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:

Licensing and Regulatory Affairs

Bureau name:

Bureau of Professional Licensing

Name of person filling out RIS:

Steven Sundeen

Phone number of person filling out RIS:

517-241-4064

Email of person filling out RIS:

SundeenS@michigan.gov

RULE SET INFORMATION:

ARD assigned rule set number:

2025-62 LR

Title of proposed rule set:

Public Health Code – General Rules

COMPARISON OF RULE(S) TO FEDERAL/STATE/ASSOCIATION STANDARDS

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 license and registration renewals and other requirements

for licensure or registration. Consequently, there are no federal rules or standards set by a national or state agency to

which the proposed rules can be compared.

A. Are these rules required by state law or federal mandate?

The following state laws require rules:

MCL 333.16194 requires that the department prescribe the expiration dates for licenses and registrations for

health care professions.

MCL 333.16174 requires the department to establish the minimum standards for determining if an applicant for

licensure or registration has a working knowledge of the English language.

The rules are not federally mandated.

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 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 are largely

consistent with the requirements of other states in the Great Lakes region. All states in the Great Lakes region provide

for the length of a license or registration cycle and license or registration renewal dates.

MCL 24.245(3)

RIS-Page 2

The states in the Great Lakes region differ in their specific requirements for demonstrating a working knowledge of the

English language for licensure or registration, but all states in the Great Lakes region require testing to demonstrate a

working knowledge of the English language for most professions.

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

arising out of the deviation.

The rules requiring an applicant for licensure or registration to demonstrate a working knowledge of the English

language vary from state to state within the Great Lakes region. Michigan requires an applicant for licensure or

registration under the Michigan Public Health Code to demonstrate a working knowledge of the English

language, MCL 333.16174. This requirement benefits Michigan citizens by ensuring that a licensee or registrant

can communicate effectively with their patients or clients.

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.

There is no need to coordinate these rules with other federal, state or local laws because there are no federal,

state, or local laws applicable to the same activity or subject matter.

PURPOSE AND OBJECTIVES OF THE RULE(S)

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

R 338.7001a: The current rule pertains to licenses and registrations that expire and renew biennially. The proposed

changes to the rule remove nursing and speech language pathology from the rule as these license types are moving

to triennial expiration and renewal. The behavior and frequency this change is intended to alter is to permit these

licensees to renew their licenses every 3 years instead of every 2 years.

R 338.7002: The current rule pertains to licenses and registrations that expire and renew triennially. The proposed

changes to the rule add nursing and speech language pathology licenses to this rule as these license types are

moving to triennial expiration and renewal. Additionally, dietetics and nutrition is added to this rule to establish the

renewal date for this profession. The behavior and frequency this change is intended to alter is to permit these

licensees to renew their licenses every 3 years.

R 338.7002b: This is a rule advises an applicant for licensure or registration that they must demonstrate a working

knowledge of the English language in accordance with the minimum standard established by the department. This is a

statutory requirement, MCL 333.16174. This rule is designed to inform an applicant for licensure or registration of this

requirement and how to comply. The frequency of the behavior is not expected to change.

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

R 338.7001a: The frequency of the targeted behavior, license renewal, will decrease for nursing and speech

language pathology licenses because they will no longer be required to renew their licenses every 2 years.

Instead, they will be required to renew their license every 3 years.

R 338.7002: The frequency of the targeted behavior is that the license renewal date for dietetics and nutrition

will be established at 3 years.

R 338.7002b: There is no frequency of targeted behavior for this rule. This rule was changed only to include

clarifying language so that an applicant will understand that a score of 300 must be achieved on each part of

the Occupational English Test.

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

R 338.7001a: Currently, the nursing and speech language pathology professions have a 2-year license cycle.

The desired practice is that these professions will be changed to a 3-year license cycle.

MCL 24.245(3)

RIS-Page 3

R 338.7002: Currently, the dietetics and nutrition profession does not have a license or registration renewal

date assigned. The desired practice is that the changes to this rule will establish a 3-year license cycle for this

profession.

R 338.7002b: Currently, the existing rule language is unclear on whether an applicant must score 300 on each

part of the Occupational English Test. The desired practice is that an applicant must achieve a score of 300 on

each part. Clarifying language has been included so that this requirement is clear.

