To: Bureau of Professional Licensing
Re: Comments for the Public Hearing for Physical Therapy Rules
Date: September 9, 2021
Thank you for this opportunity to respectfully comment on the current APTA MI
recommendations for the Draft Rules.
My comments are in regard to Activity l (formerly Activity 12).
I would like to suggest the addition of another category of acceptable methods in which
to earn PDR credits by providing clinical instruction to students, staff or other licenses.
The Board of Physical Therapy will finalize the language.
Recommended language for consideration:
A clinical training program related to the practice of physical therapy presented by
A physical therapist or physical therapy assistant who has achieved specialty
expertise and / or recognition from organizations which enhance physical therapy
patient care as approved by the board.
Currently the 4 categories of accepted programs and organizations does not include
consideration of other individual “cases” or situations where valuable clinical education
and mentorship can be and are provided. I think the best way to most clearly describe
this “new category” is to as succinctly as possible, explain my background and
My education includes a BS in physical therapy in 1974 (Wayne State University), a MS
PT in Allied Health Education in 1978 (University of Kentucky) and a DScPT in 2007
(Oakland University). During my career I also earned a certification in Orthopedic
Manual Physical Therapy (OMPT) from Oakland University in 1998, became a licensed
Rehabilitative Pilates Instructor and a licensed Gyrotonic and licensed Gyrokinesis
Instructor. My career has evolved into a Performing Arts Speciality (musicians and
dance) and the integration of therapeutic exercise and manual therapy treatment
Over the years I have taught within numerous accredited physical therapy programs as
a Guest Instructor to Assistant Professor. My employment has included several
hospitals, home healthcare and finally co-owner in a private practice for 40 years.
Providing quality clinical education has always been a priority in each position (CCCI at
hospital and in private practice). I am a life member of the APTA and one of the
benefits of those employed in my private practice was the payment of APTA dues for all
In addition, during this time I have provided many hours of “volunteer” mentorship,
lecture and clinical instruction to students, staff and other licenses. This instruction
often took place in my office or in another area not listed in the current four categories.
My outpatient office is recognized by CMS. In going forward, I am not longer working
directly in one of the four categories currently listed, but continue to work with and
mentor the above indicated professionals. To be sure, I am not unique. I think the