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BPL-BoardSupport

MacIntosh, Weston (LARA)

Fwd: Psychology rules comment

Monday, January 9, 2023 4:38:32 PM

From: Sarah Domoff <sarah.domoff@gmail.com>

Sent: Monday, January 9, 2023 4:34:27 PM

To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>

Subject: Psychology rules comment

CAUTION: This is an External email. Please send suspicious emails to

abuse@michigan.gov

To the Michigan Board of Psychology,

The Diversity, Inclusion, and Social Responsibility (DISR) committee of the Michigan Psychological

Association (MPA) recommends that the list of sponsors of CE programs be expanded to include two

additional organizations:

Society for the Scientific Study of Sexuality: https://www.sexscience.org/content.aspx?

page_id=22&club_id=173936&module_id=500493

National Latinx Psychological Association: https://www.nlpa.ws/continuing-education

Thank you for considering this comment.

Dr. Domoff, DISR Chairperson

Sarah E. Domoff, Ph.D.

Associate Professor

Department of Psychology

Central Michigan University

Research Faculty Affiliate

School of Public Health

University of Michigan

Family Health Research Lab: http://www.sarahdomoff.com/

Twitter: @sarah_domoff

From:

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BPL-BoardSupport

MacIntosh, Weston (LARA)

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FW: Psychology – General Rules (MOAHR #2022-14 LR)

Monday, January 9, 2023 3:42:40 PM

From: Tyler, Mike <mtyler@msp.edu>

Sent: Monday, January 9, 2023 3:40 PM

To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>

Subject: Psychology – General Rules (MOAHR #2022-14 LR)

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Re: Psychology – General Rules (MOAHR #2022-14 LR)

I am pleased to have this opportunity to comment on proposed changes to rules and

regulations for the professional licensing of psychologists in the state of Michigan.

Overall, I and members of the team I work with had no substantive concerns. We are

excited that efforts continue to support master’s level practitioners in the state of

Michigan and believe these individuals are an important part of the mix needed to

address the needs of citizens.

One member of our team expressed concern about wording that might be confusing

to some readers. This is in relation to R 338.2573 (2) (i). After careful reading, she

interpreted this section to apply to an LLP (not a TLLP). If the interpretation is correct

and it applies only to LLP, then is was unclear if it referred to an LLP who allows their

license to lapse and may have the license renewed if they re-apply within three years

of the lapse or if they can re-apply at any time and be renewed for three years but

only if they have passed the EPPP within the 2 years prior to the application for re-

licensure.

If the only way to reapply is within the first three years of the lapse, then the

language may be clearer if “more” was replaced with “within”. The suggested wording

provided is:

(2) An applicant whose limited license has lapsed may be relicensed

within the three years after the expiration date of the license under

section 16201 (4).....if the applicant....

I would note that there was not agreement on how this section was to be interpreted.

This disagreement might suggest some lack of clarity. I appreciate the opportunity to

be a part of this important conversation.

Sincerely,