From:  
To:  
Diane.Shields@midmichigan.org  
MDHHS-AdminRules  
Subject:  
Date:  
Attention: Policy Analyst  
Wednesday, December 8, 2021 4:47:55 PM  
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December 8, 2021  
Department of Health and Human Services  
Policy and Legislature  
Administrative Rule for Michigan Physician Orders for Scope of Treatment  
Rule Set 2021-31 HS  
Attention: Policy Analyst  
333 South Grand Avenue  
th  
5
Floor  
Lansing, MI 48933  
MDHHS-AdminRules@michigan.gov  
Dear Policy Analyst,  
I am writing on behalf of MyMichigan Health (fka MidMichigan Health) and  
respectfully submit the following suggestions regarding the Administrative Rules for  
the Michigan Physician Orders for Scope of Treatment, proposed Rules 325.81, et.  
seq (MI POST):  
·
·
·
Remove the limiting language, “those elderly” from 325.82(1) to ensure MI  
POST applies to all adult patients at end of life.  
Include detailed descriptions of the Medical Interventions in Section B of  
MDHHS 5836 instead of referring to form MDHHS 5837 for those details.  
Remove the question, “Valid DNR on file?” in Section A of the form as this  
is not relevant to the MI POST and may be confusing to first responders and  
physicians.  
·
Modify the date of January 1, 2018 in Rule 325.82(9) to demonstrate the delay  
in the State rollout and replace with a date in 2023 that will allow healthcare  
organizations and providers the time needed to prepare for the new form,  
provide education and develop processes.  
The intent of the MI POST is to offer a portable medical order set to adults with  
medical frailty or serious illness near end of life, regardless of their age. Act 368  
Section 333.5674(2) of the Public Health Code defines patient as “an adult with an  
advanced illness or means an adult with another medical condition that, despite  
available curative therapies or modulation, compromises his or her health so as to  
make death within 1 year foreseeable though not a specific or predicted  
prognosis.” As written, draft Rule 325.82(1) only applies to “those elderly  
patients”, not all adults with a medical frailty or serious illness near end of life,  
greatly limiting the effectiveness of the Rule. It is the experience of MyMichigan  
Health that patients of all ages, not just the elderly, benefit when their end of life  
wishes are clearly defined. MyMichigan Health requests the removal of the words  
“those elderly” in Rule 325.82(1) to avoid excluding non elderly adult patients who  
would otherwise benefit from this portable medical order set.  
It is imperative that these portable medical order sets are easily understood not  
only by the patient and signatory provider but also by the providers responding to a  
medical emergency. The proposed form would cause confusion as it fails to include  
the patient’s Medical Intervention choices and instead directs providers to a second  
document, MDHHS 5837.  
It is also important that the Michigan Physician Orders for Scope of Treatment not  
only serve our patients within the state of Michigan, but align with the National  
POLST Taskforce. An example of a POLST form which meets these criteria is the  
Indiana POST. This form serves a comparable patient population, is limited to 2  
pages, does not require referencing an additional form regarding Medical  
Interventions (MDHHS 5837), and does not include the question “Valid DNR on  
file”.  
Thank you for your consideration of these comments. Any questions you may have  
should be directed to advance care planning staff at 989-839-3167.  
Sincerely,  
Diane Shields  
System Vice President  
Marketing/Legislative Relations  
MyMichigan Health  
(989) 839-3518 (Midland Office)  
(989) 356-7352 (Alpena Office)  
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