March 9, 2021  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing  
Boards and Committees Section  
Public Health Code - General Rules  
2020-109 LR  
Attention: Policy Analyst  
P.O. Box 30670  
Lansing, MI 48909  
Dear Policy Analyst:  
On behalf of the Michigan Health & Hospital Association (MHA), we respectfully submit the  
following comments of support with a few recommended changes on the proposed Public  
Health Code - General Rules.  
Please consider using the term “unconscious bias” overall in the rules. “Implicit bias” implies a  
provider knowingly is involved in their bias while the term “unconscious bias” reflects the true  
meaning of what these rules are hoping to accomplish, helping those who are not aware of  
existing attitudes or stereotypes that affect their perception, action or decision making.  
To provide clarity in the rule set, the word “provider” should be reserved for the health care  
community. The rule currently uses the term provider for both trainers and those professionals  
who are licensed in Article 15, which creates confusion. For example, the rules discuss  
“providers” related to who can give instruction for implicit bias training, and those who are  
receiving the education on implicit bias, i.e., health care providers. “Training provider” should be  
updated to “instructor” or an equivalent term in 338.7004, Rule 4 (3)(c) and (4)(a).  
Regarding individuals allowed to offer training, the MHA requests 338.7004, Rule 4 (3)(c)(iv) be  
updated to “Training offered by an accredited college or university or created by tenured faculty  
and used in academic courses at accredited universities.” The draft rules as written have a  
narrow description which creates the potential of missing applicable trainings. The update will  
allow for qualified academics in non-traditional institutions to provide research-based training  
that addresses this need. In addition, the MHA recommends an additional section: “(v) Training  
offered by a nationally recognized diversity, equity and inclusion firm.” This would allow  
companies who specialize in this field, such as Cook Ross, to be used.  
To clarify that non-live modalities of trainings are acceptable, amend 338.7004, Rule 4 (3)(d)(i)  
to add the word “may” and update the section to: “A teleconference or webinar that may permit  
live synchronous interaction.” This update will ensure flexibility is maintained for both larger and  
smaller health care institutions and their providers. The nature of the health care system is 24/7  
and providers will need the flexibility to complete this training at atypical hours.  
Lastly, related to documentation retention, the MHA recommends reducing the number of years  
from six to four to match the other requirements related to continuing education credits for  
health care professions. Another option is to link required training and continuing education  
credits completion data directly to providers’ National Provider Identifier (NPI) through the  
Michigan Department of Licensing and Regulatory Affairs website.  
The MHA supports unconscious bias training for all health care personnel, Ensuring equitable  
access and care for all patients is an MHA strategic priority and eliminating health disparities is  
crucial to the MHA mission of advancing the health of individuals and communities. Thank you  
for your consideration of our comments and please reach out with any questions.  
Respectfully submitted,  
Adam Carlson  
Vice President, Advocacy  
Michigan Health & Hospital Association  
Desk: (517) 886-8245 | Cell: (269) 757-2479  
From:  
To:  
Subject:  
Date:  
Attachments:  
FW: Comments on proposed PHC General Rules- MOAHR 32020-109 LR  
Monday, March 8, 2021 2:41:57 PM  
image001.png  
From: Farrell, Chris (DHHS) <farrellc@michigan.gov>  
Sent: Monday, March 8, 2021 2:40 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Comments on proposed PHC General Rules- MOAHR 32020-109 LR  
Hello,  
First comment: R 338.7001a Biennial License and registration renewal;  
expiration. Dental Therapy is listed as a biennial license. All the other license  
and registration for dentistry, dental hygienists and dental assistants is a  
triennial license and registration renewal. The dental therapy license and  
registration renewal should be consistent with the other dental licenses and  
should be moved from R338.7001a to R338.7002 Triennial License and  
registration renewal; expiration  
Second comment:R 338.7004 Implicit bias training standards. I recommend  
changing the word “medical” to “health” in section (3)(a)(i). The word health is  
much broader and can include medical, behavioral and oral health. Medical  
may be interpreted by some as only physical health and not the broader term  
of health care. Studies demonstrate that individuals have more difficulty  
accessing behavioral and oral health care than medical/physical health care.  
