Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Wednesday, September 27, 2023 10:57 AM  
Przybylo, Kerry (LARA)  
Subject:  
Attachments:  
FW: Open Comment Period for Nursing Administrative Rules Draft  
image001.png  
From: Jennifer Avery <[email protected]>  
Sent: Wednesday, September 27, 2023 10:09 AM  
To: BPL-BoardSupport <BPL-BoardS[email protected]>  
Subject: Re: Open Comment Period for Nursing Administrative Rules Draft  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello Board Support-  
I have no objections or proposed changes to the proposed language updates, thank you for providing the opportunity  
for comment.  
Jen  
Jennifer Sjostedt Avery PhD, RN, GNP-BC  
Interim Director, School of Nursing  
Eastern Michigan University  
On Tue, Sep 26, 2023 at 8:25ꢀAM Przybylo, Kerry (LARA) <PrzybyloK@michigan.gov> wrote:  
Dear Directors of Nursing:  
The public hearing to receive comment on the nursing administrative rules is set for October 16, 2023.  
Please review the revised changes. If you wish to make a comment you may do so in one of two ways: In person or in  
writing by sending your comment to BPL-BoardSupport@michigan.gov by 5:00 p.m. on October 16, 2023.  
The rules committee has worked hard to provide better clarity. However, if you have suggested changes, please  
provide the proposed language for adoption.  
1
Warm regards,  
Kerry  
Kerry Ryan Przybylo, JD  
Manager, Boards and Committees  
Bureau of Professional Licensing  
Department of Licensing and Regulatory Affairs  
611 W. Ottawa Street  
Lansing, Michigan 48909  
(517) 342-4971 (cell)  
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2
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Monday, October 2, 2023 8:41 AM  
Przybylo, Kerry (LARA)  
Subject:  
FW: Comments/questions  
Is this something you can answer regarding nursing schools or is it a rules thing for Jennifer?  
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  
From: Lauren Foltz <[email protected]>  
Sent: Sunday, October 1, 2023 5:36 PM  
To: BPL-BoardSupport <BPL-BoardS[email protected]>  
Subject: Comments/questions  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Dear BPL,  
R 338.10303 pertains to initial program approval. Clarification about the impact on all existing  
nursing education programs within a 50-mile radius is needed. Based on the documentation  
submitted by programs seeking initial approval and the meeting minutes, it seems as though a  
survey is how this rule is satisfied. The rule should specifically state that a survey is required  
with some suggested questions specifically related to the impact on sharing clinical  
sites. Particularly, a question included in the survey should be:  
1. What is your plan to collaborate with nearby schools of nursing to ensure adequacy  
of clinical placements?  
Sincerely,  
1
Lauren Foltz  
2
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Friday, September 29, 2023 10:52 AM  
Shaltry, Jennifer (LARA)  
Cc:  
Przybylo, Kerry (LARA)  
Subject:  
FW: Comment on rules update  
From: Leefers, John P. <[email protected]>  
Sent: Friday, September 29, 2023 10:51 AM  
To: BPL-BoardSupport <BPL-BoardS[email protected]>  
Subject: Comment on rules update  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello,  
A fellow Nurse Educator shared with me the following informafion:  
“Quick MIBON Rules update: the nursing rules are open for comment on revisions currently...there are proposed  
changes, which include allowing the implicit bias training to count toward the 25 CE hours requirement, newly licensed  
nurses need to do CE for the first licensing cycle, and 120 hours of precepfing only counts for 1 contact hour (instead of  
5)”  
I have a comment one of these proposed changes:  
I am opposed to newly licensed RNs being required to complete confinuing educafion in their rst cycle. New  
grad orientees who hire into the ICUs I serve will oꢀen have 100-130 hours of class fime to prepare them for  
their role. I recognize that ICU seꢁngs are outliers for the amount of in class non-CE learning a new nurse must  
complete… but I also believe that all new nurses are going to go through some kind of training program that  
transforms them from a nursing student to a producfive professional. The purpose of contact hours is to  
promote professional growth and expand the knowledge set of our colleagues. Brand new nurses get plenty of  
that already. The addifional burden of complefing sancfioned contact hours seems unnecessary considering the  
great amount of learning and professional growth that new RNs are obligated to by the nature of employment.  
