receive their supervision in Michigan would also likely
be ineligible for licensure in other states because their
supervisor would not meet the qualifications in the state
to which the counselor is moving.
On behalf of MMHCA I would also like to provide
comment on the regulatory impact statement that has been
submitted for the record. We have numerous provisions of
this statement woefully lacking in proper disclosure.
DONALD AMIDON: I'm Dr. Donald Amidon,
A-M-I-D-O-N, and I'm speaking on behalf of MMHCA.
The Question Number 2 was compare the proposed
rule standards in similarity situated states based on
geographic location, topography, natural resources,
commonalities, or economic similarities. LARA's staff
claims that Michigan's proposed rule standards for
counselors are like other Great Lake states; in essence,
Illinois, Indiana, Minnesota, New York, Ohio,
Pennsylvania, and Wisconsin. However, Indiana,
Minnesota, and Ohio explicitly include the ability to
diagnose in their scope of practice for counselors, along
with 30 other states in the country, while Illinois,
New York, Pennsylvania, and Wisconsin use such terms such
as identify, evaluate, that clearly implies diagnosis.
Number 3 states identify any laws, rules, and
other legal requirements that may duplicate, overlap, or