Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
MOAHR-Rules@michigan.gov  
REGULATORY IMPACT STATEMENT  
and COST-BENEFIT ANALYSIS (RIS)  
Agency Information:  
Department name:  
Education  
Bureau name:  
Superintendent of Public Instruction  
Name of person filling out RIS:  
Mary Fielding  
Phone number of person filling out RIS:  
517-241-6986  
E-mail of person filling out RIS:  
FieldingM@michigan.gov  
Rule Set Information:  
ARD assigned rule set number:  
2023-78 ED  
Title of proposed rule set:  
School Social Worker Certification Code  
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.  
School social workers are mental health professionals who offer specialized knowledge and skills as an integral part  
of school communities in their roles as essential members of multidisciplinary special education teams and providers  
of special education services. The Michigan Standards for the Preparation and Practices of School Social Workers,  
adopted by the State Board of Education on October 8, 2019, are modeled after the school social worker standards  
established in 2012 by the National Association for Social Workers. Development of the Michigan standards also  
included consideration of the 2015 educational policy and accreditation standards of the Council on Social Work  
Education. There are no rules or regulations promulgated by the federal government regarding the certification of  
school social workers.  
A. Are these rules required by state law or federal mandate?  
Rules regarding intermediate school district special education plans and regarding the qualifications of special  
education personnel are mandated by sections 1701 and 1703(1) of the revised school code. MCL 380.1701 and  
380.1703. The rulemaking authority of the state board of education under MCL 380.1703 was transferred to the  
superintendent of public instruction by Executive Reorganization Order 1996-7, MCL 388.994(2)(y). As defined in  
section 6(7) of the revised school code, MCL 380.6, special education personnel include school social workers.  
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.  
There is no applicable 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  
School social worker preparation and credentialing requirements vary widely among states. Some examples of  
requirements in the Great Lakes states (Illinois, Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania, and  
Wisconsin) include: Illinois, Indiana, Michigan, New York, Ohio, and Wisconsin require a master’s degree; Illinois,  
Indiana, Michigan, New York, Ohio, and Wisconsin require a master of social work (MSW) degree earned in a  
program accredited by the Council on Social Worker Education; Illinois, Michigan, Pennsylvania, and Wisconsin  
require specialized coursework that is outside of an MSW curriculum, including special education coursework;  
Illinois, Michigan, Pennsylvania, and Wisconsin require clinical practice hours that are specific to school social work;  
and all Great Lakes states require a social worker license issued by an agency that governs the social work profession  
and a school social worker credential issued by a state agency.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of  
the deviation.  
Some state education authorities allow individuals who hold only state-issued social worker licenses to work with all  
students in school settings and other states require additional training to work with students with disabilities. In  
Michigan, individuals who hold social work licenses issued by the Department of Licensing and Regulatory Affairs  
may practice social work in school settings but, in the judgment of Michigan education stakeholders and authorities,  
serving students with disabilities requires a set of specific knowledge and skills. Without training and credentialing  
beyond social worker training and licensure, individuals who provide social work services to students with disabilities  
whose individualized education programs (IEPs) require those services may not be equipped to meet the unique needs  
of those students. In the judgment of Michigan education stakeholders and authorities, requiring additional training  
and credentialing supports the commitment to meet the obligation under the federal Individuals with Disabilities  
Education Act (20 USC 1400 to 1482) to provide students with disabilities with free appropriate public education.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed  
rules.  
There are no laws, rules, or other legal requirements that duplicate, overlap, or conflict with the 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.  
There are no federal, state, or local laws applicable to the credential requirements for school social workers.  
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. 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 rules will provide a new credentialing system for school social workers. Data about school social workers  
(SSWs) for the last five school years are as follows.  
