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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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MONDAY, APRIL 22, 2019  
AT ABOUT 1:00 P.M.  
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G. MENNEN WILLIAMS BUILDING AUDITORIUM  
525 W. OTTAWA STREET  
LANSING, MICHIGAN  
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RE: Athletic Trainers - General Rules (ORR 2018-062 LR)  
Barbers - General Rules (ORR 2018-065 LR)  
Psychology - General Rules (ORR 2018-107 LR)  
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HEARING FACILITATOR:  
WESTON MacINTOSH  
Bureau of Professional Licensing  
611 W. Ottawa Street  
Lansing, Michigan 48909  
21 ALSO PRESENT: Dena Marks  
Kerry Przybylo  
Rick Roselle  
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Stephanie Wysack  
REPORTED BY: Lori Anne Penn, CSR-1315  
33231 Grand River Avenue  
Farmington, Michigan 48336  
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I N D E X  
2 Opening Statement - Weston MacIntosh  
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4 COMMENTS:  
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Tracey Covassin - Athletic Trainers  
Frances Brown - Psychology  
Dennis Kayes - Psychology  
Jason Moser - Psychology  
Eric Ozkan - Psychology  
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11 Closing Statement - Weston MacIntosh  
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Lansing, Michigan  
Monday, April 22, 2019  
At 1:00 p.m.  
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MR. MacINTOSH: My name is Weston  
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MacIntosh and I'm an analyst for the Bureau of  
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Professional Licensing in the Department of Licensing and  
Regulatory Affairs, and I will be facilitating the  
hearing today.  
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This is a public hearing on proposed  
administrative rules entitled "Athletic Trainers-General  
Rules", "Barbers-General Rules", and "Psychology-General  
Rules". The hearing is being conducted 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.  
The hearing is being called to order at  
1:00 o'clock p.m. on April 22, 2019, at the G. Mennen  
Williams Building Auditorium located at 525 West Ottawa  
Street in Lansing, Michigan. The notice of public  
hearing was published in three newspapers of general  
circulation, as well as the Michigan Register, Issue No.  
5, published on April 1, 2019.  
We are here today to receive your  
comments on the proposed rules. If you wish to speak,  
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please make sure you have signed in and indicated your  
willingness to speak. You may use the cards provided in  
the lobby for this purpose. I will organize the cards by  
rule set so that the comments for that profession will be  
grouped 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 with a card, you may  
speak at the microphone once we have exhausted the stack  
of cards submitted to me.  
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If you have comments, please make sure  
that they relate directly to the proposed rules. If you  
have questions regarding the rules, please submit 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  
identify yourself by spelling your name and organization,  
if any, that you may be speaking for today. This will  
help the Department preparing the hearing record that  
will go before the Boards. Written statements can be  
submitted directly to me at the table. The Department  
will also accept written statements e-mailed or  
postmarked until 5:00o'clock p.m. today.  
The Department staff from the Bureau of  
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Professional Licensing includes myself, Kerry Przybylo,  
Dena Marks, Rick Roselle, and Stephanie Wysack.  
So do we have cards? Okay. So the first  
set we will take comments for is Athletic Trainers. The  
first card I have is from Tracy Covassin. So if you'd  
like to come down and speak.  
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TRACEY COVASSIN: I just got these, I  
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haven't really read it. Can I ask a question?  
MR. MacINTOSH: Yeah, it will be part of  
your -- the transcript, but I mean we can't clarify --  
TRACEY COVASSIN: Okay. So where it says  
Board here under Rule 1(a), it originally had said:  
"Board" means Michigan board of athletic trainer, and now  
it says Michigan trainer board. Do you mean athletic  
trainer, because you crossed off athletic and you listed  
us as a trainer, and we're not trainers, we're athletic  
trainers?  
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MS. MARKS: I don't have that on my copy;  
is it on that copy?  
TRACEY COVASSIN: Yes.  
MS. MARKS: I'll double check that.  
TRACEY COVASSIN: So yeah, if you could  
just double check that everything should say athletic  
trainer, not trainer.  
MS. MARKS: Correct. Trainers was marked  
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off because the Board is called Athletic Trainer Board in  
the statute, so it should still include the Athletic.  
TRACEY COVASSIN: Okay. It was crossed  
off on whatever I just picked up outside.  
MS. MARKS: All right. I will double  
check that. Thank you.  