C. What is the desired outcome?

R 338.7001a: This rule provides for biennial license or registration renewal. The proposed changes to the rule

remove nursing and speech language pathology licenses from the rule as the license types are moving to a

triennial expiation and renewal. The desired outcome is that a licensee or registrant will be able to renew their

license less frequently, which will reduce the regulatory impact on the licensee.

R 338.7002: This rule provides for triennial license or registration renewal. The proposed changes to the rule

add dietetics and nutrition, nursing, and speech language pathology licenses to this rule to establish a triennial

expiration and renewal for these professions. The desired outcome is that a licensee or registrant will be able to

renew their license less frequently, which will reduce the regulatory impact on the licensee.

R 338.7002b: This rule advises an applicant for licensure or registration that he or she must demonstrate a

working knowledge of the English language in accordance with the minimum standards established by the

department. The desired outcome is that the applicant will have a clear understanding of how they must fulfill

this requirement.

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.

R 338.7001a: This rule provides for biennial license or registration renewal. The proposed changes to the rule remove

nursing and speech language pathology licenses from the rule as these license types are moving to triennial

expiration and renewal. The rule is designed to alter the frequency of renewal and to reduce the regulatory impact on

a licensee and registrants. If the rule is not changed, the licensee would be required to continue completing the

renewal application process every 2 years.

R 338.7002: This rule provides for triennial license or registration renewal. The proposed changes to the rule would

add dietetics and nutrition, nursing, and speech language pathology licenses to this rule as these license types are

either being established or moving to triennial expiration and renewal. The rule is designed to alter the frequency of

renewal and to reduce the regulatory impact on licensees and registrants. If the rule is not changed, the nursing or

speech language pathology licensee or registrant would be required to continue completing the renewal process

every 2 years. The dietetics and nutrition licensee will not have an established renewal date.

R 338.7002b: This rule advises an applicant for licensure or registration that they must demonstrate a working

knowledge of the English language in accordance with the minimum standards established by the department. The

proposed rule is designed to assist the applicant in complying with licensure or registration requirements by clarifying

the pass rate for the allowed exams.

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

R 338.7001a: The current rule pertains to licenses and registrations that expire and renew biennially. The

proposed changes to the rule remove nursing and speech language pathology licenses from the rule as these

license types are moving to triennial expiration and renewal. The rationale for changing the rule is that the

licensing cycle for these professions cannot be changed without changing the rule.

R 338.7002: The current rule pertains to licenses and registrations that expire and renew triennially. The

proposed changes to the rule would add dietetics and nutrition, nursing, and speech language pathology

licenses to this rule as these license types are either being established or moving to triennial expiration and

renewal. The rationale for changing the rule is that the licensing cycle for these professions cannot be changed

without changing the rule.

R 338.7002b: The rationale for adding this rule is to advise an applicant for licensure or registration that he or

she must demonstrate a working knowledge of the English language in accordance with the minimum standards

established by the department.

MCL 24.245(3)

RIS-Page 4

6. 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.

R 338.7001a: The current rule pertains to licenses and registrations that expire and renew biennially. The proposed

changes to the rule remove nursing and speech language pathology licenses from the rule as these license types are

moving to triennial expiration and renewal. The health, safety, and welfare of Michigan citizens is protected by

providing a beginning and end date to the license and registration length of health care professionals. This change in

the rule decreases the burden on licensees moving from a 2-year cycle to a 3-year cycle by eliminating the frequency

of completing the renewal process to reduce the regulatory impact on a licensee.

R 338.7002: The current rule pertains to licenses and registrations that expire and renew triennially. The proposed

changes to the rule add dietetics and nutrition, nursing, and speech language pathology licenses to this rule as these

license types are either being established or moving to triennial expiration and renewal. The health, safety, and

welfare of Michigan citizens is protected is protected by providing a beginning and end date to the license and

registration length of health care professionals. This change in the rule decreased the burden on licensees moving

from a 2-year cycle to a 3-year cycle by eliminating the frequency of completing the renewal process to reduce the

regulatory impact on a licensee.