School year# districts that # SSWs# SSW credentials  
employed SSWsissued by the Department of Education  
_________________________________________________________  
2018-2019485 2108442  
2019-20204892294627  
2020-20215052437627  
2021-20225042622632  
2022-20235202811751  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
MCL 24.245(3)  
RIS-Page 3  
The proposed rules will replace the current “approval” system with a requirement that school social workers hold a  
valid school social worker credential. Based on data compiled from the Michigan Online Educator Certification  
System (MOECS) over the last five years, it is expected that 600 to 700 school social workers will obtain a school  
social worker credential annually as a result of promulgation of the proposed rules. The approximately 2,800 current  
school social workers for whom the Department of Education has issued an “approval” will receive an initial school  
social worker certificate at no cost.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
Currently, school districts apply for “approval” of individuals to work as school social workers. The responsibility for  
overseeing that process lies in the Department of Education’s Office of Special Education (OSE). The proposed rules  
will replace this system with a credentialing system under which a school social worker shall hold school social  
worker certification or shall work under a school social worker permit held by the school district. The Department of  
Education’s Office of Educator Excellence (OEE) will oversee that system. One goal is to recognize the complex,  
multifaceted profession of school social worker that is comparable to the professions of other certified educators  
whose credentialing systems are overseen by OEE. Currently, 10 providers of educator preparation programs have  
been approved to provide school social worker training and to recommend candidates for school social worker  
credentials.  
C. What is the desired outcome?  
The desired outcome is that school social workers will obtain school social worker credentials under the rules. The  
goals of the transfer of responsibility to oversee the credentialing system from OSE to OEE include ensuring the  
competence of school social workers, reducing the duplication of resources between OSE and OEE, creating  
consistencies in the credentialing process for all educators, and recognizing the expertise and training of school social  
workers.  
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.  
Currently, school districts apply for “approval” of individuals to work as school social workers. The proposed rules  
will replace this system with a credentialing system under which a school social worker may hold school social  
worker certification or may work under a school social worker permit held by the school district. This change will  
recognize the profession of school social worker as on par with the professions of other certified educators, will  
provide school social workers with the opportunity to hold portable certification, and will ensure adherence to  
standards for the preparation and practice of school social workers recently adopted by the State Board of Education  
and to continuing education requirements that seek to ensure that school social workers possess current information  
and training in the field of school social work. The standards adopted by the State Board of Education provide detailed  
guidance related to ethics and values for practice, assessment, intervention, evaluation, the pursuit of human rights and  
social and economic justice, interdisciplinary leadership and collaboration, and legal requirements and advocacy.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
As currently written, the rules reflect an antiquated system of “approval” of school social workers, providing no easily  
portable credential for school social workers and creating a perceived disparity between the professionalism of school  
social workers and that of other educators. The current rules also do not recognize that a school social worker is first  
and foremost a social worker and is therefore required to hold a valid social worker license issued by the Department  
of Licensing and Regulatory Affairs. Nor do the current rules reflect and recognize the professional learning in which  
school social workers engage to keep abreast of developments in their field and to maintain their skills.  
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 protect the health, safety, and welfare of Michigan students with disabilities by ensuring a  
reasonable level of qualifications and experience for school social workers, who provide social work services to  
students whose IEPs require social work services.  
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
R 340.1017 will be rescinded because its content will be added to new R 340.1002. R 340.1018 will be rescinded  
because it is an obsolete and unnecessary rescission rule.  
Fiscal Impact on the Agency  
MCL 24.245(3)  
RIS-Page 4  
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 fiscal impact on the Department of Education will include costs in an unknown amount associated with Attorney  
General representation of OEE in administrative hearings described in the proposed rules. The fiscal impact on the  
department will also include costs associated with modification of the MOECS to replace the “approval” process  
with the new credentialing system and to make routinely scheduled improvements. It is estimated that those costs  
will be approximately $260,000.00. No cost savings are anticipated.  
11. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
It is expected that the MOECS costs will be covered in the OEE and OSE annual budgets for system maintenance  
and upgrade. No additional appropriation or other funding is expected for 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 are necessary to replace the antiquated and inadequate “approval” system for school social  
workers. The proposed rules will require that an individual who provides social work services to students with  
disabilities whose IEPs require those services hold a school social worker credential under the rules or work under a  
school social worker permit held by the employing school district. Individuals applying for school social worker  
certification will apply using the MOECS. School districts will apply for school social worker permits, also using the  
MOECS. Currently, application evaluation fees for certificates and permits under MCL 380.1538 are $160.00 for  
initial educator certification and $45.00 for substitute permits.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable  
compared to the burdens.  
Some may argue that the rules impose a burden in requiring a new credential for school social workers instead of the  
currently required “approval.” Any such burden would be minimal and would be far outweighed by the benefits,  
which include the following.  
1.Recognition of the expertise, additional training, and professional learning required of school social workers.  
2.Inclusion of school social workers in the Department of Education’s credentialing system, replacing an antiquated  
and inadequate system of “approvals” issued to school districts.  
3.Decoupling credentialing and employment so that employment is not a requirement for credentialing and so that a  
school social worker will hold a readily recognizable, portable, professional credential.  
4.Enabling the Department of Education to gather data related to school social workers.  
5.Facilitation of the Department of Education’s ability to monitor school social workers for compliance with statutory  
requirements related to school safety.  
6.Dedication of Department of Education staff to support both school social worker credential applicants and holders  
and their employers.  
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.  
No increase or decrease in school district revenues is anticipated. School districts will be required to pay a nominal  
application evaluation fee for a school social worker permit. MCL 380.1538 currently sets the application evaluation  
fee for a substitute permit at $45.00.  
MCL 24.245(3)  
RIS-Page 5  
14. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
The proposed rules address the use of school social worker services by public schools, requiring certification or  
permitting of school social workers. Public schools will be required to apply for and pay a minimal fee for school  
social worker permits for individuals employed as school social workers who do not hold school social worker  
certificates.  
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.  
Public schools are now required to ensure that school social workers are “approved.” Under the proposed rules,  
public schools shall ensure that an individual providing school social work services holds valid school social worker  
certification or is working under a school social worker permit. It is anticipated that action necessary to be in  
compliance with the rules will be minimally burdensome.  
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 has been no appropriation to state or local government units and no funding source has been provided for  
additional expenditures, if any, associated with the proposed rules.  
Rural Impact  
16. In general, what impact will the rules have on rural areas?  
The rules’ impact on rural areas will not differ from their impact on non-rural areas.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
Public schools will be affected by the rules, as will individuals employed as school social workers.  
Environmental Impact  
17. Do the proposed rules have any impact on the environment? If yes, please explain.  
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 proposed rules do not apply to small businesses.  
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 proposed rules do not apply to small businesses.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on  
small businesses.  
The proposed rules do not apply to small businesses.  
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 proposed rules do not apply to small businesses.  
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 apply to small businesses.  
D. Describe how the agency established performance standards to replace design or operation standards required  
by the proposed rules.  
The proposed rules do not apply to small businesses.  
MCL 24.245(3)  
RIS-Page 6  
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 apply to small businesses.  
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 apply to small businesses.  
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.  
The proposed rules do not apply to 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.  
The proposed rules do not apply to small businesses.  
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
The proposed rules do not apply to small businesses.  
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 do not apply to small businesses.  
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The proposed rules do not apply to small businesses.  
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.  
Small businesses were not involved in the development of the proposed rules, which do not apply to small  
businesses.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
Small businesses were not involved in the development of the proposed 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 will be no statewide compliance costs of the rule amendments other than school districts’ payment of the  
application evaluation fee for school social worker permits. Currently, the application evaluation fee for a substitute  
permit is $45.00.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the  
proposed rules.  
School districts will be directly affected by and benefit from the proposed rules. School districts will be responsible  
for the cost of school social worker permit application evaluation fees.  
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.  
With the exception of application evaluation fees for school social worker permits no additional costs are expected to  
be imposed on school districts as a result of 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.  
