VIA email at BPL-BoardSupport@michigan.gov
November 22, 2021
Department of Licensing and Regulatory Affairs
Bureau of Professional Licensing– Boards and Committees Section
Attention: Policy Analyst
P.O. Box 30670, Lansing, MI 48909-8170
Re: Public Health Code - General Rules – Rule Set 2021-74 LR
Dear Policy Analyst:
I am writing on behalf of the Michigan State Medical Society (MSMS) regarding Public Health
Code - General Rules - Rule Set 2021-74 LR. MSMS respectfully requests your consideration of
an administrative amendment to R 338.7004 - Implicit Bias Training Standards. In addition to
representing approximately 15,000 Michigan physicians and physicians-in-training of all
specialties and practice settings, MSMS is accredited by the ACCME to provide CME training and
is recognized by the ACCME to accredit 30 other locally based organizations that provide CME.
We are supportive of the efforts by the State of Michigan to raise awareness about the impact of
implicit bias on patient-provider interactions, treatment decisions, treatment adherence, and
patient health outcomes. Addressing health disparities and advancing health equity is a
strategic priority of MSMS.
MSMS requests the following change:
•
Amend Rule 4 (3)(d)(iii) to strike “interactive.”
Michigan licenses approximately 36,000 physicians. As written, 12,000 physicians (one third of
licensed physicians) will need to participate in one hour of implicit bias training per year. As a
physician education community, it will be difficult to assure enough live training options for this
number of physicians. The same concerns are applicable for the 400,000 other health care
professionals who are also required to fulfill this requirement.
Additionally, the pandemic brings additional safety concerns regarding regularly scheduled, in
person conferences as well as the ability for physicians to schedule appropriate time to attend
sessions during regularly scheduled work hours with their current workload.
For these reasons, MSMS respectfully requests the interactive component be eliminated to allow
both in person and virtual programming without a live component as this new training
requirement is rolled out in an expedited manner.