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STATE OF MICHIGAN  
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
BUREAU OF PROFESSIONAL LICENSING  
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PUBLIC HEARING  
TUESDAY, JANUARY 19, 2021  
AT ABOUT 1:00 P.M.  
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HELD VIA ZOOM CONFERENCE  
LANSING, MICHIGAN  
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RE:  
Chiropractic - General Rules  
(MOAHR #2019-84 LR)  
Pharmacy Technicians - General Rules  
(MOAHR #2020-29 LR)  
Speech-Language Pathology - 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: Kerry Przybylo  
Andria Ditschman  
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LeAnn Payne  
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24 REPORTED BY:  
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Lori Anne Penn, CSR-1315  
Penn Reporting, LLC - lori.penn@yahoo.com  
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Opening Statement - Weston MacIntosh  
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COMMENTS:  
MARTIN BROWN  
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KRIS FETTERMAN  
ERIC DiMARTINO  
GARTH AAMODT  
DONALD RENO  
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ROBERT FENELL  
KRIS FETTERMAN  
ROBYN PEAKE  
LARRY KAPLAN  
ROYANN HASSINGER  
LEWIS SQUIRES  
LEIGHIA WELLS  
DONALD RENO  
GARTH AAMODT  
MARTIN BROWN  
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21 Closing Statement by Mr. MacIntosh  
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Tuesday, January 19, 2021  
At 1:00 p.m.  
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MR. MacINTOSH: Good afternoon. My name  
is Weston MacIntosh, and I am an analyst 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 proposed  
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administrative rules entitled "Chiropractic - General  
Rules", "Pharmacy Technicians - General Rules", and  
"Speech-Language Pathology - General Rules". We are  
conducting the hearing as required by the Administrative  
Procedures Act to allow the public to comment on the  
proposed to changes to these rule sets. As with all  
other public hearings on draft rule sets, the only items  
discussed during this hearing will be proposed changes to  
the rule sets. This hearing will not be covering any  
questions or discussions on any other issues, such as  
reopening businesses, as this is not the proper platform.  
We are calling this hearing to order at  
1:00 o'clock p.m. on January 19, 2021, via Zoom, to  
follow measures designed to help prevent the spread of  
Coronavirus Disease 2019 (COVID-19). The notice of  
public hearing was published in three newspapers of  
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general circulation, the Grand Rapids Press, the Flint  
Journal, and the Mining Journal, on January 5, 2021, as  
well as the Michigan Register, Issue #24, published on  
January 15, 2021.  
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All comments should relate directly to  
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the proposed rules. If you have questions about the  
rules, you may place your comments on the record and the  
Department will review and consider them. If you have  
suggested changes to the proposed rules, please include  
the specific reasons why the changes would be in the  
public interest.  
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We'll take comments in the following  
manner.  
For those using the Video Conference Portion,  
i.e., not calling on the telephone, please use  
the "Raise Your Hand" feature in Zoom. I will  
call on individuals to speak and they will be  
unmuted at that time.  
For participants that are available only by  
telephone, we'll ask if you wish to make a  
comment after the video participants have  
finished.  
If you have a comment but do not wish to speak,  
please note that the Department will also accept  
written statements e-mailed or postmarked to  
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BPL-BoardSupport@Michigan.gov until 5:00 o'clock  
p.m. today.  
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Those making comments should clearly and  
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slowly say and spell your name and advise if you are  
speaking on behalf of an organization. We will limit  
comments to three minutes per person. Please remember  
that only one person should speak at a time.  
The Department staff from the Bureau of  
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Professional Licensing includes Kerry Przybylo, Andria  
Ditschman, and LeAnn Payne, as well as myself.  
We will group the comments by rule set so  
that we can group the comments together. And I'm not  
going to go alphabetically, I'm going to actually start  
with the first rule set we'll look at is taking comments  
for Speech-Language Pathology - General Rules. Is there  
anyone who wishes to speak on the Speech-Language  
Pathology - General Rules?  
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MS. PRZYBYLO: Wes, I don't see anybody's  
hands up.  
MR. MacINTOSH: I'm just looking at the  
second page. Okay. Yeah, I'm not seeing anyone either.  
Okay. So the next rule set we'll look at  
is comments for Pharmacy Technicians - General Rules. Do  
we have anyone who would like to make comments on the  
Pharmacy Technicians - General Rules?  
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MS. PRZYBYLO: Wes, this is Kerry.  
don't see anybody's hands up for the Pharmacy Technician  
Rules.  
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MR. MacINTOSH: I don't either.  
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So next we'll take the third set, which  
is the Chiropractic - General Rules. Is there anyone who  
would like to make a comment on the Chiropractic -  
General Rules? And again, please, if you wish to make a  
comment, please raise Your hand under the participants'  
tab in Zoom.  
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MS. PRZYBYLO: Wes, it looks like Martin  
Brown has a comment.  
MR. MacINTOSH: Yes, Martin, it looks  
like you're unmuted. Go ahead.  
MARTIN BROWN: Are asking me to begin my  
comment?  