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TRACEY COVASSIN: Thank you.  
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MR. MacINTOSH: Okay. Do we have any  
other comments for Athletic Trainers? (No response.)  
Any other comments for Barbers? (No  
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response.)  
Okay. So we'll go next to Psychology,  
and I'll just go alphabetically from what I have up here  
so far. So I have Dr. Brown from the Michigan School of  
Psychology.  
FRANCES BROWN: Thank you, Wes. So I'm  
Frances Brown, F-r-a-n-c-e-s, Brown, B-r-o-w-n, from the  
Michigan School of Psychology. Okay. So I have a  
statement to read, and this is about a differentiation in  
training of psychologists for doctoral students and  
post-doctoral graduates. And Wes, would you please,  
there's multiple copies in there.  
(Documents provided to Mr. MacIntosh.)  
MR. MacINTOSH: Thank you.  
FRANCES BROWN: You're welcome.  
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Okay. So respectfully submitted for  
consideration: On behalf of the Michigan School of  
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Psychology, and in consideration of other institutions of  
higher education, we request greater clarity in the  
language pertaining to monthly hours of supervision as  
outlined in Part 3, Limited Licensed Psychologists,  
R 338.2561, Rule 61(1)(b)(iv). Training:  
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(ii) The practicum must require not less  
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than 500 clock hours of psychological work. The  
applicant shall be supervised by a psychologist who is  
licensed in this state, eligible for licensure in this  
state, or licensed or certified at the independent  
practice level in the state where the practicum takes  
place. That's not of issue.  
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The second point, (iv) The applicant  
shall meet in person with his or her supervisor for a  
minimum of eight hours a month during the practicum. So  
we have had difficulty enacting this practice and this is  
why.  
The beginning and end of an academic  
semester does not coincide with the beginning and end of  
a month. For your consideration, a student in a graduate  
program will fulfill the 500-hour practicum requirement  
over multiple semesters of enrollment, which may also  
span multiple years. A semester, and consequently,  
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practicum work, often will begin and/or end mid-month or  
with partial months of active practicum work due to  
semester breaks or training site schedules.  
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Clarification is sought as to the intent  
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of the language of eight hours per month. During this  
important time in a student's training, supervision is  
provided weekly, with at least two hours per week spent  
in supervision. In certain months, December for example,  
students are typically enrolled for only a two-week  
period at the beginning of the month with a winter break  
after that. Additionally, in months that contain more  
than four weeks, in a five-week month, the student may  
have more than eight hours of supervision that month if  
they're getting their two hours every week.  
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Below is proposed language for your  
consideration, intended to provide clarity and maintain  
the required hours and function of supervision. The  
proposed language is: .  
Eight hours of supervision per month, to  
be pro-rated during the training experience to no less  
than two hours per week while in practicum.  
In contrast to the language pertaining to  
limited licensed psychologists, the following is the  
language for those with a doctoral degree. So what I was  
just speaking about was for the masters level clinicians.  
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For doctoral students, it says:  
Training: The applicant shall have  
successfully completed an internship that was an  
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integrated part of a doctoral degree that satisfies the  
requirements in subdivision (a)(i) and (a)(ii) of this  
rule, or an equivalent postdoctoral internship as  
determined by the Board.  
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This section does not specify hours per  
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month or week, nor is it specified in the Psychology  
Supervision Evaluation form for doctoral applicants.  
We thank you for your consideration.  
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MR. MacINTOSH: Thank you. So next I  
have Dennis Kayes.  
DENNIS KAYES: I have only one copy. My  
name is Dennis Kayes, K-a-y-e-s. Do you need my address?  
MR. MacINTOSH: No.  
DENNIS KAYES: Good afternoon. My name  
is Dennis Kayes, and I live in Huntington Woods. I'm a  
retired attorney, but more importantly, for eight years  
(ending this past December), I was a public member of the  
Michigan Board of Psychology. While serving on the  
Board, I was a member of the Disciplinary Subcommittee,  
and twice I was on an ad hoc subcommittee working on  
revisions to the rules. The amendments to the rules  
being discussed today are amendments I worked on. One of  
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the amendments, the deletion of Rule 27 (formerly known  
as R 338.2527), is one of the rules -- is one that the  
Rules Subcommittee opposed and which the whole Board, by  
a large majority, voted to oppose. At both levels I was  
one of the principal opponents of the deletion, and I am  
here today to continue that opposition and to urge you  
not to delete the rule.  
