL 24.232(9) does not apply.

Purpose and Objectives of the Rule(s)

6. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.

MCL 24.245(3)

RIS-Page 3

Part 1: This part includes the definitions for terms used in the rule set. The proposed rule changes will add a

definition for “animal patient” and clarify other definitions for better reader understanding.

Part 2: This part pertains to approved veterinary technician training programs and the approved veterinary technician

examination. The proposed rules will relocate the substantive portion of R 338.4978 to this section and update the

standards for accrediting veterinary technicians training programs adopted by the American Veterinary Medical

Association’s Committee on Veterinary Technician Education and Activities. A proposed rule will add the board’s

approval and adoption of the Veterinary Technician National Examination for licensure. The proposed rules will

clearly identify the educational programs and examination required for licensure.

Part 3: This part pertains to the requirements for licensure. The proposed rules will clarify the requirements for

licensure by examination, amend the requirements for licensure by endorsement, and amend the requirements for

relicensure.

The amendments to the licensure by endorsement rule will require the applicant to disclose each license, registration,

or certification in a health profession or specialty issued by any other jurisdiction or entity and require the applicant to

demonstrate that no disciplinary proceedings are currently pending and that any prior sanction has been satisfied

before being licensed by endorsement. The proposed rule is intended to assist an applicant in becoming licensed by

endorsement and to ensure public safety.

The amendments to the relicensure rule will organize the requirements into an easy-to-use chart format. The proposed

rule will require the applicant to disclose each license, registration, or certification in a health profession or specialty

issued by any other jurisdiction or entity and require the applicant to demonstrate that no disciplinary proceedings are

currently pending and that any prior sanction has been satisfied before being relicensed. The proposed rule is

intended to assist an applicant in becoming relicensed and to ensure public safety.

Part 4: This part pertains to the requirements for license renewal and continuing education. The proposed rules will

clarify the date when continuing education is required for license renewal. The proposed rules will also advise that a

waiver of the continuing education requirement must be received by the department before the expiration date of the

license. It will also amend the “in-person” continuing education requirement to also permit those hours to be earned

using live, synchronous contact. The proposed rules are intended to assist an applicant in accumulating the continuing

education required for license renewal.

A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.

The frequency of use is not expected to change.

B. Describe the difference between current behavior/practice and desired behavior/practice.

MCL 24.245(3)

RIS-Page 4

Part 1: This part includes the definitions of terms used in the rule set. The current rule does not include a definition

for the term “animal patient,” and the proposed rule will add that definition. The desired result is better reader

understanding.

Part 2: This part pertains to approved veterinary technician training programs and the approved veterinary technician

examination. The proposed rules will relocate the substantive portion of current R 338.4978 to this section and update

the standards for accrediting veterinary technician training programs adopted by the American Veterinary Medical

Association’s Committee on Veterinary Technician Education and Activities. A proposed rule will add the board’s

approval and adoption of the Veterinary Technician National Examination for licensure. The proposed rules will assist

the applicant in identifying the educational programs and examination required for licensure.

Part 3: This part pertains to the requirements for licensure. The proposed rules will clarify the requirements for

licensure by examination, amend the requirements for licensure by endorsement, and amend the requirements for

relicensure. The proposed rules are intended to assist an applicant in becoming licensed or relicensed and to ensure

public safety.

Part 4: This part pertains to the requirements for license renewal and continuing education. The proposed rules are

intended to clarify the continuing education requirements and to assist the licensee in accumulating the continuing

education required for license renewal.

C. What is the desired outcome?

MCL 24.245(3)

RIS-Page 5

R 338.4971: This rule pertains to the definitions for terms used in the rule set. The proposed rules will clarify several

existing definitions and add a definition for “animal patient.” The desire outcome is increased reader understanding of

the terms used in the rule set.

R 338.4971a: This is a proposed new rule that will relocate the information pertaining to the board’s approval of

veterinary technician training programs currently located in R 338.4978. The proposed rule will organize the education

and examination information into a new part for ease of use and update the program accreditation information.

R 338.4971b: This is proposed new rule that will provide the board’s approval and adoption of the Veterinary

Technician National Examination for licensure. This approval and adoption is not in the current rule set.

R 338.4972: This rule pertains to licensure by examination. The rule will be revised for clarity.