MR. MacINTOSH: Yeah. Can you please  
just state and -- state your name and first and last and  
just spell it, because we do have a court reporter, just  
so she has a record.  
MARTIN BROWN: Okay. Thank you. My name  
is Martin Brown, M-a-r-t-i-n B-r-o-w-n, and I'm president  
of Macomb County Chiropractic Association, M-a-c-o-m-b,  
County Chiropractic Association.  
Is the reporter, stenographer ready for  
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me to begin?  
MR. MacINTOSH: Go ahead, Martin, yeah.  
MARTIN BROWN: I oppose the Board of  
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Chiropractic granting authority over the review and  
approval of continuing education to the Michigan  
Association of Chiropractors, MAC for short. This is not  
a common standard in other professions here, nor is it  
common in other states' chiropractic boards. This option  
is very questionable and controversial.  
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I am a loyal, longstanding, dues-paid  
member of MAC and its predecessor since the early '80s.  
I have consistently attended MAC events for over 35  
years. I recognize MAC's fine efforts in serving its  
members and promoting the profession, but there are  
limits on MAC's organizational role.  
MAC is a non-regulatory, nongovernmental  
membership trade organization and should not be given a  
regulatory role. Chiropractors are not required to join  
MAC. The State board's primary obligation is to protect  
the health, safety, and welfare of the public. MAC's  
role is to serve its members. These are different and  
separate roles and the distinction should remain.  
MAC holds continuing ed programs and  
derives significant income from these. There is a clear  
conflict of interest if MAC were to oversee all other  
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providers of continuing ed. The proposed rules provide  
no oversight, no checks or balances on MAC whatsoever.  
In fact, MAC has been placed above the rules with no  
application, review, or approval required for their own  
programs. MAC courses should be impartially reviewed.  
do not doubt the validity of MAC programs, but I oppose  
an unequal review process.  
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The Federation of Chiropractic Licensing  
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Boards established PACE, Providers of Approved Continuing  
Ed, with an well-accepted rigorous review process  
utilized by the vast majority, some 80 percent of state  
boards, for impartial review. PACE is perfectly suitable  
for Michigan.  
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Another issue, chiropractic college  
courses given on campus are currently automatically board  
approved. Off-campus and online courses should also be  
automatically approved in the new rules. There are no  
chiropractic colleges in the State of Michigan. The same  
course taught in-state for the doctors' safety and  
convenience of course warrants automatic approval if  
taught on campus, likewise for online courses. The  
pandemic has taught us about valid flexible options. All  
universities offer online courses to protect from COVID,  
and chiropractic CEs should become more accessible, not  
further encumbered.  
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The State must preserve fair government  
authority. The Board of Chiropractic must always focus  
on its role of protecting the public. I speak in the  
name of fairness, equal justice, and ethical principles.  
And I've also submitted written documents personally and  
as president of the Macomb County Chiropractic  
Association providing reasonable options for a just and  
fair alternative to serve the board and the public.  
Thank you very much.  
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MR. MacINTOSH: Thank you, Dr. Brown.  
And I'll just also remind folks, we  
already have received a lot of written comments. If you  
sent in a written comment, you don't have to basically  
say the same thing. You know, if we have your written  
comment, we have your written comment and we'll obviously  
pass it along to the board, just for everybody's  
clarification. So if you've already submitted something  
and it would be basically the same thing that you would  
say otherwise, you don't need to say it again for the  
sake of the record.  
Who else would like to make a comment on  
Chiropractic - General Rules?  
MS. PRZYBYLO: Wes, Kris Fetterman has a  
comment. She was unable to raise her hand.  
MR. MacINTOSH: Okay. Kris, go ahead.  
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KRIS FETTERMAN: Thank you. I'm Kris  
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Fetterman with Fetterman Events, spelled K-r-i-s, last  
name is F- as in Frank e-t-t-e-r-m-a-n. And I sent each  
board member of a packet of information a few weeks ago  
that explained my thoughts and opinions on the issue; if  
you didn't receive it, I can e-mail the information  
again. But I sent it because I had heard the board  
members were given incorrect information that weighed in  
on your decision to move in the direction you were  
taking.  
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My company provides CE seminars for about  
38 states right now, and we've interacted with state  
boards for each of these states and have seen firsthand  
the differences in state boards that use their state  
associations for some aspect of their business. In each  
of these states, the chiropractors in the state feel as  
if their state board is controlled by the state  
association, the transparency of the board disappears,  
and the impropriety of the board increases. There's a  
lot of distrust between the doctors and the board. It  
also builds a great divide between the chiropractors and  
the association.  
Now, I have always, have always and  
always will encourage doctors to join their state  
association, and specifically the Michigan one because  
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they do a lot of great things for the chiropractors. We  
only do continuing education, but the state association  
does a lot more with legal and legislative issues  
specifically. But so saying that, it's -- this is not to  
just go against state association, this is actually  
something that should be kept separate.  
