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STATE OF MICHIGAN  
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
BUREAU OF PROFESSIONAL LICENSING  
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PUBLIC HEARING  
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FRIDAY, JULY 25, 2025  
AT ABOUT 9:00 A.M.  
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OTTAWA BUILDING  
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611 WEST OTTAWA STREET, UL-5  
LANSING, MICHIGAN  
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RE: Occupational Therapy - General Rules  
(MOAHR #2024-25 LR)  
Pharmacy - Pharmacist Continuing Education  
(MOAHR #2024-29 LR)  
Physical Therapy - General Rules  
(MOAHR #2023-53 LR)  
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HEARING FACILITATOR:  
WESTON MacINTOSH  
Bureau of Professional Licensing  
611 W. Ottawa Street  
Lansing, Michigan 48909  
22 ALSO PRESENT: Kerry Przybylo  
Steve Sundeen  
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25 REPORTED BY: Lori Anne Penn, CSR-1315  
Penn Reporting, LLC - lori.penn@yahoo.com  
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I N D E X  
2 Opening Statement - Weston MacIntosh  
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4 COMMENTS:  
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Craig Miller - Physical Therapy  
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7 Closing Statement - Weston MacIntosh  
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Lansing, Michigan  
Friday, July 25, 2025  
At 9:00 a.m.  
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(Public hearing commences pursuant to due notice.)  
MR. MacINTOSH: Good morning. My name is  
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Weston MacIntosh, and I'm a Departmental Specialist for  
the Bureau of Professional Licensing in the Department of  
Licensing and Regulatory Affairs, and I will be  
conducting the hearing today.  
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This is a public hearing on the proposed  
administration rules titled "Occupational Therapy -  
General Rules", "Pharmacy - Pharmacist Continuing  
Education", and "Physical Therapy - General Rules". We  
are conducting this hearing under the authority of the  
Administrative Procedures Act, Public Act 306 of 1969, on  
behalf of the Department of Licensing and Regulatory  
Affairs, Bureau of Professional Licensing.  
We are calling this hearing to order at  
9:00 o'clock a.m. on July 25, 2025, in UL-5 at 611 West  
Ottawa Street, Lansing, Michigan. Publication of the  
notice of public hearing was in three newspapers of  
general circulation, including the Flint Journal on  
June 6, 2025, the Grand Rapids Press on June 10, 2025,  
the Escanaba Daily Press on July 5, 2025, as well as the  
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Michigan Register, Issue #12, published on July 15, 2025.  
We are here today to receive your  
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comments on the proposed rules. If you wish to speak,  
please make sure you have signed in and said that you  
wish to speak. You may use the cards supplied for this  
purpose. I will organize the cards by rule set so that  
the comments for that profession are in a group together  
in the transcript. If you would like to testify and have  
not signed in, please do so now. For those of you who do  
not wish to sign in with a card, you may speak once we  
have exhausted the stack of cards that you give to me.  
If you have comments, please make sure  
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that they relate directly to the proposed rules. If you  
have questions about the rules, please include your  
questions as part of your testimony for the Department's  
review. If you have suggested changes to the proposed  
rules, please include the specific reasons why the  
changes would be in the public interest.  
For the record, when you testify, please  
give us your name by spelling your name and the  
organization, if any, that you may be speaking for today.  
This will help the Department prepare the hearing record  
that will go before the Boards. You can give written  
statements directly to me at the table. The Department  
will also accept written statements emailed or postmarked  
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until 5:00 o'clock p.m. today.  
The Department staff from the Bureau of  
Professional Licensing also includes Kerry Przybylo and  
Steven Sundeen.  
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The first rule set that we will take  
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comments for are the "Occupational Therapy - General  
Rules". Is there anyone who wishes to speak on the  
"Occupational Therapy - General Rules"?  
Hearing none. The second rule set that  
we'll take comments for is the "Pharmacy - Pharmacist  
Continuing Education". Is there anyone who wishes to  
speak on the "Pharmacy - Pharmacist Continuing  
Education"?  
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Hearing none. The third rule set that  
we'll take comments for are the "Physical Therapy -  
General Rules". So the first card that we have for that  
profession is from Craig Miller.  
MR. MILLER: Thank you. My name is Craig  
Miller, it's C-r-a-i-g M-i-l-l-e-r. I'm a physical  
therapist in Michigan. I appreciate the opportunity to  
comment. I did submit written comments, so I will  
truncate my verbal comments to stay within the time  
limits.  
I wanted to make clear at the getgo that  
while I am a member and the current chair of the Michigan  
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Board of Physical Therapy and a member of the Board of  
Directors for the Federation of State Boards of Physical  
Therapy, I am not providing these comments on behalf of  
either of those Boards, rather as a constituent and  
licensed physical therapist in Michigan. I received my  
degree in physical therapy from Wayne State in 1994, and  
have been continuously licensed in Michigan since 1995.  
The primary focus of my comments relates  
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to the proposed removal of the jurisprudence examination  
as this is a proposal that I am not in favor of,  
especially as there is no alternative proposed in its  
place.  