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Here is why:  
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To begin, the push to delete the rule did  
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not come from any member of the Board; it came solely  
from the Department of Licensing and Regulatory Affairs.  
When I asked the Department's representative, Weston  
MacIntosh, why the Department wanted the rule deleted, he  
responded that the Department believed the rule was not  
authorized under the Public Health Code. I then asked  
him whether there was any case in which the court had  
opined that the rule was not authorized. He did not  
respond then or numerous times thereafter when I repeated  
the question. It's obvious that the answer is no, there  
is no such opinion. This despite the fact that during my  
eight years on the disciplinary subcommittee there were  
numerous times when the Department filed complaints  
against psychologists alleging violations of the rule.  
In fact, I went further and asked Mr. Weston whether  
there was any time when a psychologist, in defending  
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against a complaint, even alleged that the rule was not  
authorized. Again, he never answered me. I am sure that  
the answer again is no, there are no opinions; in fact,  
no one ever objected.  
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But just as importantly, the rule is in  
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fact authorized under the Code. First, MCL 333.16145(2)  
provides that, "A Board or task force may promulgate  
rules necessary or appropriate to fulfill its functions  
as prescribed in this article." Second, MCL 333.16221  
provides that a Board, through its Disciplinary  
Subcommittee, shall punish certain behavior, including,  
as set forth in Clause (a), "A violation of general duty,  
consisting of negligence or failure to exercise due  
care,... or any conduct...that impairs or may impair the  
ability to...skillfully practice the health profession."  
It seems to me (and must have seemed to every  
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psychologist who was ever charged with a violation of  
Rule 27) that Rule 27 is appropriate for the Board in  
fulfilling its functions under Section 16221. I simply  
cannot understand why the Department not only feels  
otherwise, but feels otherwise so strongly that it is  
pushing to delete a rule to which nobody has ever  
objected and which has helped make the psychology  
profession a very respected one.  
One further point I'd like to make.  
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Because the rule is not -- because deleting the rule is  
not being proposed by the Board, I tried to find in the  
statutes and regulations some authority for this to be  
forced upon the Board, and I could find none. The Public  
Health Code provides that rules governing psychologists  
are adopted by the Board, not by some other entity.  
Thank you for allowing me to speak to  
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MR. MacINTOSH: Next we have Jason Moser.  
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JASON MOSER: Good afternoon. My name is  
Jason Moser, J-a-s-o-n M-o-s-e-r, I'm Associate Professor  
and Associate Director of Clinical Training at the  
Michigan State University. I'm here representing my  
clinical psychology doctoral program, as well as the  
clinical psychology doctoral program at the University of  
Michigan headed by the Director of Clinical Training  
there, Patricia Deldin.  
I'm here today to provide additional  
support and thanks for the addition under Rule 41  
pertaining to the standards for doctoral-level psychology  
programs that are adopted by reference in the rules, the  
approved programs that now appear as -- under 41(1)(d),  
the accreditation standards of the Psychological Clinical  
Science Accreditation System, or (PCSAS). Our two  
Universities, our two programs are very supportive of  
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this addition to the rules that the PCSAS is a program  
that's recognized by the Board for licensure in Michigan,  
and we continue that support and are very happy to see  
that addition on there, and that we wanted to just add a  
couple of things since we first submitted our white paper  
in support of PCSAS to being an option for clinical  
licensure in Michigan in 2016, we also appeared before  
the Board in 2018, and we appreciate the time that the  
Board took to read over those materials and to have us  
comment.  
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Since those meetings and since those  
times, PCSAS, as an alternative accrediting body, has  
also been approved by APPIC, the major internship system  
for students in clinical psychology. It has also been  
recognized by the Department of Veterans Affairs, and has  
also been recognized by a number of other states so far,  
including Delaware, Missouri, Illinois, New Mexico,  
Arizona, as well as other states that don't require any  
changes but are recognizing obviously PCSAS, California  
and New York, two states that don't require any  
additional changes to their rules, but many states are  
already allowing PCSAS graduates to be licensed in their  
state, and we fully support Michigan adopting that  
alternative as well so that graduates from our program,  
Michigan State, as well as University of Michigan and  
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others, can seek licensure here in the State of Michigan.  