R 338.4976: This rule pertains to licensure by endorsement. This rule will be revised for clarity and will require the

applicant to disclose each license, registration, or certification in a health profession or specialty issued by any other

jurisdiction or entity and require the applicant to demonstrate that no disciplinary proceedings are currently pending

and that any prior sanction has been satisfied before being licensed by endorsement. The proposed rule is intended to

assist an applicant in becoming licensed by endorsement and to ensure public safety.

R 338.4978: This rule pertains to the approval and adoption of veterinary technician training programs. This rule will

be rescinded for organization and the substance of the rule will be updated and relocated to Part 2 of the proposed rule

set, Education and Examination.

R 338.4982: This rule pertains to relicensure. The proposed amendments to this rule will organize the requirements

into an easy-to-use chart format. The proposed rule will require the applicant to disclose each license, registration, or

certification in a health profession or specialty issued by any other jurisdiction or entity and require the applicant to

demonstrate that no disciplinary proceedings are currently pending and that any prior sanction has been satisfied before

being relicensed. The proposed rule is intended to assist an applicant in becoming relicensed and to ensure public

safety.

R 338.4991: This rule pertains to license renewal and continuing education. The proposed rules will clarify the date

when continuing education is required for license renewal. The proposed rules will also advise that a request for

waiver of the continuing education requirement must be received by the department before the expiration date of the

license. The proposed rule is intended to assist an applicant in accumulating the continuing education required for

license renewal.

R 338.4993: This rule pertains to acceptable continuing education. The proposed rule will amend the “in-person”

continuing education requirement to allow those hours to be earned using live, synchronous contact. The proposed rule

is intended to assist an applicant in accumulating the continuing education required for license renewal.

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 6

Part 1: This part includes the definitions of terms used in the rule set. The proposed rule will add a definition for

“animal patient” and clarify other definitions. The rule is intended to provide better reader understanding and to avoid

confusion that may occur without the definitions.

Part 2: This part pertains to approved veterinary technician training programs and the approved veterinary technician

examination. The proposed rules include the board’s approval and adoption of the standards for accrediting veterinary

technician training programs adopted by the American Veterinary Medical Association’s Committee on Veterinary

Technician Education and Activities and the Veterinary Technician National Examination for licensure. The proposed

changes are intended to assist an applicant in determining which educational programs and examination have been

approved by the board and are required for licensure.

Part 3: This part pertains to the requirements for licensure. The proposed rules will clarify the requirements for

licensure by examination, amend the requirements for licensure by endorsement, and amend the requirements for

relicensure. The amendments to the licensure by endorsement and relicensure rules will require the applicant to

disclose each license, registration, or certification in a health profession or specialty issued by any other jurisdiction or

entity and require the applicant to demonstrate that no disciplinary proceedings are currently pending and that any

prior sanction has been satisfied before being licensed by endorsement or relicensed. The proposed changes are

intended to assist an applicant in becoming licensed or relicensed and to ensure public safety.

Part 4: This part pertains to the requirements for license renewal and continuing education. The proposed rules are

intended to clarify the continuing education requirements for license renewal. The proposed rules will advise a

renewal applicant of the requirements for continuing education and to assist the applicant in accumulating the

continuing education required for license renewal.

A. What is the rationale for changing the rules instead of leaving them as currently written?

Part 1: This part includes the definitions of terms used in the rule set. The proposed rule will add a definition for

“animal patient” and clarify other definitions. These changes cannot be accomplished without amending the rules.

Part 2: This part pertains to approved veterinary technician training programs and the approved veterinary technician

examination. The proposed rules provide for the board’s approval and adoption of the standards for accrediting

veterinary technician training programs adopted by the American Veterinary Medical Association’s Committee on

Veterinary Technician Education and Activities and the Veterinary Technician National Examination (VTNE) for

licensure. The updates to the accreditation standards for the training programs and the approval and adoption of the

VTNE cannot be accomplished without amending the rules.