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The principal tenet of the Public Health  
Code and the Rules is to protect the public. The  
regulatory impact statement has a potential flaw, which  
is that the question asked in the impact statement is  
whether the proposed rules exceed that of other  
jurisdictions, however, for public protection, it should  
also be examined whether the proposed rules significantly  
undercut a level of safety. The proposed removal of the  
jurisprudence examination would be an example of this.  
While the impact statement correctly  
points out that some jurisdictions don't have a  
jurisprudence examination, what is missed is that all but  
one has a continuing education requirement related to  
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jurisdictional laws and rules on the practice of physical  
therapy. The only jurisdiction that deviates from this  
is New York state, but New York state does provide on its  
state website a self-study on jurisprudence that scores  
the outcome and provide the answers with references to  
the rationale for correct answers; so there's some form  
of jurisprudence requirement in all those Great Lakes  
states, some are both at initial licensure and renewal.  
Removing the jurisprudence requirement in Michigan would  
place Michigan at the lowest level as compared to the  
other states.  
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Michigan is also the only jurisdiction in  
the U.S. that allows for endorsement of Canadian  
physiotherapists and assistants. LARA does not currently  
report how many licensees have been endorsed through this  
route. The province of Ontario, as note, requires a  
jurisprudence assessment for initial licensure and at  
renewal.  
CAPTE, the Commission on Accreditation of  
Physical Therapy Education, does have a standard that  
indicates programs are to provide education on  
jurisdiction laws and rules, but it's applicable to the  
jurisdiction of the program. It's not reasonable to  
expect CAPTE programs outside of Michigan to adequately  
train on our laws and rules in Michigan. The Board  
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currently does not report the number or percent of  
licensees receiving their PT/PTA training outside of  
Michigan.  
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Non-CAPTE programs for non-U.S. training  
PTs and PTAs has no expectation for training on the laws  
and rules in Michigan. According to a 2024 practice  
analysis by the FSBPT, between 15 to 16% of the PT  
licensees in Michigan graduated from non-CAPTE programs.  
Without a jurisprudence requirement in some form, these  
individuals would have never been required or given as a  
component of their education information on the laws and  
rules governing PT practice in Michigan.  
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Public meetings were held by the PT rules  
committee as well as the Michigan Board of PT in 2024 and  
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for removal of the jurisprudence examination; both  
meetings resulted in the same recommendation from the  
Board and the committee, which was to not remove the  
jurisprudence examination, with a carveout for those  
submitting for relicensure in cases where the license had  
lapsed for no more than three years.  
There seems to be nominal, if any, burden  
on an applicant; as the impact statement notes, the cost  
is $53, and candidates can take the exam as many times as  
needed to pass. Should there be burdens due to the  
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testing process, that should be looked at to determine  
potential options such as an online Jurisprudence  
Assessment Module as used in several U.S. jurisdictions,  
including Ohio, or some other alternatives to demonstrate  
competency, that would seem to be indicated.  
I do have another consideration there  
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regarding the PDR credits, but that's in my written  
testimony or comments.  
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With that being said, I'm sincerely  
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grateful for the time allowed to express these points.  
In summary, it would seem more consideration on removing  
the jurisprudence exam is needed. Removing it eliminates  
the one method in establishing a minimal competency in  
knowledge of the laws and rules governing the practice of  
physical therapy in Michigan. I accept that there's  
evidence addressing the need for accessibility to  
healthcare, barriers to licensure are not necessarily  
warranted, however, the Public Health Code's preeminent  
position is that of protecting the public and to  
significantly provide assurance to Michiganians and  
Michiganders as to the adequacy of physical therapy  
providers' knowledge of the laws and rules is of the  
utmost importance. Thank you.  
MR. MacINTOSH: Thank you, Craig.  
Is there anyone else who wishes to speak  
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on the "Physical Therapy - General Rules"?  
Hearing none. If there are no other  
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people who wish to speak on the rules at this time, we'll  
take a short recess.  
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(Recess from 9:09 a.m. until 9:25 a.m.)  
MR. MacINTOSH: So we're back on the  
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record. One more check, is there anyone else who wishes  
to speak on either the "Occupational Therapy", the  
"Pharmacy - Pharmacist Continuing Education", or the  
"Physical Therapy - General Rules"?  
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Hearing none. If there no further  
comments at this time, I hereby declare the hearing  
closed. The record will remain open until today at 5:00  
o'clock p.m. for any other comments you may wish to share  
about the proposed rules. Thank you for coming.  
(Public hearing concluded at 9:26 a.m.)  
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1 STATE OF MICHIGAN )  
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2 COUNTY OF MACOMB )  
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I, Lori Anne Penn, certify that this  
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transcript consisting of 11 pages is a complete, true,  
and correct record of the public hearing held in the  
captioned matters on Friday, July 25, 2025.  
I further certify that I am not  
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responsible for any copies of this transcript not made  
under my direction or control and bearing my original  
signature.  
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I also certify that I am not a relative  
or employee of or an attorney for a party; or a relative  
or employee of an attorney for a party; or financially  
interested in the action.  
July 28, 2025  
_________________ _____  
Date  
Lori
Notan  
My Commission Expires June 15, 2031  
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