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Many states, almost all states in fact,  
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use PACE to handle the CE approvals in some manner. Some  
states rely solely on PACE and use their approval as the  
board's approval, and other states use a PACE precheck to  
sort through the applications and make it less lengthy  
for their time, so there's an option of control for the  
state boards. PACE is a part of the Federation of  
Chiropractic Licensing Board, they're the ones who  
control the national board testing. They are an unbiased  
organization that's designed to ensure that CE programs  
are of the highest quality and that providers adhere to  
strict guidelines, and there's an extensive application  
process to even become a PACE provider, which weeds out  
individuals or companies that try to get CE approval for  
seminars that don't enhance the doctors' knowledge or  
education.  
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Now, I understand there are more and more  
CE applications coming into the board for review and that  
this is taking a lot of the board's resources of staff  
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and member time, however, to give this duty to the state  
association will dissolve any transparency of fairness  
and ethical morality that the board has. It will also  
give the appearance of impropriety, whether real or  
imagined. So I'm asking the board members to reconsider  
this option and look into the possibility of using PACE  
instead to handle this duty. They're equipped to do this  
and already handle this for the majority of state boards.  
Members of the FCLB receive annual  
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benefits, such as free access to online reporting,  
reporting agent service, polls, poll surveys regarding  
scope or practice issues, and several more benefits that  
help govern, towards govern their state professional.  
Michigan is only -- is one of only three states that are  
not members of the Federation, all other states are.  
One of the most attractive benefits for  
regulatory boards is the retention of authority. The  
boards that are a part of the FCLB retain their authority  
and they can choose to implement PACE as a means of  
delegating some of the workload associated with that  
authority.  
Another big benefit, and this is one of  
the largest ones I've been told, is their CIN-BAD  
program. Members, board members can look up licensed  
applicants to make sure they don't have board actions in  
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other states. CIN-BAD also sends out monthly  
notification on any board action so that state licensing  
boards can request get a heads up. That way if a doctor  
who's licensed in Tennessee has his Oklahoma license  
revoked for unprofessional conduct, the Tennessee board  
will be able to act before that doctor hurts a patient in  
their state. So, and all boards, all licensing boards  
are required to report actions to the National  
Practitioner Databank; FCLB handles that via the CIN-BAD.  
So it can be a huge cost savings, and that's one of the  
things I am presenting, presenting this information so  
you can make an informed decision and encourage you to  
consider the FCLB's PACE program as a better option.  
Thank you.  
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MR. MacINTOSH: Do we have any other  
comments on the Chiropractic --  
MS. PRZYBYLO: Eric DiMartino has a  
comment.  
MR. MacINTOSH: Okay. Eric, go ahead.  
And again, please, you know, state your first and last  
name, and please spell it.  
ERIC DiMARTINO: Thank you. Good  
afternoon. My name is Dr. Eric DiMartino, that's E-r-i-c  
D-i-M-a-r-t-i-n-o, and I currently serve as chairman of  
the board for the Michigan Association of Chiropractors.  
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I'm here today to speak in support of the  
proposed Administrative Rule, the change regarding  
Chiropractic continuing education, as well as discuss a  
potential change to the current rule regarding  
chiropractic relicensure.  
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First, regarding the proposed rule  
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governing continue education, this solution was arrived  
at after a member of the Michigan Board of Chiropractics  
continuing education committee contacted the MAC  
regarding the intense administrative burden faced by  
their committee. In researching models across the  
country and keeping in mind their desire to keep the  
approval process within the State of Michigan, the rules  
committee work group arrived at this solution.  
MAC programs are already approved for  
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continuing education without going through the  
application process; this is the result of the recent  
changes to the Administrative Rules that were approved  
and went through the public hearing process years ago,  
this again is acknowledging the MAC's years of  
high-quality programs that consistently meet State of  
Michigan requirements. The MAC has the nonprofit legal  
structure, expertise, experience, and well-informed staff  
to provide a professional evaluation that strictly  
follows the guidelines for approved continuing education  
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outlined in the current State of Michigan Administrative  
Rules. As long as the current guidelines are followed,  
programs will be approved.  
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As I mentioned, there are precedents  
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among other states for taking such action, including the  
chiropractic licensing boards of Kansas and Tennessee,  
both of which delegate the authority for the review and  
approval of chiropractic continuing education programs to  
their chiropractic state associations. Also, other  
professional membership organizations in Michigan, such  
as the realtors and CPAs, have taken on this critical  
responsibility.  
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The MAC board of directors, leadership  
and education programs committee are confident that the  
model proposed by the rules committee work group and  
passed by the full Board of Chiropractic solves the  
administrative issues faced by the Board of Chiropractic  
and ensures that CE programs continue to count for the  
Michigan chiropractic scope of practice as well as  
current trends in Michigan's chiropractic practice, while  
continuing to allow only the highest quality programs for  
continuing education. I firmly believe that the proposed  
change to the rule governing acceptable chiropractic  
continuing education will greatly benefit the licensed  
chiropractors in our state and the State of Michigan  
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itself.  
Next I'd like to talk about the  
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Administrative Rule governing chiropractic relicensure --  
THE REPORTER: Can you slow down a little  
bit, please. I'm sorry.  
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ERIC DiMARTINO: Am I speaking too fast?  
THE REPORTER: You're getting faster and  
faster. Thank you.  