(3) The implicit bias training must be related to reducing barriers and  
disparities in access to and delivery of health care services and meet all of the  
following requirements:  
(a) Training content must include, but is not limited to, 1 or more of the  
following topics:  
(i) Information on implicit bias, equitable access to medical care, serving a  
diverse population, diversity and inclusion initiatives, and cultural sensitivity.  
Christine Farrell, RDH, BSDH, MPA  
Pronouns: (she/her)  
Oral Health Program Director  
Division of Child and Adolescent Health  
MI Dept of Health and Human Services  
Cell Phone: 517-243-6657  
Fax: 517-335-9397  
Confidentiality Notice: This message, including any attachments is intended solely for the use of the  
named recipient(s) and may contain confidential and/or privileged information. Any unauthorized  
review, use, disclosure, or distribution of this communication(s) is expressly prohibited. If you are  
not the intended recipient, please contact the sender by reply e-mail and destroy any and all copies  
of the original message.  
March 9, 2021  
Re: Comments on Rule Number(s): R 338.7001-338.705  
To Whom It May Concern:  
Thank you for the opportunity to provide comments on the Implicit Bias  
Rules.  
Board of Directors  
The mission of the Michigan Oral Health Coalition is to mobilize stakeholders  
and advocate for policies and resources that connect Michiganders to optimal  
oral health. The MOHC works to create a large, interconnected network of  
national, state and local advocates dedicated to working collaboratively on  
advocacy, education and awareness of oral health.  
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Kimberly Singh, MA, CHES  
President  
My Community Dental Centers  
William Ridella, MPH, MBA  
Treasurer  
Macomb County Health  
Department  
We applaud LARA for promulgating these rules on implicit bias and that all  
dental providers are included in these rules. Specifically, we are glad to see  
that implicit bias training must be done with every license renewal and not  
just as one-time training. Second, we are glad that interactive training is  
required and that there are a range of options.  
Faiyaz Syed, MD, MPH  
Secretary  
Michigan Primary Care  
Association  
Mert Aksu, DDS, JD, MHSA  
University of Detroit Mercy  
School of Dentistry  
Some improvements we recommend:  
Including Dental Therapists as provider with a triennial renewal like all  
of the other dental providers.  
Increasing the number of hours of training required.  
Including as a requirement or recommendation that information  
learned be shared within non-licensed staff.  
Using the word health instead of medical throughout the rule. Medical  
implies solely physical health.  
Dr. Drew Stern, DDS  
Pediatric Dentist  
Jim Milanowski, MS  
Michigan Association of  
County Health Plans  
Allowing an established non-profit organizations to provide the  
training.  
Stacey Murphy, MS  
Kent Cty. Oral Health Coalition  
While the fact that implicit bias definition is broad and inclusive is good, we  
are concerned that implicit bias regarding race could be seen as optional if  
other groups included are covered. We recommend that all trainings be  
required to cover race-based implicit bias.  