Thank you for your time.  
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MR. MacINTOSH: Next I have Eric Ozkan.  
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ERIC OZKAN: My name is Eric Ozkan, it's  
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E-r-i-c, last name is O-z-k-a-n. My name is Dr. Eric  
Ozkan, and I am appearing today as both a concerned  
citizen and as a professional psychologist who has  
practiced in Michigan for the past 16 years. While I  
feel it is relevant to mention that I currently serve as  
Chair of the Michigan Board of Psychology and have had  
significant responsibility in drafting today's proposed  
rule set, I must emphasize that the following statement  
is my personal view and should not be seen as reflecting  
the view of the Board of Psychology as whole. I am  
speaking only for myself on this matter.  
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I believe the overall revision to our  
rule set is an outstanding piece of collaboration between  
Licensing and Regulatory Affairs (LARA) and the Michigan  
Board of Psychology. It significantly improves upon our  
last update in 2015, but does contain one change that I  
strongly disagree with.  
The change is the removal of an entire  
section of the rules entitled R 338.2527, Prohibited  
Conduct, or simply, Rule 27. This section clearly and  
specifically enumerates seven groups of unacceptable  
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conduct that all competent psychologists view as  
potentially damaging to their clients. Examples of such  
prohibited conduct include: Engaging in unfair  
discrimination against clients; engaging in sexual  
relationships with clients, their family members,  
supervisees, or students; engaging in other multiple  
relationships, such as business relationships, with  
clients or their family members; exploiting clients in  
other ways that use the therapeutic relationship to  
directly benefit the licensee, and; neglecting to provide  
continuity of care to clients.  
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While I'm confident that nobody disagrees  
with the necessity of having these prohibitions applied  
to psychologists, the entire section comprising Rule 27  
was rescinded from the current proposed revision. The  
reasoning, as I understand it, falls along two lines:  
(1) It is suggested that Michigan's Public Health Code  
does not actually provide any statutory authority to the  
Board of Psychology allowing them to promulgate rules  
regarding prohibited conduct, even though these rules  
have existed for decades, and (2) It is suggested that  
even if the Board of Psychology had such authority,  
explicitly stating specific examples of prohibited  
conduct in the rules is unnecessary as it merely  
duplicates more general language already present in the  
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Public Health Code. It is feared that such duplication  
may lead to confusion about precisely what conduct is and  
is not prohibited.  
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Although I feel I understand LARA's  
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reasoning on this matter, I disagree with it based on the  
following seven points:  
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(1) I have found it difficult to  
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understand precisely why the language of the Public  
Health Code does not allow the Board of Psychology to  
promulgate rules for the conduct of its own licensees.  
Not being an attorney myself, I have deferred to  
individuals who are attorneys and have observed some  
disagreement among them on this matter. Given that, I'm  
not sure that the primary rationale put forth rescinding  
Rule 27 is uncontestable.  
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(2) Whether or not the new -- whether or  
not the Public Health Code provides language allowing the  
Board of Psychology to promulgate new rules or not, no  
new rules are being proposed or added with this revision.  
I would merely request that rules already present and  
having a long history be maintained without modification.  
Even if the authority to promulgate rules by the Board is  
legitimately open to question, it seems there would be  
little danger in maintaining the current rules while the  
matter is resolved.  
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(3) The existence of Rule 27 is not mere  
window-dressing. The rules on prohibited conduct,  
particularly those related to sexual misconduct and other  
forms of boundary crossing, are routinely cited by  
attorneys from the Office of the Attorney General as a  
basis for misconduct charges brought against licensees.  
As it stands, Rule 27 is relied upon by attorneys as an  
effective and convenient tool for dealing with  
professional misconduct.  
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(4) The presence of similar sections  
entitled "Prohibited Conduct" are found in the  
administrative rules for other professions, including  
Massage Therapy, Physical Therapy, and Acupuncture. The  
long-standing presence of such a section in the  
psychology rule set and its continuing presence in these  
newer professions suggests that there is no inherent  
problem having such a section in addition to the more  
general language present in the Public Health Code.  
(5) The practice of psychology presents  
unique challenges regarding client safety as compared  
with other professions. For us, the rules regarding  
boundary crossing are particularly important because of  
the private, one-on-one, and often emotionally intimate  
nature of our work with clients. Our training and ethics  
rigorously and explicitly address these challenges and we  
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have no problem ensuring that our public rules do so as  
well. Rule 27 provides bright lines for misconduct that  
are not subject to interpretation. Psychologists welcome  
such transparency as good for both our profession and for  
the public.  
