Part 1 General Provisions: The current rules provide definitions for terms used in the rule set, but the definitions rule
does not reference terms defined in the Public Health Code. Without the rule change, the reader may not understand all
of the terms used in the rules.
Part 2 Licensure: The current rules pertain to the requirements for training standards for identifying victims of human
trafficking, licensure, licensure by endorsement, relicensure, and license renewal. The proposed rules will assist an
applicant for licensure or renewal in meeting this training requirement because the date of compliance will be
clarified. The proposed rules will also add references to other administrative rules that impose requirements on an
applicant for licensure or renewal, such as demonstrating proficiency in the English language and completing implicit
bias training, to assist an applicant in meeting all requirements for licensure or renewal. The proposed rules will
amend the licensure by endorsement rule to add the requirements for a Canadian-licensed applicant to assist the
applicant in becoming licensed and require an 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 rules will assist an applicant in determining if he or she satisfies all of the
requirements for licensure. Without the proposed changes, an applicant will be unable to determine if he or she
satisfies all applicable requirements for licensure, relicensure, or license renewal.
Part 4 Continuing Education: The current rules pertain to the accumulation of continuing education and approved
continuing education. The proposed rules will clarify that holding a Board of Certification (BOC) certification during
each year of the renewal cycle satisfies the continuing education requirements for renewal. As currently written, the
rule has caused confusion to licensees by referencing the number of credits that could be earned if the licensee holds
the BOC certification for less than the full 3-year cycle. By removing any reference to the continuing education
credits earned by holding the BOC certification for each year that the BOC certification is held and including the BOC
approved programs as an activity that earns the credits approved by the BOC in activity code “b,” licensees should
have a better understanding on how continuing education credits from BOC certification or by attending BOC
programs are earned.
Part 5 Delegation and Adoption by Reference of Professional Standards: The current rule pertaining to delegation and
supervision requirements incorrectly imposes a duty to supervise another licensee when the act, task, or function falls
within the licensee’s scope of practice. The proposed rule will remove this duty because the licensee performing an
act, task, or function within his or her own scope of practice is not a delegatee, and no supervision by the athletic
trainer would be necessary. As written, this rule may be causing confusion.
A. What is the rationale for changing the rules instead of leaving them as currently written?
Part 1 General Provisions: The proposed rules are necessary to provide information pertaining to words used in the
Part 2 Licensure: The current rules pertain to the requirements for licensure, licensure by endorsement, relicensure,
and license renewal. The proposed rules are intended to comply with statutory changes, ensure that a licensee is
aware that requirements in other rules must be satisfied, and to ensure public safety by verifying that an applicant’s
health professional credentials are not subject to current sanctions.
Part 4 Continuing Education: The current rules pertain to the requirements for accumulating continuing education
credits. The proposed rules are intended to clarify the credits earned by holding a BOC certification for the entire
renewal cycle and those earned by taking BOC courses if the BOC certification was held for less than the full 3 years
of the renewal cycle. This cannot be accomplished without changing the rules.
Part 5 Delegation and Adoption by Reference of Professional Standards. The current rule pertaining to delegation is
stated incorrectly. No delegation is needed if the duty to be performed is already within a licensee’s scope of practice.
This cannot be corrected without amending the rule.
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.