From:  
To:  
Subject:  
Date:  
FW: Upcoming Hearing Commentary  
Wednesday, November 17, 2021 7:12:44 AM  
From: Doctor Cantwil <doccant1@aol.com>  
Sent: Tuesday, November 16, 2021 9:53 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Upcoming Hearing Commentary  
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Dear LARA representatives:  
I have been practicing dentistry for 33 years in the State of Michigan and I speak against the mandated  
Implicit Bias Training for licensure.  
I believe that the overwhelming majority of dental health care providers provide care to their patients in a  
non-biased manner. Those that don't will not be changed by a mandated implicit bias course because  
such a course cannot change this type of character flaw. Patients would be better served by dentists  
dedicating this mandated time to improving clinical procedures in order to improve clinical outcomes.  
Most dentists I know, and I know many, do not allow such a bias to affect the recommendations and/or  
treatment of their patients. We are guided and sworn to abide by the American Dental Association Code  
of Ethics.  
I feel that this mandate will ultimately propel negative attitudes towards those that insist on proclaiming  
their uniqueness, and want to be identified, and treated differently, because of their perceived  
uniqueness. This in turn forces and enhances bias rather than eliminating it.  
We are professionals and it is also very insulting to be accused of needing this type of "therapy." We are  
not in the business of subscribing to absurd social narratives. We are in the business to care for our  
patients in a way that fulfills the ethical and spiritual guidelines which govern us. State imposed  
requirements, such as Implicit Bias Training are intrusive and burdensome for dental professionals.  
Sincerely,  
James K Cantwil DDS  
Flushing, Michigan  
From: Susan Moon <powerofprayer91@gmail.com>  
Sent: Saturday, November 13, 2021 2:51 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Public Hearing (MOAHR#2021-74 LR) Implicit Bias Revision Nov. 22,2021  
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RE: Public Hearing November 22, 2021 General Rules (MOAHR #2021-74 LR)  
IMPLICIT BIAS TRAINING REVISION  
At a time when healthcare professionals are in short supply and overworked, I would have you  
reconsider the necessity of implicit bias training on all practioners every re-licensure. Additionally,  
there is scant research showing implicit bias training is effective beyond the academic institution. It  
seems unreasonable to mandate continually training for current healthcare providers in the area of  
implicit bias training when there is only suggestions and possible solutions that are unproven.  
Implicit Bias training was required on a regular basis since 2015 for the Minneapolis police and yet  
the death of George Floyd still occurred. Having a one time implicit bias training class to try and  
reveal unconscious bias could potentially be helpful for providers who are motivated to overcome  
these beliefs, but to require continual courses with unproven results is not time or cost effective.  
There are only two states in the U.S. that require this, MI and CA, most likely due to the paltry  
research regarding effectiveness beyond the academic school. Therefore, I would recommend that  
the implicit bias training stand as written in the current law with no revision requiring this training  
for relicensure or reregistration be added. The training for those categories would be optional.  
Susan Moon  
944 Geller Ct.  
East Tawas MI 48730  
From:  
To:  
Cc:  
Subject:  
Date:  
FW: Comments - Public Health Code - General Rules – Rule Set 2021-74 LR  
Monday, November 22, 2021 4:34:27 PM  
Attachments:  
image003.png  
image004.png  
image005.png  
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Proposed Rule_PHC-General_Ltr_112221.pdf  
Importance:  
High  
From: Stacey Hettiger <SHettiger@msms.org>  
Sent: Monday, November 22, 2021 4:20 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Rebecca Blake <rblake@msms.org>; Benjamin Louagie <BLOUAGIE@msms.org>  
Subject: Comments - Public Health Code - General Rules – Rule Set 2021-74 LR  
Importance: High  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Please see attached comments from the Michigan State Medical Society regarding Public Health  
Code - General Rules – Rule Set 2021-74 LR. If you have any questions, please feel free to contact  
me.  
Sincerely,  
Stacey  
Stacey P. Hettiger | Senior Director  
Medical and Regulatory Policy  
Michigan State Medical Society  
517-336-5766 | shettiger@msms.org  
VIA email at BPL-BoardSupport@michigan.gov  
November 22, 2021  
Department of Licensing and Regulatory Affairs  
Bureau of Professional LicensingBoards 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.  