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ERIC DiMARTINO: You can't keep up.  
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Okay.  
Moving on, I'd like to talk about the  
Administrative Rule governing chiropractic relicensure  
for chiropractors whose Michigan license has been expired  
for three years or more. Prior to the rewrite of the  
rules that became effective in 2019, all applicants for  
relicensure were required to satisfy either of the  
following: Either 45 hours of continuing education in  
the preceding three years with all the outlined  
requirements, or have been licensed as a chiropractor in  
another state of the United States during the three-year  
period immediately preceding the applications for  
relicensure. This was changed in the most recent rewrite  
of the rules.  
Currently, doctors seeking Michigan  
relicensure after their license has been elapsed for  
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three years or more are now required to have the 45 hours  
of continuing education and either have been licensed in  
another state for three years preceding the application  
or have passed a National Board of Chiropractic Examiners  
special purposes examination for chiropractic. We feel  
that this is overly burdensome on doctors seeking  
relicensure in that if a doctor has been continuously  
licensed in another state for the three years immediately  
preceding applications for relicensure, has been  
following the state's continuing education rules, and has  
no sanction against his or her license in that other  
state, they are presumed to have the skills to practice  
chiropractic in the State of Michigan. We also do not  
believe that passing the NBCE SPEC exam is necessary to  
establish the presumption of having the skills and  
ability to practice chiropractic in the State of  
Michigan.  
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It is also important to note that if a  
doctor had never been licensed in Michigan at all, the  
process to get a license is much less cumbersome, but  
because someone may have gotten a Michigan license right  
out of school, but then moved to another state to  
practice and now wants to come back to Michigan, they  
must follow a completely different and more stringent set  
of rules. We would like to see the rule rewritten to be  
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more in line with the rule prior to the previous rewrite  
in which chiropractors have access to two methods in  
which to gain relicensure: (1) through continuing  
education, or (2) having been continuously licensed in  
another state for the immediate past three years. This  
change will continue to protect both the general public  
and the profession itself while easing a burdensome  
requirement on applicants for relicensure whose license  
has been expired for three years or more. Thank you for  
your time and your consideration of these comments.  
MR. MacINTOSH: The next hand I see  
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raised is (inaudible) --  
THE REPORTER: I'm sorry, Wes, I could  
not hear you.  
MR. MacINTOSH: Sorry. The next hand I  
see raised is Garth Aamodt. Hopefully I pronounced that  
correctly. Garth.  
GARTH AAMODT: You were close.  
MR. MacINTOSH: And then please, again,  
just state your first and last name and please spell it.  
Thank you.  
GARTH AAMODT: Okay. Can you hear me  
now?  
MR. MacINTOSH: Yes.  
GARTH AAMODT: My name is Dr. Garth  
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Aamodt, and that's spelled A-a-m-o-d-t, pronounce it  
Aamodt.  
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I actually don't represent anyone here  
except my own opinion. I have sent in a letter from  
January 12 to the board, so I won't repeat anything I've  
said there. I have just a couple of things I didn't  
bring up in my letter that I think pertain here, some of  
them from been brought up by the previous speakers. I'll  
keep it real brief.  
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My chief concern is the wording, which I  
think is new wording, about how approved university  
seminars must be on campus for automatic approval. That  
bothers me. One reason is because every year I  
participate in an annual conference held in Chicago,  
Illinois, it's sponsored by National University of  
Chiropractic, it's also sponsored by the ACA Council on  
Orthopedics, but as I understand it, because they draw  
chiropractors from all over the country, often all 50  
states, or at least contiguous states, they hold it off  
campus, they hold it at the Marriott Hotel; it's  
convenient, you can book your room there, and it's a  
three-day conference. I'm concerned that because it's  
off campus, even though it's sponsored by a university,  
does that mean that they or the other sponsors or the ACA  
are going to have to add to their burden to apply for  
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sponsorship or approval for their CE hours. I don't know  
that they have to do that with other states, but I  
presume that since they are automatically included in  
most other provisions being sponsored by the University  
and the ACA, that that would be a formality that I would  
think would not be necessary under normal circumstances.  
My other concern is the conflict of  
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interest. We have not always had the best continuing  
education seminars in Michigan, sorry. I'm not saying  
those were sponsored by the MAC, we've had other  
organizations before the MAC, but I have actually seen  
some pretty bad things sponsored by various previous  
trade organizations, so I'm concerned that if the  
ideology becomes farther leaning one way or another,  
we're going to find an unintentional bias in what they  
may approve or not approve, so that concerns me. Also,  
I'm concerned that conflict of interest, if they're doing  
a seminar on one topic and Fetterman, say, for example,  
or someone else, Macomb, applies for a similar topic you  
might say, will they prefer theirs since theirs are  
automatically approved. That's not a bonus that you're  
automatically approved and are above the, I guess you'd  
say the vetting process.  
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So those are my main contentions. It  
could be that I have a misunderstanding, I have read the  
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rule change and I've tried to stay informed, but my main  
concern is one of conflict of interest and the additional  
burden that would come upon organizations that right now  
know that they're already vetted by I would assume almost  
all other states, so why are we adding to their burden.  