MCL 24.245(3)  
RIS-Page 7  
The actual statewide compliance cost of the proposed rules on individuals will be the $160.00 certificate application  
evaluation fee. Based on data compiled from the Michigan Online Educator Certification System (MOECS) over the  
last five years, it is expected that 600 to 700 school social workers will obtain a school social worker credential  
annually as a result of promulgation of the proposed rules, with an estimated actual statewide compliance cost of  
between $96,000.00 and $120,000.00 for the initial certification of 600 to 700 school social workers. However, the  
cost may be less in the early years of implementation of the proposed rules because school social workers who are  
currently “approved” will receive an initial school social worker certificate at no cost. For certificate renewal (with  
an application evaluation fee of $160.00), school social workers will be required to complete 75 hours of education-  
related professional learning, opportunities for which include some continuing education that is offered at no cost. In  
addition, the proposed rules require that the applicant for a school social worker certificate hold a social work license  
issued by the department of licensing and regulation. Because continuing education required for renewal of a social  
work license will satisfy the continuing education requirements for renewal of a school social worker certificate, the  
holder of a school social worker certificate may incur no additional continuing education costs for renewal of the  
certificate.  
A. How many and what category of individuals will be affected by the rules?  
School social workers and individuals applying for certification as school social workers will be affected by the rules.  
There are approximately 2,800 currently employed individuals for whom the Department of Education has issued  
“approvals” as school social workers.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The proposed rules will recognize the profession of school social worker as on par with the professions of other  
certified educators, will provide school social workers with the opportunity to hold portable certification, and will  
ensure adherence to standards for the preparation and practice of school social workers recently adopted by the State  
Board of Education and to continuing education requirements that seek to ensure that school social workers possess  
current information and training in the field of school social work. With the exception of the 2,800 school social  
workers who are currently “approved,” individuals applying for school social worker certification will be charged the  
application evaluation fee of $160.00 for an initial school social worker certificate.  
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result  
of the proposed rules.  
No cost reductions are anticipated 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 primary and direct benefits of the proposed rules will include:  
1. Recognition of the expertise, additional training, and professional learning required of school social workers, of  
whom there are currently approximately 2,800 who hold “approvals” issued by the Department of Education.  
2. Decoupling credentialing from employment so that a school social worker will hold a readily recognizable,  
portable, professional credential.  
3. Enhanced ability of the Department of Education to gather data about school social workers, to monitor school  
social workers for compliance with statutory requirements related to school safety, and to dedicate staff to support  
school social worker credential applicants, school social worker credential holders, and their employers. In 2022-  
2023, 520 Michigan school districts employed school social workers.  
Secondary benefits of the proposed rules may include:  
1. Increased expertise of school social workers serving both students with disabilities whose IEPs require social work  
services and their families.  
2. Increased professionalism of special education personnel employed in public schools.  
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The proposed rules will not impact business growth in Michigan. It is unknown if the proposed rules will result in the  
employment of more individuals as school social workers 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.  
MCL 24.245(3)  
RIS-Page 8  
No individuals or businesses will be disproportionately affected by the rules as a result of their industrial sector,  
business size, or geographic location. If school social workers are considered a segment of the public, they will be  
disproportionately affected by the proposed rules, which create a system of certification of school social workers.  
