May 26, 2022
Department of Licensing and Regulatory Affairs
Bureau of Professional Licensing
Boards and Committees Section
Genetic Counseling – General Rules
2021-43 LR
Attention: Departmental Specialist
611 W. Ottawa St.
P.O. Box 30670
Lansing, MI 48909
Dear Department Specialist:
On behalf of Michigan hospitals, the Michigan Health & Hospital Association (MHA) appreciates the
opportunity to provide comments on the Genetic Counseling – General Rules.
The MHA supports the Department in establishing genetic counselor licensure to align with the majority of
states implementing professional standards for practitioners providing genetics and genomics to improve
healthcare for Michigan patients.
The genetic counseling draft rules require licensing applicants to be in good standing with the American
Board of Genetic Counseling (ABGC) or the American Board of Medical Genetics and Genomics
(ABMGG). The MHA requests the Department grant temporary licensing to practitioners who have
been providing genetic counseling services for 3 years prior to the rule’s effective date, as they
work to satisfy the educational requirements demanded by the ABGC and ABMGG to be in good
standing. These practitioners have been providing high-quality genetic counseling within their hospitals
and have the endorsement of hospital leadership to continue providing services as they work to satisfy
the new licensure requirements.
The MHA is concerned that nurse practitioners who have been trained to provide genetic counseling
services will have to cease providing care because of the limited educational programs available in
Michigan to satisfy the ABGC or ABMGG educational requirements. Michigan only has two accredited
genetic counseling programs at the University of Michigan and Wayne State University. Both programs
require students to be onsite and the University of Michigan accepts approximately 10 students per class,
and Wayne State University accepts 8 students per class. The MHA asks the department to allow
hospitals and health systems to endorse these practitioners to have temporary licenses and allow
for extra time to identify alternative educational programs that would allow these practitioners to
obtain active candidate status from the ABGC or the ABMGG.
