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These rules for the registration and amendment of vital records are largely derived from the 2011 Model Vital
Statistics Act and Regulations and previous versions published in 1992 and earlier. Model statutory and regulatory
language is periodically developed by committees representing state jurisdictions and the federal government.
Deviations from the model reflect differences in state law, such as the time periods required for the registration of
births and deaths, or the circumstances requiring creation of a new birth certificate, for example. There are 57 vital
statistics reporting systems in the US: the fifty states, five territories, Washington, DC, and New York City. Locally,
Ohio, Indiana, and Ilinois have comparable vital statistics laws and procedures to Michigan, but for differing
timeframes for recordation and compliance with processes.
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of
the deviation.
These proposed rules do not exceed standards in other states, but rather implement different standards insofar as they
are required by state law.
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed
rules.
We are not aware of any laws, rules, or other legal requirements that may duplicate, overlap, or conflict with these
proposed rules. The proposed rules are amendments to longstanding rulesets that have not historically demonstrated
such conflicts.
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.
The proposed rules are amendments to longstanding rulesets that implement the statewide system of vital records and
statistics in Michigan and its relationships at the local, state, and federal level. The proposed amendments were
developed in conversations with local registrars, agency subject matter experts, and colleagues in other states.
Purpose and Objectives of the Rule(s)
4. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.
The proposed rules provide requirements and procedures for the amendment of vital records documents, including
birth, death, and fetal death. These vital events occur daily in Michigan, including over 100,000 births and deaths per
year, more than 50,000 marriages, and 25,000 reports of divorce in recent years. Changes or amendments to records
are most common with birth certificates and include establishments of paternity, name changes, adoptions, changes to
sex designation, among others. Changes to death records are not as frequent but do occur periodically, while changes
to fetal death records are rare. Marriage and divorce records must be amended by the issuing county clerk or court,
respectively.
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.
The frequency of occurrence of vital events, including births, deaths, marriages, divorces, and acknowledgements of
paternity are not expected to change because of these proposed rules.
B. Describe the difference between current behavior/practice and desired behavior/practice.
Proposed rules are amendments to longstanding rulesets. Amendments to these rules include language to describe the
use of electronic systems to replace paper-based vital records registration. Other changes include clarifying eligibility
to request changes to vital records by defining next of kin, and clarifying the evidence needed to request
administrative changes for simple corrections such as spelling of names.
C. What is the desired outcome?
Adoption of these proposed rules will provide additional clarity to the public for eligibility and requirements for
changes to vital records documents. As vital records, particularly birth and death certificates, have become increasingly
relied upon as sources of identity and are used to obtain government and private benefits, the need to ensure the
integrity of the information on these records has increased. The ultimate desired outcome is increased trust in the
integrity and validity of vital records documents by ensuring only eligible people are able to request changes that are
supported by sufficient evidence.
5. 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)