Part 3: This part pertains to the requirements for licensure. The proposed rules will clarify the requirements for

licensure, amend the requirements for licensure by endorsement, and amend the requirements for relicensure. The

amendments to the licensure by endorsement rule and the relicensure rule will require the applicant to disclose each

license, registration, or certification in a health profession or specialty issued by any other jurisdiction or entity and

advise that the applicant must demonstrate that no disciplinary proceedings are currently pending and that any prior

sanction has been satisfied before being licensed by endorsement or relicensed. The proposed changes cannot be

implemented without amending the rules.

Part 4: This part pertains to the requirements for license renewal and continuing education. The proposed rules are

intended to clarify the continuing education requirements for license renewal. The proposed changes cannot be

accomplished without amending the 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.

MCL 24.245(3)

RIS-Page 7

The scope of practice of a veterinary technician means the practice of veterinary medicine based on less

comprehensive knowledge and skill than that required of a veterinarian and performed under the supervision of a

veterinarian, MCL 333.18805(1).

According to the Centers for Disease Control and Prevention, veterinary medicine contributes to public health in a

variety of ways, including ensuring that animals used in the food supply are free of disease, providing care for service

and companion animals, and ensuring that diseases carried by animals are not transmitted to humans.

To ensure that veterinary technicians are appropriately regulated in Michigan to provide veterinary services, the

following are the proposed changes to the rules:

Part 1: This part includes the definitions of terms used in the rule set. The proposed changes will ensure reader

understanding and compliance with the requirements of the rules.

Part 2: This part provides the information pertaining to approved veterinary technician training programs and the

approved veterinary technician examination. The proposed changes will ensure that an applicant has satisfied the

current educational and examination requirements for licensure.

Part 3: This part pertains to the requirements for licensure. The proposed changes will ensure that an applicant has

satisfied the current standards for licensure, licensure by endorsement, or relicensure.

Part 4: This part pertains to the requirements for renewal and the accumulation of continuing education credits. The

proposed changes will ensure that the applicant for license renewal has completed the necessary continuing education

from a board-approved activity to stay up-to-date in his or her education and training.

9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.

R 338.4978: This rule pertains to veterinary technician training programs approved by the board. This rule will be

rescinded and the substance of the rule relocated to new Part 2, the Education and Examination section, for

organization and clarity.

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 or a funding source provided because there are no 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.

MCL 24.245(3)

RIS-Page 8

Part 1: This part includes the definitions of terms used in the rule set. The rule helps ensure reader understanding

and compliance with the requirements of the rules. There is no additional burden on an individual as a result of the

proposed changes.

Part 2: This part provides the information pertaining to approved veterinary technician training programs and the

approved veterinary technician examination. There is no additional burden on an individual as a result of the

proposed changes.

Part 3: This part pertains to the requirements for licensure. The proposed rules will ensure that an applicant has

satisfied the current standards for licensure, licensure by endorsement, or relicensure. There is no additional burden

on an individual as a result of the proposed changes.

Part 4: This part pertains to the requirements for renewal and continuing education. The proposed rules are required

by statute and will ensure that the applicant for license renewal has completed the necessary continuing education

from a board-approved activity to stay up-to-date in his or her education and training. There is no additional burden

on an individual as a result of the proposed changes.

A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable

compared to the burdens.

There is no identified burden imposed by the proposed rules.

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 reductions for other 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, town, 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 the 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 the proposed 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 impose requirements on individual licensees. Even if a licensee’s home or workplace is located

in a rural area, the department could not change the requirements placed on an applicant or licensee based on where

the individual lives or works because it would create a disparity in the regulation of the profession.

A. Describe the types of public or private interests in rural areas that will be affected by the rules.

MCL 24.245(3)

RIS-Page 9

The public and private interests of ensuring that animals used in the food supply are free of disease, providing care

for service and companion animals, and ensuring that diseases carried by animals are not transmitted to humans do

not vary based on location.

While the practice of veterinary medicine in a rural area may differ from the practice in a non-rural area, the

regulation of this subfield of veterinary medicine would not affect public or private interests in a rural area differently

than it would affect those interests in a non-rural area.

Environmental Impact

17. Do the proposed rules have any impact on the environment? If yes, please explain.

The proposed rules do not have any impact on the environment.

Small Business Impact Statement

18. Describe whether and how the agency considered exempting small businesses from the proposed rules.

The department did not consider exempting small businesses because they are not impacted by the proposed rules.

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 rules cannot exempt small businesses because the rules do not directly regulate small businesses. The rules

regulate individual licensees.