And we're just spreading out the burden in this state,  
we're need not really improving it. I personally think  
that PACE is a great way to go. I have no ax to grind  
either way, I'm a private practitioner, but these are my  
concerns, and I appreciate the opportunity to express  
them.  
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MR. MacINTOSH: Thank you, Garth.  
Next we'll do Don Reno. And again,  
please state your first and last name and spell them.  
DONALD RENO: Well, good afternoon,  
everybody. My name is Dr. Donald Reno, D-o-n-a-l-d,  
middle initial M., last name Reno, R-e-n-o. And I'm here  
today to speak in support of the proposed changes to the  
Michigan Board of Chiropractics Administrative Rules.  
There's been some awesome points that  
have been made by all parties. And I speak as the former  
BOC chairman, served eight years on the Michigan board,  
and there's a couple things I think I can help to clarify  
here.  
Administratively, the State of Michigan  
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deals with its boards maybe a little bit differently than  
some other states; I think it's an extremely great system  
that the State of Michigan has utilized over the years.  
Many states have boards with budgets and directors and  
heavy, cumbersome internal organization factors. The  
State of Michigan does not allow for board budgets and  
secretaries that are private to the members of the board  
per se, which is a very good way to keep the board in  
line without being a sheriff in town.  
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PACE is also -- or FCLB is an  
organization that does specialize in continuing education  
through their PACE program. Due to the fact that  
Michigan does not participate in the FCLB -- the reason  
why that is is it's a cost pay-for-play organization --  
since there's no budget for the board to pay FCLB dues,  
the board had always navigated the world of CEs through  
volunteer. Yes, it's a cumbersome situation. I believe  
the MAC is stepping up in great faith to take on a burden  
that will have no financial redeeming qualities to it,  
they are not going to be paid for the work that they're  
going to do, and there is no new conflict because most of  
these chair of the CE committee on the board has always  
been a MAC member, so there is no new introduction to any  
kind of conflict of interest whatsoever in my opinion.  
The members of the Association are dues  
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paid, it is not incumbent upon the MAC to pay the FCLB to  
pay for the approval of the continuing education credits.  
Especially in a pandemic period where obviously cost  
containment is is very, very important, I think it would  
be unfair for us to put additional costs on the shoulders  
of the doctors for the MAC or -- not the MAC, but for the  
board to participate with the FCLB. It's just, it's an  
additional cost that's not really in the best interest of  
the public.  
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And in my eight years as, or disciplined  
in the Board of Chiropractic, I've always observed  
nothing but the utmost integrity in the review of the CEs  
with no conflict, and if there was any disapproval of a  
CE, it was over something that just simply didn't appear  
in the paperwork or the quality of the program. So I  
speak in support of this, and I can't imagine a better  
organization to review the CEs for the State of Michigan  
and offer the best and highest quality of public  
protection.  
MR. MacINTOSH: Thank you for your  
comments. Next I see Robert Fenell. Robert.  
ROBERT FENELL: Good afternoon. My name  
is Dr. Robert Fenell, and that's spelled R-o-b-e-r-t  
F-e-n-e-l-l, and I'm here representing nobody other than  
myself right now.  
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I'm a practicing chiropractor and  
licensed in the State of Oklahoma, and I am speaking here  
today to oppose the rule under consideration which would  
give the Michigan Association of Chiropractors, or MAC,  
sole authority over continuing education.  
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We have a different, but somewhat  
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similar, process here in Oklahoma. You may or may not  
know that we have two state associations, and as a  
practicing chiropractor, we are required to take one of  
the handful of seminars that are made available to us  
each year by either/or of the different state  
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associations. It makes for -- and I'm speaking for let's  
just say nearly a hundred percent of the chiropractors in  
the State of Oklahoma because I personally have met most  
of the chiropractors through my affiliations with either  
one or other of those associations. So, and it is a  
disadvantageous environment for us to practice in. The  
speakers that are chosen for either/or of the two  
associations, in many opinions of the doctors, we'd  
rather have other presenters. Speaking to colleagues of  
ours who practice in other states, they have a plethora  
of seminars and speakers they can gain their CE hours  
through, and they may travel, some of them come to other  
states, and what have you. But in Oklahoma, it's very  
limited.  
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A colleague of mine who practices in  
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Michigan mentioned this to me recently, and I said, oh,  
no, please, I hope that doesn't happen to you guys, that  
sounds like it could even be potentially worse because  
there's one association and they'll have full control  
versus we have two associations and there's some shared  
control there of course. But it's very, very limiting,  
the DCs here wish that we had similarities of other  
states, possibly, for example, PACE certified or able to  
get a seminar that's certified through a chiropractic  
college, but that's not the case, unfortunate for the  
Oklahoma chiropractors, and it sounds like this would be  
the more unfortunate for doctors practicing chiropractic  
in the State of Michigan. So I greatly oppose that  
consideration, and hopefully Michigan can remain how they  
have been. I'm just speaking from the love of  
chiropractic and a fellow chiropractor. That's all I  
have to say.  
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MR. MacINTOSH: Thank you for your  
comment.  