Holli Seabury, EdD  
Delta Dental Foundation  
Michele Strasz, MPA  
Past President  
Catalyst for Action Consultants  
Warm Regards,  
Christine M. Farrell, RDH,  
BSDH, MPA  
Ex-Officio Member  
Michigan Department of  
Health and Human Services  
Ellen Sugrue Hyman  
Executive Director  
Staff  
Ellen Sugrue Hyman, JD  
Executive Director  
Contact Us  
7215 Westshire Dr.  
Lansing, MI 48917  
From:  
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Date:  
FW: Public Comment Regarding Public Hearing for the Public Health Code General Rules on March 9  
Sunday, March 7, 2021 11:17:26 AM  
From: Saad, Fayrouz (LEO) <SaadF@michigan.gov>  
Sent: Friday, March 5, 2021 4:44 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Phillippi, Karen (LEO) <PhillippiK@michigan.gov>; Fenton, Annie (LEO) <FentonA@michigan.gov>  
Subject: Public Comment Regarding Public Hearing for the Public Health Code General Rules on  
March 9  
To Whom It May Concern:  
The Office of Global Michigan within the Department of Labor & Economic Opportunity (LEO) submits  
the following public comment in relation to the Public Hearing for the Public Health Code General  
Rules – MOAHR #2020-109 LR:  
The Office of Global Michigan recommends that R338.7002b (Minimum English Language Standard)  
include the Occupational English Test (OET) as an additional test option for applicants who are  
graduates of a foreign prelicensure education program not taught in English or if English is not the  
applicant’s native language. Further, we recommend that an overall minimum score of 300 be  
considered as proof of an applicant’s ability to meet the minimum English language standard for  
licensure. The OET is the only international English language test designed specifically for healthcare  
professionals. The OET has been approved by regulators in Florida, Washington state and Oregon as  
an eligible test of English language proficiency for internationally trained nurses. Additionally, the  
Education Commission for Foreign Medical Graduates (ECFMG) offered OET as a pathway to  
certification this year, following the suspension of the Step 2 Clinical Skills (CS) component of the  
USMLE.  
Thank you for your attention to this matter.  
Fayrouz Saad  
Executive Director  
Office of Global Michigan  
Michigan Department of Labor and Economic Opportunity  
Victor Building  
201 N Washington Street Lansing MI 48933  
Office: Cell: 517-930-4994 I Email: saadf@michigan.gov  
From:  
To:  
Subject:  
Date:  
FW: Public Comment  
Tuesday, March 2, 2021 10:39:36 AM  
I wasn’t sure who should receive this, so I sent it to all of you.  
From: James Sullivan <james@behanlaw.com>  
Sent: Tuesday, March 2, 2021 10:37 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Public Comment  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
I am providing a comment on the Public Health Code General Rules MOAHR 2020-109 during the  
open comment period.  
An applicant who has had their education credentials evaluated by a credential evaluation service  
will already have a completed the English proficiency requirement. The way the rule is written will  
require the applicant to satisfy the English proficiency requirement twice. May I suggest that the  
following phrase be added to the rule: “The applicant’s credentials and English proficiency have  
been evaluated and determined to be equivalent to the credentials required in this state by a board-  
approved credentialing agency.”  
Respectfully  
submitted,  
James D Sullivan,  
ESQ.  
From:  
To:  
Subject:  
Date:  
FW: Public Comment to Public Health Code General Rules – MOAHR #2020-109 LR:  
Sunday, March 7, 2021 11:13:11 AM  
From: Steve Tobocman <steve.tobocman@gmail.com>  
Sent: Friday, March 5, 2021 9:54 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Public Comment to Public Health Code General Rules – MOAHR #2020-109 LR:  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Global Detroit submits the following public comment in relation to the Public Hearing for the  
Public Health Code General Rules – MOAHR #2020-109 LR.  
Global Detroit is a regional economic and community development organization. With a  
focus on immigrants and global talent, we develop and implement inclusive strategies to  
drive the growth, revitalization and broadly shared prosperity of Detroit and Southeast  
Michigan.  
Global Detroit recommends that R338.7002b (Minimum English Language Standard)  
include the Occupational English Test (OET) as an additional test option for applicants who  
are graduates of a foreign prelicensure education program not taught in English or if  
English is not the applicant’s native language. Further, we recommend that an overall  
minimum score of 300 be considered as proof of an applicant’s ability to meet the minimum  
English language standard for licensure.  
It is our understanding that the OET is the only international English language test designed  
specifically for healthcare professionals. The OET has been approved by regulators in  
Florida, Washington state and Oregon as an eligible test of English language proficiency for  
internationally trained nurses. Additionally, the Education Commission for Foreign Medical  
Graduates (ECFMG) offered OET as a pathway to certification this year, following the  
suspension of the Step 2 Clinical Skills (CS) component of the USMLE.  
Thank you for your attention to this matter.  
--  
Steve Tobocman  
Executive Director, Global Detroit  
Pronouns: He; His; Him  
C: (313) 516-9681  
Inclusive Economies. Vibrant Communities.  
;