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 Department of Education relied on data in the MOECS and on the websites of other state departments of  
education, including the following websites for Great Lakes states:  
Illinois:  
•National Association of Social Workers, Ilinois Chapter (https://www.naswil.org/ssw)  
•Illinois State Board of Education (https://www.isbe.net/Pages/PEL-School-Support-Ed-Lic.aspx)  
Indiana Department of Education (https://www.in.gov/doe/educators/educator-licensing/school-services-  
employee/#:~:text=To%20be%20a%20licensed%20school,approved%20school%20social%20worker%20program  
Minnesota:  
•Minnesota Board of Social Work (https://mn.gov/boards/social-work/applicants/applyforlicense/lsw.jsp)  
•Minnesota Professional Educator Licensing and Standards Board (https://mn.gov/pelsb/aspiring-  
educators/preparation-programs/related-services/)  
New York:  
•New York State School Social Workers’ Association (https://nyssswa.org/credentialing/school-social-work-  
certification/)  
•New York State Education Department (https://www.highered.nysed.gov/tcert/)  
Ohio State Department of Education (https://education.ohio.gov/getattachment/Topics/Teaching/Licensure/Apply-for  
-Certificate-License/Pupil-Services-Licenses/Social-Worker-Licensure-Considerations.pdf.aspx?lang=en-  
US#:~:text=Hold%20a%20master's%20degree%20from,of%20Higher%20Education%20approved%20graduate)  
Pennsylvania Department of Education (https://www.education.pa.gov/Educators/Certification/Staffing%  
20Guidelines/Pages/CSPG87.aspx#:~:text=A%20School%20Social%20Worker%20Educational,or%20an%  
20equivalent%20foreign%20qualification)  
Wisconsin Department of Public Instruction (https://dpi.wi.gov/sspw/pupil-services/school-social-work/licensing)  
The Department of Education also relied on a research article published in the July 2021 issue of the journal,  
Children & Schools (Volume 43, Issue 3, pages 167-174), entitled “Certification and Professional Preparation of  
School Social Workers, School Psychologists, and School Counselors,” by Brandon Mitchell, Andy Frey, and  
Michael S. Kelly. The article, which is available with access at http://academic.oup.com/cs/article/43/3/167/6319834,  
was provided to the Department of Education by a board member of the Michigan Association of School Social  
Workers, the web address of which is https://masswmi.site-ym.com.  
In August 2018, a group of stakeholders representing PK-12 schools, educator preparation programs, and  
professional organizations representing the school social worker community began meeting on a biweekly basis to  
revise the Michigan standards for the preparation of school social workers, with the intent to create a comprehensive  
credential system and to recognize the expertise of school social workers in providing services to students with  
disabilities. The credentialing of school social workers was an issue addressed by the stakeholder group. After  
seriously considering the application evaluation fee that would be imposed for school social worker certification (in  
the same amount imposed for teacher, school administrator, school psychologist, and school counselor certification  
or licensure), the stakeholder group strongly recommended that a system of school social worker certification replace  
the “approval” process. The recommendation reflected the stakeholder group’s determination that the benefits of  
upholding school social work as a profession and allowing school social workers to hold individual, portable  
MCL 24.245(3)  
RIS-Page 9  
certification outweighed the cost of the application evaluation fee. The school social worker standards proposed by  
the stakeholder group were presented to the State Board of Education on June 11, 2019, and there was a period for  
public comment through September 15, 2019. Comments were submitted by 70 individuals representing 22 counties  
and 39 school districts and intermediate school districts, including 36 school social workers, 20 school  
administrators, 4 preparation program representatives, 3 parents or citizens, and 1 professional organization  
representative. At its October 8, 2019 meeting, during which the goal to create a certification system for school  
social workers was discussed, the State Board of Education approved the revised standards.  
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.  
Estimates were made based on relevant data from the MOECS for recent school years.  
Alternative to Regulation  
35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
There is no reasonable alternative that would achieve the goals of the proposed rules.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
MCL 380.1703(1) requires rules regarding the qualifications of school social workers. Credentialing of educators is a  
matter of state law and there is no reasonable alternative that would achieve the goals of 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.  
Credentialing of educators is a matter of state law. No regulatory program operating through private market-based  
mechanisms is feasible.  
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.  
The proposed rules reflect the standards adopted by the State Board of Education based on the extensive involvement  
and input of a wide range of stakeholders. The stakeholder committee strongly recommended the implementation of  
a certification system for school social workers to replace the current “approval” system. The committee did not  
consider a significant alternative.  
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.  
There are no instructions regarding the method of complying with the rules under MCL 24.245b(1)(c).  
MCL 24.245(3)  
;