MS. PRZYBYLO: Weston, Kris Fetterman was  
next on the list. She had an additional comment to make  
and messaged me before the other people put their hand  
up.  
MR. MacINTOSH: Oh, okay. Go ahead,  
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Kris.  
KRIS FETTERMAN: Oh, thanks. I just  
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wanted to mention Dr. Reno had mentioned -- no, no, it  
wasn't Dr. Reno, it was Dr. DiMartino, that Tennessee  
uses their state association. They actually switched two  
years ago and are with PACE. Their association still is  
automatically approved, but they do go through PACE, you  
have to be a PACE provider to be approved there, and I  
wanted to mention that.  
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And I also mentioned -- wanted to say  
something about verbiage being given to people to speak  
here which is in the chat box, that doesn't quite seem  
right, but I just thought I'd bring that up. That's all.  
Thank you.  
MR. MacINTOSH: Just as a heads-up, no  
one should be commenting in the chat box, comments are  
supposed to be made orally for the purpose of this  
hearing.  
Let's see here. Next I see Robyn Peake.  
Go ahead, Robyn.  
ROBYN PEAKE: I am sorry for the comment  
that ended up in the public chat, I thought I was  
responding to somebody privately and it did not respond  
to that individual, and my apologies for that.  
I
recognized that after the fact, and I did make that  
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apology on chat for any disruption. That was certainly  
not my intent.  
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I have a love of chiropractic,  
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chiropractic is my first go-to for healthcare for myself  
and my family. And it's important to me that we have  
doctors and continuing ed that are efficient, that are  
effective. One of the concerns that I have as an  
individual is what's the value of online coursework that  
can -- that has no supervision. Somebody could set up a  
program to play and then walk back in two to three hours  
later when it's complete. How much value has that served  
for the chiropractor, and what does that translate to for  
care of patients.  
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Just because something comes in does not  
mean that it needs to be approved. I think that running  
it through the MAC would streamline the process, I think  
it would help for both doctors as well as the providers  
of the coursework. There's certain standards that I  
expect out of my chiropractor, there's certain standards  
that I would hope would be followed with the continuing  
ed programs. To resist those standards I think puts the  
public at risk. I think there needs to be the programs  
that have the proper supervision that can verify that the  
doctors have in fact completed the coursework, that can  
have a positive result on how they practice and  
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protecting the public. Thank you very much.  
MR. MacINTOSH: Thank you for your  
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comments. Is there anyone -- I'm not seeing any other  
hands right now. Is there anyone else who would like to  
make a comment? Let me just really quick circle back  
because I'm not seeing any hands right now.  
Was there anyone else who would want to  
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make a comment on either the Speech-Language Pathology -  
General Rules or the Pharmacy Technician - General Rules?  
Okay. I'm not seeing anyone.  
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anyone else who would like to make a comment on the  
Chiropractic - General Rules?  
MS. PRZYBYLO: Weston, Larry Kaplan is  
physically raising his hand.  
MR. MacINTOSH: Okay. Larry, go ahead.  
Again, please state your first and last name and spell  
them for the record.  
LARRY KAPLAN: Okay. My name is Larry  
Kaplan, L-a-r-r-y K-a-p-l-a-n.  
I strongly oppose this measure. I've  
been a MAC member for many years, I was an MCC member, I  
was a Society member. They put, the MAC puts on great  
seminars, but I think there has to be a regulatory part  
of it. I think there's a conflict of interest here both  
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financially on both sides. The MAC, from what I  
understand, is more of a membership association, and it  
even says in its bylaws that it's not a regulatory  
agency, and I think that's a conflict there. The state  
board, they might be overwhelmed and maybe they need help  
in doing it, but they're the ones who can give a fair  
maybe assessment of the continuing ed, and I never  
understood why this came to where it is.  
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Not everyone in the State here is a  
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member of the MAC, so now, arbitrarily now they have to  
become a member or they have to abide by their rules, and  
there's no regulation, they're just being handed over  
this priority of regulating the continuing ed program.  
And everything else has been said.  
I've been to many seminars, the MAC puts  
on great seminars, Macomb puts on, I've been to Omni,  
I've been to Fetterman, I've been all over, and they're  
all really good, and I just think right now, I just think  
it would be a conflict of interest, and that's my input.  
Everything else has been said. So that's it, and I thank  
you for the opportunity.  
MR. MacINTOSH: Thank you for your  
comments. I see a hand, Royann Hassinger. Royann, can  
you hear me? You're on mute.  
ROYANN HASSINGER: Yes. Okay. I'm  
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sorry. I'm Royann Hassinger, I'm a chiropractor in  
Ortonville. I have been a member of MAC --  
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MR. MacINTOSH: First of all, can you  
please spell your first and last name.  
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ROYANN HASSINGER: I'm sorry. My first  
name is Royann, R-o-y-a-n-n, Hassinger, H-a-s-s- like in  
Sam i-n-g-e-r. I'm in Ortonville, Michigan.  
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There are several of us in my little,  
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tiny community, and I believe we all practice  
differently; that is one of my concerns with MAC being  
the primary or having authority over all the continuing  
education.  