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(6) All competent psychologists are  
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acutely aware of the rules and ethics surrounding the  
complex relationships we engage in as a matter of course.  
While we are clear-thinkers in this regard, we are not  
lawyers. Delving into the minutiae of the carefully  
crafted language present in the Public Health Code is  
akin to deciphering hieroglyphics for many of us. Given  
that, every psychologist I know relies on the  
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Administrative Rules for Psychology as their source for  
guidelines regulating our profession. Until I became a  
member of the licensing board in 2012, I had never even  
thought of consulting the Public Health Code for  
professional guidance, and I never needed to. I think  
this is likely true of most practicing psychologists. As  
with most professions, I believe, we rely on what is  
present in the rules as a more accessible and  
understandable distillation of the Public Health Code.  
(7) A final consideration regards the  
optics of removing Rule 27; how it would appear to our  
colleagues and the public at large. With the release of  
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any new rule set, the most natural first question to ask  
is, "What's changed?" In the current cultural and  
political climate, matters of sexual impropriety by  
professionals are rightly being taken more seriously by  
all of us. Why would we chose to remove rules clearly  
forbidding such misconduct? The fact that the Public  
Health Code may contain duplicate protections may be lost  
on many as those protections are relatively hidden from  
view. I am proud to be a member of a profession that has  
clearly written rules specifically identifying sexual and  
other misconduct as unacceptable. I can see no danger in  
keeping those rules specific and stating them clearly in  
an easily accessible document like this rule set.  
Overall, the current set of proposed  
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rules represents a clearer, leaner set of guidelines for  
the psychologists of Michigan to follow. Additions have  
been made which clarify the requirements for licensure,  
and inconsistencies in many areas have been disposed of.  
Expanded opportunities for obtaining continuing education  
credits are especially important to push forward at this  
time. I strongly support the content of this proposed  
revision of the rules, except for one controversial but  
consequential issue regarding the recision of Rule 27.  
Please consider reinstating R 338.2527,  
Prohibited Conduct, Rule 27. The rationale for  
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rescinding it is simply inadequate in the face of  
numerous and varied reasons for keeping it. In informal  
discussions among colleagues, I have not found a single  
instance where its removal from the rules was considered  
anything but a mistake.  
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Thank you very much.  
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MR. MacINTOSH: Do I have anyone else who  
wishes to speak at this time?  
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FRANCES BROWN: I'm sorry, I forgot to  
mention that on this document that I gave you, on the  
back --  
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MR. MacINTOSH: You might want to state  
your name again.  
FRANCES BROWN: Oh, I'm sorry. Frances  
Brown, President, Michigan School of Psychology.  
On the back of this document, for your  
information, we've provided the semester information  
where the breaks are for the major psychology programs in  
the State of Michigan. Thank you.  
MR. MacINTOSH: Okay. If there's no one  
else who wishes to speak at this time, we'll take a short  
recess.  
(Recess held from 1:26 p.m. to 1:44 p.m.)  
MR. MacINTOSH: Okay. If there are no  
further comments at this time, I hereby declare the  
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hearing closed. The record will remain open until 5:00  
p.m. today for any additional comments you may wish to  
share regarding the proposed rules. Thank you for  
coming.  
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(Hearing concluded at 1:45 p.m.)  
- - -  
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1 STATE OF MICHIGAN )  
)
2 COUNTY OF MACOMB )  
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I, Lori Anne Penn, certify that this  
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transcript, consisting of 22 pages, is a complete, true,  
and correct record of the public hearing held on Monday,  
April 22, 2019.  
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I further certify that I am not  
responsible for any copies of this transcript not made  
under my direction or control.  
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Digitally signed by Lori Anne Penn  
DN: cn=Lori Anne Penn, o=Metro  
Court Reporters, ou=Metro,  
email=metrostate@sbcglobal.net,  
c=US  
Lori Anne  
Penn  
Date: 2019.04.30 09:40:56 -04'00'  
April 26, 2019  
Date  
______________________________________  
Lori Anne Penn, CSR-1315  
Notary Public, Macomb County, Michigan  
My Commission Expires June 15, 2019  
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;