R 338.7002b: This rule provides the minimum English language standard required for licensure or registration. The

proposed rule will protect the health, safety, and welfare of Michigan residents by ensuring that a licensee or

registrant can communicate effectively with a patient or client.

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

None of the rules in this draft rule set can be rescinded as they are necessary to communicate the licensure or

registration renewal dates for licensees. Additionally, the rule establishing minimum English language proficiency is

required by statute, MCL 333.16174.

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.

8. 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 department does not expect the implementation of the proposed rules to result in additional costs or savings for

the department.

9. 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.

10. 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.

R 338.7001a: The current rule pertains to licenses and registrations that expire and renew biennially. The proposed

changes to the rule remove nursing and speech language pathology licenses from this rule as these license types are

moving to triennial expiration and renewal. The proposed changes to the rule would not impose any new burden on

individuals.

R 338.7002: The current rule pertains to licenses and registrations that expire and renew triennially. The proposed

changes to the rule would add dietetics and nutrition, nursing and speech language pathology licenses to this rule as

these license types are either being established or moving to triennial expiration and renewal. The proposed changes

to the rules would not impose any new burden on individuals.

R 338.7002b: This rule provides the minimum English language standards required for licensure or registration. The

MCL 24.245(3)

RIS-Page 5

proposed amendments to the rule do not place a burden on the individual, it clarifies the minimum score requirements

for the approved tests.

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 new identified burdens in the proposed rules.

IMPACT ON OTHER STATE OR LOCAL GOVERNMENTAL UNITS

11. 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 decreases in revenues or costs to other state or local government units

because of the proposed rules.

12. 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, county, town,

village, or school district because 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 actions that the governmental units must take to comply with the proposed rules.

13. 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 because of these rules. No additional expenditures are

anticipated or intended with the proposed rules.

RURAL IMPACT

14. In general, what impact will the rules have on rural areas?

The proposed rules impose requirements on individual licensees and registrants regardless of where they live. Even if

a licensee’s or registrant’s workplace is in a rural area, the department could not vary the requirements based on their

location because it would create a disparity in the regulation of the professions governed by these rules.

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

There is no expected disparate impact on public or private interests in rural areas because of the proposed

rules.

ENVIRONMENTAL IMPACT

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

No, the proposed rules will have no impact on the environment.

SMALL BUSINESS IMPACT STATEMENT

16. 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.

17. 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

MCL 24.245(3)

RIS-Page 6

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 and registrants.

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

effect on small businesses.

It is estimated that no small businesses are affected by the proposed rules, so there is no probable effect on a

small business that can be identified.

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 and registrants. The rules were drafted to be the least

burdensome on all affected individuals.

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 and

there are no skills necessary to comply with reporting requirements because there are no reporting

requirements imposed on small business. 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.

18. 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 or registrant. Therefore, there is

no disproportionate impact on a small business because of its size or geographic location.

19. Identify the nature of any report and the estimated cost of its preparation by small businesses required to

comply with the proposed rules.

A small business is not required to prepare any report under the proposed rules, so it is estimated that a small

business will incur no cost in preparing a report to comply with the proposed rules.

20. Analyze the costs of compliance for all small businesses affected by the proposed rules, including costs of

equipment, supplies, labor, and increased administrative costs.

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 registrants and not small businesses.

21. 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.

22. 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.

23. 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.

If a rule exempted or set lesser standards for compliance by a small business, there would be no cost to the agency

for administering or enforcing that rule because the rules do not apply to a business of any size. The rules apply to

individuals practicing a health care profession in Michigan.

24. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small

businesses.

MCL 24.245(3)

RIS-Page 7

Licensure and registration of health care professions is required by statute. Statute also requires that the department

establish the length of a renewal cycle and the license or registration expiration date. Statute also requires that a

licensee or registrant demonstrate a working knowledge of the English language and that the department establish

the standards that the licensee or registrant must meet.

If the department could exempt or set lesser standards for small businesses employing a health care professional, it

would create a disparity in the regulation of health care professionals and would expose Michigan citizens to harm

from an unlicensed or unregistered person who has not demonstrated that they are qualified to render such care.

Ensuring that all businesses employ licensed or registered health care professionals is in the public’s best interest.

25. Describe whether and how the agency has involved small businesses in the development of the proposed

rules.

