BOMATS Request for Changes to the Michigan Athletic Training General Rules
My name is Matthew Hambleton, and I am the Michigan Athletic Trainer's Society
Governmental Affairs Committee Chair. The intent of this letter is to issue a public comment
regarding a proposal of alternative options to address the Athletic Training General Rules and the
continuing education (CEU) requirements for maintaining a Michigan athletic trainer (AT)
license.
Previously I have submitted in writing a request to change the license renewal requirements for
ATs from having to complete 75 CEUs within a 3-year renewal cycle to simply having to show
proof of being current with the Board of Certification (or BOC) national standards. The BOC
requires 50 CEUs within a 2-year renewal cycle in order to maintain the national ATC
certification credential. Both the Michigan licensing requirements and the national BOC
certification requirements indicate needing to acquire an average of 25 CEUs per year. For ATs
who choose to maintain both sets of credentials it poses a certain challenge.
Under these circumstances, ATs must be careful and plan to receive no more than 25 CEUs per
year depending on the reporting cycle. This can be challenging depending on what CEU
opportunities that may present each year.
So long as the AT receives no more or no less than 25 CEUs each year then there is not any
foreseen issues. However, if the AT earns an excessive amount of CEUs in one year, it could
cause the AT to then need to earn more CEUs in a subsequent year, and therefore create the need
for additional coursework as well as increase their financial burden. (See Appendix for an
example of a potential scenario).
Allowing for this proposed standard, there would still be the result of the AT earning an average
of 25 CEUs per year, but it would also eliminate the challenges in complying with both the State
and the National requirements.
This proposal would also be in compliance with the recent State law, Public Act 19 of 2020. This
ACT states, “the rules must adopt, by reference, the continuing education standards for athletic
trainers issued by the Board of Certification, Inc. that are in existence on the effective date” ...
And that “The department may incorporate by reference, in whole or in part, existing standards
in the rules.”
In addition, the Act states that “The department, in consultation with the board, shall promulgate
rules to require licensees seeking renewal to furnish evidence acceptable to the department and
the board of the successful completion, during the preceding license cycle, of those continuing
education requirements.”
It is not unreasonable to say that “acceptable evidence” would include the licensee simply having
to show proof that that they have met the national standards of the BOC since they too require 25
CEUs per year. The idea is that if an AT that can show proof that they are in good standing with
the BOC requirements then they must also be in good standing with the Michigan licensing
requirements.
