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FW: Attention: Departmental Specialist. Implicit Bias Public Health Code Updates  
Friday, July 15, 2022 10:27:58 AM  
From: Breijak, Duane <dbreijak.naswmi@socialworkers.org>  
Sent: Friday, July 15, 2022 10:23 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Attention: Departmental Specialist. Implicit Bias Public Health Code Updates  
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Attention: Departmental Specialist  
On behalf of the National Association of Social Workers - Michigan Chapter and our 5,000 + social  
work members across the state, we would like to submit a proposed change to the Public Health  
Code, specifically in regards to the implicit bias training requirements.  
We are requesting that the language is updated to reflect that if a licensee takes an approved  
continuing education course on implicit bias AND that training also satisfies the implicit bias training  
requirements, the licensee could use that one training to satisfy both the CE and implicit bias  
licensure requirements.  
As currently written, this creates a new standard and a first-of-its-kind requirement that does not  
allow licensees to count continuing education credit for a required relevant training. This  
wording/rule is already causing a great deal of confusion amongst licensed professionals, schools of  
social work, and organizations hosting continuing education programming.  
This would fall specifically under R 338.7004, section 2.  
Current wording:  
Beginning June 1, 2022, and for every renewal cycle thereafter, in addition to completing any  
continuing education required for renewal, reregistration, or relicensure, an applicant for license or  
registration renewal, reregistration, or relicensure under article 15 of the code, MCL 333.16101 to  
333.18838, except those licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall  
have completed a minimum of 1 hour of implicit bias training for each year of the applicant’s license  
or registration cycle.  
Suggested wording:  
Beginning June 1, 2022, and for every renewal cycle thereafter, in addition to completing any  
continuing education required for renewal, reregistration, or relicensure, an applicant for license or  
registration renewal, reregistration, or relicensure under article 15 of the code, MCL 333.16101 to  
333.18838, except those licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall  
have completed a minimum of 1 hour of implicit bias training for each year of the applicant’s license  
or registration cycle. If a licensee takes a continuing education course on implicit bias and that  
training also satisfies the implicit bias training requirements, the licensee may use that one training  
to satisfy both the continuing education and implicit bias licensure requirements.  
Thank you for your consideration.  
Duane Breijak, LMSW-Macro (He/Him/His)  
Executive Director  
517-487-1548  
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July 8, 2022  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing  
Administrative Rules for Public Health Code General Rules  
2022-17 LR  
Dear Department Specialist:  
On behalf of Michigan hospitals, the Michigan Health & Hospital Association (MHA) appreciates the  
opportunity to provide comments on the Administrative Rules for Public Health Code General Rules.  
The MHA supports the proposed changes in R 338.7004 Implicit bias training standards that clarifies  
participants have the opportunity to interact with the instructor and other participants. The MHA requests  
additional guidance be added to further reduce confusion and address questions the MHA has received  
from healthcare professionals since the rule’s effective date:  
R 338.7004 Implicit bias training standards  
Rule 4.  
(2) Beginning June 1, 2022, and for every renewal cycle thereafter, in addition to completing any  
continuing education required for renewal, reregistration or relicensure, an applicant for license or  
registration renewal, reregistration, or relicensure under article 15 of the code, MCL 333.16101 to  
333.18838, except those licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall have  
completed a minimum of 1 hour of implicit bias training for each year of the applicant’s license or  
registration cycle.  
(3)(d) Acceptable modalities of training include any of the following:  
(i) A teleconference or webinar that allows live synchronous interaction that provides for the opportunity  
for participants to interact with the instructor and other participants.  
(ii) A live presentation that provides for the opportunity for participants to interact with the instructor and  
other participants.  
(iii) An asynchronous webinar that is followed by a live synchronous interaction for a portion of  
the course that provides the opportunity for participants to interact with the instructor and other  
participants.  
Please contact me at rsmiddy@mha.org if you have any questions regarding these comments or if you  
need additional information.  
Respectfully submitted,  
Renée Smiddy  
Senior Director, Policy  
VIA email at BPL-BoardSupport@michigan.gov  
July 18, 2022  
Department of Licensing and Regulatory Affairs  
Attention: Department Specialist  
P.O. Box 30670  
Lansing, MI 48909-8170  
Re: Public Health Code - General Rules Rule Set 2022-17 LR  
To Whom It May Concern:  
The Michigan State Medical Society (MSMS) is supportive of the efforts by the state of Michigan  
to raise awareness about the impact of implicit bias on patient-health professional interactions,  
treatment decisions, treatment adherence, and patient health outcomes. Addressing health  
disparities and advancing health equity is a strategic priority of MSMS.  
As you consider the draft Administrative Rules for the Public Health Code General Rules (Rule  
Set 2022-17 LR), MSMS respectfully requests LARA amend Rule 4(3)(d) by removing reference to  
the live component requirement in that subdivision. Logistically, the implementation of the  
current requirement is overwhelming health professionals and those who provide continuing  
education training.  
The live component and mid-cycle requirements do not take into consideration that more than  
400,000 health care professionals need to be trained. Most continuing education organizations  
in and out of the state are not able to provide enough training due to a shortage of expert  
speakers and the availability of providing all programming live. Additionally, the live component  
has eliminated a significant number of high-quality implicit bias programs from academic  
centers like Stanford University, UCLA, and Cornell, as well as trusted health care institutions like  
the National Institute for Health. The live component is a further burden for the already over-  
worked health care system. Most physicians who register for current MSMS webinars complete  
those outside of normal works hours. Weekends and holidays are the busiest for mandatory  
content courses. Eliminating the option of online classes further taxes professionalsability to  
fulfill this latest requirement.  
MSMS has received over one thousand inquiries from all different health care professionals in  
the last six weeks regarding implicit bias training; more than any other issue in the past 25  
years. These communications are all based on the current rules which do not follow any of the  
precedented processes for new compulsory topics. The rules for immediate roll-out, the pre-  
and post-assessment, and the live component are overly complicated and are more onerous  
than any other state requirement in the country.  
July 18, 2022  
Department of Licensing and Regulatory Affairs  
Attn: Department Specialist  
Page 2  
For these reasons, MSMS urges the Department to eliminate the live component of the implicit  
bias training.  
Thank you for the opportunity to comment. Should you have any questions regarding our  
recommendation, MSMS would be happy to discuss further. The MSMS point of contact is  
Rebecca J. Blake, Senior Director of Subsidiaries, Education and Foundation. Ms. Blake can be  
reached at rblake@msms.org or 517.336.5729. Your consideration is greatly appreciated.  
Sincerely,  
Julie L. Novak  
Chief Executive Officer  
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