November 22, 2021  
Department of Licensing and Regulatory Affairs  
Bureau of Professional LicensingBoards and Committees Section  
Page 2  
Thank you for the opportunity to comment. Should you have any questions regarding our  
recommended changes, MSMS would be happy to discuss further. Thank you for your  
consideration.  
Sincerely,  
Julie L. Novak  
Chief Executive Officer  
From:  
To:  
Subject:  
Date:  
Attachments:  
FW: Implicit Bias Training  
Tuesday, November 16, 2021 3:29:28 PM  
image002.png  
I believe this goes to you.  
Thank you,  
Stephanie Wysack  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-241-7500  
Confidentiality Notice: This State of Michigan 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 any confidential and/or privileged information contained in this email is expressly  
prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy any and all  
copies of the original message.  
From: Milan Sata <milansata@gmail.com>  
Sent: Tuesday, November 16, 2021 3:26 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Implicit Bias Training  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
To Whom It May Concern,  
In regards to the new Implicit Bias Training being considered for re-licensure, I would like to say that  
I feel it is an overreach to require this of dentists. I have been practicing for 26 years and do not feel  
I have been biased towards anyone because of their race, religion, sexual orientation, or how they  
identify. In the past I have worked in areas that were primarily minorities and lower income. I have  
also worked with patients who were LBGT. Never once have I received a complaint on how they  
were treated or that I was somehow biased towards them. I understand the world is changing and  
you want to appear to be politically correct at every step of the way, however I feel this is not  
something that should be mandated to be re-licensed after 26 years of working and never once  
having a complaint. If you want to offer this as an elective towards our CE's then that is fine, but to  
require it is a complete overreach. There will always be some bad apples in any profession, but to  
add on to everyone's requirements when the majority are very ethical and treat patients objectively  
and professionally is not necessary.  
Milan Sata DDS  
810-694-0200  
Grandblancdentalcenter.com  
From:  
To:  
Cc:  
Subject:  
Date:  
Attachments:  
FW: Public Hearing (MOAHR#2021-74 LR) Implicit Bias Revision Nov. 22,2021  
Monday, November 15, 2021 7:20:24 AM  
image002.png  
Dena,  
Here is a comment about the rules for the public hearing on Monday.  
Kerry  
From: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Sent: Monday, November 15, 2021 7:05 AM  
To: Przybylo, Kerry (LARA) <PrzybyloK@michigan.gov>  
Subject: FW: Public Hearing (MOAHR#2021-74 LR) Implicit Bias Revision Nov. 22,2021  
Thank you,  
Stephanie Wysack  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-241-7500  
Confidentiality Notice: This State of Michigan 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 any confidential and/or privileged information contained in this email is expressly  
prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy any and all  
copies of the original message.  
From:  
To:  
Cc:  
Subject:  
Date:  
Attachments:  
FW: Public Health Code - General Rule (R. 338.7004): Implicit Bias Training Standards  
Monday, November 22, 2021 7:10:23 AM  
HFHS Comment Letter LARA Implicit Bias Training FINAL.pdf  
Dena,  
Forwarding the message below to you.  
Kerry  
From: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Sent: Friday, November 19, 2021 4:25 PM  
To: Przybylo, Kerry (LARA) <PrzybyloK@michigan.gov>  
Subject: FW: Public Health Code - General Rule (R. 338.7004): Implicit Bias Training Standards  
Would this go to Wes?  
LeAnn  
From: Daugherty, Payton <pdaughe1@hfhs.org>  
Sent: Friday, November 19, 2021 3:54 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Valade, Diane K. <DVALADE1@hfhs.org>  
Subject: Public Health Code - General Rule (R. 338.7004): Implicit Bias Training Standards  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Good afternoon,  
On behalf of Henry Ford Health System, thank you for the opportunity to submit comments on the  
LARA Implicit Bias Training Standards.  
Sincerely,  
Kimberlydawn Wisdom, M.D.  
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