A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on

small businesses.

There are approximately 3,348 veterinary technicians licensed in Michigan.

A licensee may work in a small business. However, 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 business differently because

the impact is to the individual licensee only.

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 individual licensees. The rules were drafted to be the least burdensome on all affected licensees.

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 for small businesses with the

proposed rules because the proposed rules do not impact small businesses.

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 do not impact small business. They impact an individual licensee. Therefore, there is no

disproportionate impact on a small business because of its size or geographic location.

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 affect individuals applying for licensure and renewal, regardless if they practice in a small

business. There is no separate cost to a small business.

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.

MCL 24.245(3)

RIS-Page 10

There are no expected costs for equipment, supplies, labor, or administrative costs that a small business would incur

in complying with the proposed rules.

The rules impact licensees and not small 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.

There are no expected costs for legal, consulting, or accounting services 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 rather than a small business. 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.

Therefore, there is no cost to the agency for administering or enforcing the rules because exempting or setting lesser

standards of compliance for a small business 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 proposed rules impose requirements on individual licensees rather than a small business. 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. 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 the Michigan Board of Veterinary Medicine in the development of the proposed rules.

The board is composed of professional and public members.

A. If small businesses were involved in the development of the rules, please identify the business(es).

No small businesses were involved in the development of the rules.

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 estimated compliance costs with these rule amendments on businesses or groups.

A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the

proposed rules.

No businesses or groups will be directly affected or benefitted by the proposed rules. No additional costs will be

imposed on any businesses or groups.

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.

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.

It is estimated that there will be no new compliance costs imposed on individuals as a result of the proposed rules.

A. How many and what category of individuals will be affected by the rules?

All licensees and applicants are affected by the proposed rules.

B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?

MCL 24.245(3)

RIS-Page 11

There is no qualitative or quantitative impact on individuals as a result of the proposed rules.

30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result

of the proposed rules.

There are no cost reductions to 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 proposed rules use clear, concise language, and implement the statutory requirements for licensing. The clear,

concise language allows the public, applicants, and licensees to better understand the requirements for licensure and

renewal.

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, job creation, or job elimination in Michigan.

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 individuals or businesses to be disproportionately impacted by the rules as a

result of their 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.

The Centers for Disease Control and Prevention:

https://www.cdc.gov/mmwr/preview/mmwrhtml/su5502a4.htm#:~:text=The%20veterinary%20profession%

20contributes%20to%20improvement%20of%20human,helping%20manage%2021st%20century%20public%

20health%20challenges%20%283%2C4%29

National Association of Veterinary Technicians in American: National Association of Veterinary Technicians in

America (navta.net)

Illinois: https://www.ilga.gov/commission/jcar/admincode/068/06801505sections.html; 225 ILCS 115/ Veterinary

Medicine and Surgery Practice Act of 2004. (ilga.gov)

Indiana: PLA: Veterinary Technician Registration Application & Instructions; PLA: Statutes & Rules (in.gov)

Kentucky: The Practice Act (kybve.com); The Practice Act (kybve.com)

Minnesota: Home (mvma.org)

New York: http: NYS Veterinary Technician: License Requirements (nysed.gov); NYS Veterinary Medicine: Laws,

Rules & Regulations (nysed.gov)

Ohio: Veterinary Tech (ohio.gov)

Pennsylvania: Veterinary Technician Licensure Requirements Snapshot (pa.gov); Board Laws and Regulations

(pa.gov)

Wisconsin: DATCP Home Veterinary Technician Certification Application Process (wi.gov)

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 the rules are required by statute, no estimates were made.

Alternative to Regulation

MCL 24.245(3)

RIS-Page 12

35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.

Since the rules are required by statute, there are no reasonable alternatives to the proposed rules.

A. Please include any statutory amendments that may be necessary to achieve such alternatives.

Since the rules are required by statute, a statutory change would be needed to provide an alternative.

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. The licensing

and regulation of veterinary technicians are state functions, and states regulate veterinary technicians by statute,

regulation, or both. Private market-based systems are not used for licensing and regulation.

There are professional organizations that establish criteria for membership, but these 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 their competency or hold them 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.

The instructions for compliance are included in the rules.

MCL 24.245(3)