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I've attended MAC seminars, I've attended  
other seminars. If I want an in-depth seminar, if I want  
to learn a new program, it is very difficult to get that  
at seminars sponsored by larger organizations.  
I'm concerned about the conflict of  
interest. I want to be able to practice the way the laws  
say I can, but are different from the person down the  
street from me. That is what gives our patients the  
freedom of choosing a particular doctor. Unfortunately,  
because I turned 65 and had to get Medicare, I went to a  
medical doctor. I didn't really get a choice as to who I  
got, and they're all the same so it really didn't matter.  
Nothing wrong. But now I really, really appreciate the  
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fact that I can choose the doctor who I want as a  
chiropractor, my patients can choose me as opposed to  
Dr. Brown. He doesn't live near me so it's not a  
problem. But we can choose who we want because of how we  
practice, and I am afraid that MAC will restrict what my  
continuing education credits are.  
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I did like what Dr. Eric had said about  
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licensing. I agree, if you've been practicing out of  
state, you should be able to come to Michigan if you  
qualify. Dr. Reno made a comment that the chiropractic  
board has always had an MAC president; that does kind of  
seem strange to me. But I just think that from an  
individual chiropractor not associated with any  
organization, that PACE or some non-biased organization  
would be a better supplier for our continuing education  
credits. Thank you.  
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MR. MacINTOSH: Thank you for your  
comments. Squires.  
LEWIS SQUIRES: There we go. Thank you,  
Weston. I'm Dr. Lou Squires, S-q-u-i-r-e-s. I'm the  
immediate past chairman of the board.  
MR. MacINTOSH: (Inaudible).  
THE REPORTER: I'm sorry, I didn't hear  
you, Weston.  
MR. MacINTOSH: I asked for him to spell  
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his first name for the record as well.  
THE REPORTER: Thank you.  
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LEWIS SQUIRES: Sorry, Weston. First  
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name Lewis, L-e-w-i-s, last name Squires, S-q-u-i-r-e-s.  
I'm speaking in favor of these rule changes as a person  
that has been on this board for eight years, appointed by  
Governor Snyder at the time.  
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We have seen a lot of situations occur  
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within Michigan on the CE, and within the last two years  
we have had an overabundance of CE credits turned in,  
some positive, some negative, some outside our scope, and  
some within our scope. It has been extremely challenging  
for the doctors that review these CE credits to keep up  
with all those situations that they're faced. I'm urging  
the State to understand that the importance of doing all  
this is to safeguard the public, but also to be able to  
present the best educational seminars for CEs. This not  
to criticize any of the CEs put on by other organizations  
or universities, this is to help us in the process. That  
doesn't mean that other organizations and universities  
sponsored or entrepreneurs are going to not receive their  
credits, this is just a starting point for this, this is  
something that's vitally important on behalf of the Board  
of Chiropractic to safeguard the public and to provide  
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quality educational situations for our doctors. I think  
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there's a little confusion going on with some of the  
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people that have spoke about exactly what the rules are  
intended to do, so I just wanted to say that, and I do  
support this. Thank you very much.  
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MR. MacINTOSH: Thanks for your comments.  
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Next I see Leighia Wells.  
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LEIGHIA WELLS: Hi. My name is Leighia  
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Wells, L-e-i-g-h-i-a, Wells, W-e-l-l-s. I'm a provider  
in Portage, Michigan, and I've been a part of the MAC in  
the past and enjoyed my time very much there.  
I think the MAC does a very good job with  
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other endeavors, legislative, and also with supporting  
changes in, governmental changes that are needed and with  
legalized changes that we also need implemented.  
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don't, however, agree with having the MAC be in charge of  
continuing education. I think that is a conflict of  
interest. I do appreciate that they want to help with  
it, but I am concerned about what courses would be  
automatically agreed to, and we're spending money on that  
instead of other endeavors, and I think that that should  
be separated and not combined into two.  
Many times I do not attend the  
conferences that occur at -- for the State for the MAC  
because, or I only attend a few of classes that happen  
because I don't agree with the information that's being  
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presented, and I don't necessarily agree with many of the  
courses being presented on a very large scale, and so I  
often take classes in other states and don't even get the  
continuing education credits from Michigan applied  
because these other organizations don't go through the  
rigorous process to get it applied for Michigan because  
if they only have me there, I'm not going to ask them to  
make sure that that gets applied.  
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So I want to make sure that classes,  
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also, if they're off campus for a university, they should  
automatically count just as much as if they're on campus.  
I completely disagree with that rule. I saw that come up  
a year or so ago and I couldn't even believe it, it makes  
no sense to me that suddenly the same teachers that are  
putting the presentation on, you know, down the street,  
no longer is automatically in. That's more work for  
whoever is approving these courses, so that should be  
automatically taken care of.  
I see no reason why we don't use PACE.  
I've looked into other states, and that's what they're  
using. That seems a legitimate way, an effective and  
efficient way of completing some of these courses.  