The department did not involve any small businesses in the development of the proposed amended rules.

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

No small businesses took part in the development of the rules.

COST-BENEFIT ANALYSIS OF RULES (INDEPENDENT OF STATUTORY IMPACT)

26. 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.

27. 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 the proposed rules impose no new actual statewide compliance costs on regulated individuals or

on the public.

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

All licensees and registrants are affected by the proposed rules as the rules provide for updated renewal cycles

and amended standards for demonstrating that the individual possesses a working knowledge of the English

language.

The citizens of Michigan will be affected by the rules because the proposed rules ensure that an applicant has a

working knowledge of the English language before being licensed or registered to facilitate better

communication.

However, the number of licensees that will be impacted by the changes to these rules are as follows:

Nurses: 209,176 licensees

Speech language pathologists: 7,071 licensees

Dietetics and Nutritionists: Unknown as this profession is not yet licensed.

Foreign Applicants: Unknown as the bureau does not have a way of determining how many foreign applicants

plan on seeking licensure in the state.

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

The qualitative impact on dietetics and nutrition, nursing, and speech language pathology licensees will be the

convenience of only having to complete the renewal process every 3 years instead of every 2 years which

reduces the regulatory impact on these licensees. It is anticipated that there will be no quantitative impact on

any licensees and registrants because they must already renew at the end of their renewal cycle. They must

already demonstrate a working knowledge of the English language to be licensed or registered.

MCL 24.245(3)

RIS-Page 8

The qualitative impact of the proposed rules on the citizens of Michigan will be that they can be ensured that the

licensed or registered health care provider will be able to effectively communicate with them in English while

delivering health care services. It is not anticipated that there would be any quantitative impact on the citizens

of Michigan as a result of the proposed rules because licensees and registrants must already maintain an active

license or registration and licensees and registrants must already demonstrate that they have a working

knowledge of the English language, so there is no new cost involved that may be passed along to patients or

clients.

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

result of the proposed rules.

There are no expected reductions in costs to businesses, individuals, groups of individuals, or governmental units

because of the proposed rules.

The costs for licensees will remain unchanged. The license renewal fees will remain the same: Nurses:

approximately $66.00 for each year of the license cycle; Speech Language Pathologists: approximately $83 for each

year of the license cycle.

Dietetics and nutritionists: the initial licensure fee will be approximately $240 for a 3-year license. The renewal fee will

be approximately $55 for each year of the license cycle.

Please note that while lengthening the license cycle increases the amount of money the licensee needs to pay upon

renewal, the cost per year will remain unchanged.

29. 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 any assumptions.

The qualitative primary and direct and secondary or indirect benefit of the proposed rules to nursing and speech

language pathology licensees will be the convenience of only having to complete the renewal process every 3 years

instead of every 2 years which reduces the regulatory impact on these licensees. For dietetics and nutrition, the

benefit is having an established renewal date. It anticipated that there will be no quantitative primary and direct and or

secondary or indirect benefit of the proposed rules to any licensees and registrants because they must already renew

at the end of their renewal cycle. They must already demonstrate a working knowledge of the English language to be

licensed or registered.

The qualitative primary and direct and secondary or indirect benefit of the proposed rules on the citizens of Michigan

will be that they can be ensured that the licensed or registered health care provider will be able to effectively

communicate with them in English in the delivery of health care services. It is not anticipated that there would be any

quantitative primary and direct or secondary or indirect benefit to Michigan citizens as a result of the proposed rules

because licensees and registrants must already maintain an active license or registration and demonstrate that they

have a working knowledge of the English language, so there are no new costs involved that may be passed along to

patients or clients.

30. 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.

31. 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 disproportionate effect on any individuals or businesses by their industrial

sector, segment of the public, business size, or geographical location.

32. 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.

