The proposed SUD Administrative Rules provide clarity for providers and recipients, ensure that SUD service
programs comply with industry and licensing standards, and set forth minimum criteria for delivery of these services
to protects residents. The proposed rules help to ensure that recipients and residents in Michigan who are seen by
licensed health professionals and licensed counselors in a wide variety of physical settings are able to achieve
consistent, repeatable, and standardized care that protects their safety and rights while receiving treatment. Any
burdens or duplicative acts may stem from the licensure of a facility that also employs separately licensed
individuals, but this burden is minimal to the overall benefits for recipients and citizens. Facility licensure containing
licensed individuals is already used under the current SUD Administrative Rules, is used with other health facilities
such as hospitals, nursing homes, and surgical facilities, and doesn’t extend any burden or duplicity beyond the
current practice. This regulatory process helps assure recipient care and safety is provided during the delivery of
important and needed health care services.
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable
compared to the burdens.
There are no identified burdens.
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
There are no anticipated increases or decreases to revenue for other state or local governmental unit. The SUD
licensure remains a voluntary, service-driven licensure, meaning those entities not providing treatment or care are not
required to seek licensure. Government entities that provide SUD services are not required to obtain licensure from
LARA. A reduction in cost is likely to be seen by many SUD licensees because of the addition of branch locations
that can be licensed under the parent location, the reduction in the frequency of drug testing for methadone programs,
and the addition of limited certified counselors that can be licensed to provide counseling services. These changes
may result in lower cost for procedures and staffing.
14. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school
district by the rules.
There are no programs, services, duties, or responsibilities imposed on the entities named.
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 programs, services, duties or responsibilities imposed on the entities named.
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.
There is no appropriation to state or local government required.
16. In general, what impact will the rules have on rural areas?
The proposed rules affect the State of Michigan as a whole by establishing statewide minimum standards for all SUD
services program licensees. Research suggests a need for more SUD service providers in Michigan’s rural areas. The
revised regulations, such as the deregulation of buprenorphine services and the inclusion of clinically managed
residential withdrawal management services, could foster an environment in which it is easier for these programs to
function, in turn, expanding access to SUD services.
A. Describe the types of public or private interests in rural areas that will be affected by the rules.
These revised rules will ameliorate any unnecessary regulatory obstacles to establishing SUD programs throughout
Michigan, but these changes will be especially impactful in rural areas.