And I'm also curious, I started to do  
some digging but it was very hard to find, is what are  
other healthcare professional boards doing for continuing  
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education. Do they have a state-run organization like  
we're considering, the MAC, in control of all of the  
courses? I don't know the answer to that, but I want to  
make sure that we're in alignment with what other  
professions are doing in our State. If we are to be  
considered legitimate, we need to make sure that we're in  
alignment with all other health professions.  
So in conclusion, I disagree with the MAC  
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being in charge, not because I don't think they're  
capable, but I think there could be some bias, and I  
think there is a conflict of interest, and I do think we  
should consider other options. Obviously the State board  
is having difficulty running through all of this  
information for all of these submissions, but I think we  
need another alternative, and I don't think it should be  
the MAC unfortunately controlling this. And that's all I  
have to say. Thank you.  
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MR. MacINTOSH: Thank you for your  
comments. Any other comments at this time? Don Reno, go  
ahead.  
DONALD RENO: Yeah. This is a process.  
What the State of Michigan came to when I was on the  
board was the awareness that this was cumbersome indeed,  
and with the multiplicity of the number of programs that  
have come in, that is where the reason came in. And  
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Dr. Wells, your statement about PACE being a great entity  
is not to say -- to take anything away from them, but the  
structure in your state does not give any participation  
because the requirement is that you as an individual  
would have to pay for a representative to go to PACE and  
the FCLB. With those dollars not being there, I think  
it's unfair to shoulder the practitioners with that.  
The MAC as an entity will not have the  
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ability to deny anything because there's a rule  
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structure, and the structure will hold every entity just  
as accountable as the other, and as this is a good-faith  
gesture, not a gesture, but act by the State of Michigan  
to clarify something that became very, very cumbersome.  
Volunteer individuals on the board don't see a dime or  
get paid for the work that they do to show up in Lansing,  
do the hard work behind the scenes, and then show up in  
Lansing and ask for an approval of everybody who's shown  
up here today to testify against the process. The  
process has no conflicts in it. And I know there's  
questions and it's cumbersome, but you just have to trust  
in the fact that you've got a great group of people  
currently on the board right now that have you and your  
profession's best interest in mind.  
MR. MacINTOSH: Thanks you. Any other  
comments?  
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MARTIN BROWN: I have a comment.  
MR. MacINTOSH: Garth Aamodt.  
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GARTH AAMODT: Yeah. Is it possible to  
just ask a question so maybe some clarity can be added  
here. And my main question -- again, this is Dr. Garth  
Aamodt, G-a-r-t-h A-a-m-o-d-t. I'm not making a  
statement, I'm just asking, is there clarity or a reason  
can be explained by those who support this, like  
Dr. Reno, about why the phrase of on-campus classes are  
automatically approved if sponsored by a university, but  
they're going to require going through the MAC, I assume,  
if they're not on campus? Doesn't that add to the  
burden? And if the goal is to remove the burden or  
lessen the burden, why didn't that phraseology get  
changed there? That's all I ask.  
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MR. MacINTOSH: Thank you. Do we have  
any other comments?  
MS. PRZYBYLO: Dr. Martin has a question,  
or has a comment, Wes.  
MR. MacINTOSH: Dr. Martin Brown, go  
ahead.  
MARTIN BROWN: The name is Martin Brown,  
M-a-r-t-i-n B-r-o-w-n.  
Robyn Peake had made a comment about  
continuing ed that was offered online and questioned the  
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validity of that. I just want to remind the board and  
those attending that the board already approves up to 15  
hours of online credits, and they're often accompanied  
with quizes and so on to ensure the validity of the  
program, so it wouldn't be a change in terms of adding  
the on-campus or off-campus or online automatic credit  
approval to college courses.  
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Additionally, I did provide in written  
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version a detailed analysis of each of the providers and  
a breakdown and did some statistical reporting in a  
written document provided for your review, and  
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approximately one-third of the programs would fall into  
that category and would drop off; in other words, of the  
some 300 applications, would reduce it to some 200. In  
fact, only two providers make up the vast majority of the  
entire block of all of those courses. Eighty-seven  
percent of those submitted courses that were reviewed and  
approved are online courses, 13 percent are live courses,  
only 40 courses out of the some 300. So if the board  
opted for direct application for five or fewer  
applications per sponsor and maintained a concurrent  
option of application to PACE or whomever is chosen, then  
the board's workload would decrease by over 90 percent,  
they would only have reviewed 21 applications, fewer  
applications than have been provided each year for the  
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past 6 years. So it's a reasonable thing to look at a  
multiple course option in terms of approval where the  
board could retain the option with a limit of up to five  
applications and the overage could go to PACE as the  
authority to review any multitude or quantity of courses.  
So I've provided all the details and the breakdowns in my  
written report that was sent by e-mail. If you have  
questions, I'd be happy to review them as well.  
MR. MacINTOSH: Thank you for your  
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comment. Are there any other comments? Okay. I'm not  
seeing any other comments.  
So if there are no other comments or  
anyone else who would like to speak at this time, I  
hereby declare the hearing closed. The record will  
remain open until 5:00 o'clock p.m. for any other  
comments you may wish to share about the proposed rules.  
Thank you for attending.  
(At 1:53 p.m., the public hearing concluded.)  
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