Illinois:

Dietetics and Nutrition License Cycle: https://ilga.gov/commission/jcar/admincode/068/068012450D03100R.html

Nursing License Cycle: https://ilga.gov/commission/jcar/admincode/068/068013000A00400R.html

Speech Language Pathology License Cycle:

https://ilga.gov/commission/jcar/admincode/068/068014650000700R.html

Indiana:

Dietetics and Nutrition License Cycle: https://iga.in.gov/laws/2025/ic/titles/25#25-14.5-6

MCL 24.245(3)

RIS-Page 9

Nursing License Cycle: https://iar.iga.in.gov/code/2026/848/1#848-1-1-8

Speech Language Pathology License Cycle: https://iar.iga.in.gov/code/2026/880/1#880-1-3.1

Minnesota:

Dietetics and Nutrition License Cycle: https://www.revisor.mn.gov/rules/3250.0045/

Nursing License Cycle: https://mn.gov/boards/assets/Renewal_Licensure_FAQ_tcm21-356028.pdf

Speech Language Pathology License Cycle: https://www.revisor.mn.gov/statutes/cite/148.5191

New York:

Dietetics and Nutrition License Cycle: https://www.cdrnet.org/registration-maintenance

Nursing License Cycle: https://www.op.nysed.gov/professions/registered-professional-nursing/license-

requirements#:~:text=Your%20license%20is%20valid%20for,while%20your%20registration%20is%20expired

Speech Language Pathology License Cycle: https://www.op.nysed.gov/professions/speech-language-

pathology/continuing-education

Ohio:

Dietetics and Nutrition License Cycle: https://med.ohio.gov/for-licensees/miscellaneous-resources/dietetics-

nutrition#:~:text=The%20Ohio%20Board%20of%20Dietetics%20requires%20licensees,the%20practice%20of%20diet

etics%20every%20two%20years

Nursing License Cycle: https://nursing.ohio.gov/licensing-and-certification/renewal-schedule

Speech Language Pathology License Cycle: https://shp.ohio.gov/staying-licensed/renewal

Pennsylvania:

Dietetics and Nutrition License Cycle: https://www.pa.gov/agencies/dos/department-and-offices/bpoa/boards-

commissions/nursing/licensed-dietitian-nutritionist-licensure-snapshot

Nursing License Cycle: https://www.nurse.com/nursing-resources/lpn-license-renewal-guides/pennsylvania-lpn-

license-renewal-requirements/

Speech Language Pathology License Cycle: https://www.pa.gov/agencies/dos/department-and-offices/bpoa/boards-

commissions/speech-language-pathology-and-audiology/speech-language-pathologists-licensure-snapshot

Wisconsin:

Dietetics and Nutrition License Cycle:

https://dsps.wi.gov/Pages/Professions/Dietitian/Default.aspx#:~:text=Per%20Wis.,take%20the%20next%20available

%20examination.

Nursing License Cycle: https://docs.legis.wisconsin.gov/code/admin_code/n/2.pdf

Speech Language Pathology License Cycle: https://www.speechpathology.com/state-license-requirements/wisconsin

A. How were estimates made, and what assumptions were made? Include internal and external sources,

published reports, information provided by associations or organizations, etc., that demonstrate a need

for the proposed rules.

Since statute mandates the rules, no estimate was necessary.

ALTERNATIVE TO REGULATION

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

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

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

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

34. 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.

The rules are required by statute, so private market-based systems cannot serve as an alternative. The department is

charged with establishing the renewal dates for licensees and registrants. Private market-based systems cannot be

used for this purpose because they are not used for licensing or registration.

There are professional organizations that establish criteria for membership, but these organizations would provide the

MCL 24.245(3)

RIS-Page 10

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 that licensees and registrants would hold current, valid

licenses or registrations.

No other states in the Great Lakes region use a private, market-based system to license, register, or regulate licensed

and registered health care professionals.

Lastly, it is not feasible to establish a regulatory program similar to the proposed rules because state statute requires

that the department establish the date pertaining to the renewal of licenses and registrations regulated by the

Michigan Public Health Code, MCL 333.16194(1).

35. 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 rules pertaining to the expiration dates of licenses and registrations are required by the Michigan Public Health

Code, MCL 333.16194(1). 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

36. As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of complying with

the rules, if applicable.

The rules will explicitly inform licensees and registrants of renewal dates. The renewal information will be clearly listed

on the website and application for renewal.

An applicant for licensure or registration should determine how he or she will demonstrate a working knowledge of the

English language in accordance with the minimum standards established by the department.

MCL 24.245(3)