Perhaps an compromise would be an exempfion for RNs who become employed in direct care.  
Thank you,  
John Leefers, BSN, RN, CCRN-K  
He/Him/His  
Adult Critical Care Nurse Educator  
Nursing Practice and Development  
517.648.7161 Cell  
corewellhealth.org  
1
1840 Wealthy St SE  
Grand Rapids, MI 49506  
Office # 1H-65  
MC: 465  
As a nursing professional development practitioner, I facilitate the development of nurses and allied health  
personnel from novice to expert. I achieve this by being a learning facilitator, change agent, leader, mentor,  
champion of scientific inquiry and partner for practice transitions.  
2
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Monday, October 16, 2023 7:05 AM  
Shaltry, Jennifer (LARA); Przybylo, Kerry (LARA)  
FW: Comments on Nursing Administrative Rules Draft Revisions  
Subject:  
From: Meringa, Joshua M.(Josh) <[email protected]>  
Sent: Friday, October 13, 2023 4:22 PM  
To: BPL-BoardSupport <BPL-BoardS[email protected]>  
Subject: Comments on Nursing Administrative Rules Draft Revisions  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello Board of Nursing Rules Commiꢀee,  
Please accept my comments below on the Draꢁ Nursing Administrafive Rules that have been proposed and are  
scheduled for a public hearing on Monday, October 16.  
1. R 338.10601 (5)  
Please keep this rule intact. Eliminafing this rule would begin requiring newly licensed Michigan nurses to  
complete all confinuing educafion requirements during their inifial licensing cycle, which for most would be their  
rst 2 years in pracfice as new grad nurses. Most newly licensed nurses will have recently completed not only  
their formal nursing educafion programs, but also have studied for and successfully taken the NCLEX. During  
this fime most newly licensed nurses will complete rigorous orientafion and onboarding programs, which  
include hands on training and educafion as well as competency validafion for independent pracfice. Many  
newly licensed nurses will also parficipate and complete nurse residency programs, which have educafional and  
professional development components spanning the first year (or two) in pracfice. Due to this extensive  
educafion experience that most newly licenses nurses will have recently parficipated in, I would suggest that the  
Board of Nursing confinue to excuse newly licensed nurses from the general confinuing educafion requirements  
during their inifial licensing period. My understanding is that way back when, the rafionale for newly licensed  
nurses (new grads) not being required to complete confinuing educafion hours was based on the fact that they  
have recently completed a rigorous nursing educafion program within the past few years and should be up to  
date on current nursing pracfice standards as then enter the workforce. The purpose of confinuing educafion is  
for nurses to maintain confinued competence in a rapidly changing healthcare environment. I would argue that  
our newly licensed nurses are already doing this during their rst two years in pracfice for the reasons stated  
above.  
2. R 338.7004 / R 338.10602 (b)  
Thank you for proposing allowing the recently required 2 hours of implicit bias training per licensing cycle to  
count toward 25 contact hour relicensure requirements, similar to pain. This is appreciated and makes a lot of  
sense. This will result in less confusion as well. Many organizafions have been offering contact hours for implicit  
bias training that nurses technically can’t use toward confinuing educafion requirements, because it was  
required to be above and beyond the 25 hours.  
3. R 338.10602 (i)  
1
Please consider maintaining the 120 hours of precepfing for 5 contact hours provision as acceptable confinuing  
educafion rather than changing it to 120 hours of precepfing for 1 contact hour. This provision has been helpful  
in recruifing and rewarding much-needed preceptors for new nurses as well as students. There is great demand  
for willing, qualied nursing preceptors in our healthcare organizafions to mentor and train new nurses. Many  
organizafions are not able to pay preceptors a premium to serve in this role, which is demanding and necessary  
to ensure a supply of highly qualied nurses successfully enter the workforce and transifion into  
pracfice. Allowing nurses to precept in a 1:1 relafionship to claim 5 hours of confinuing educafion credit for 120  
hours of precepfing provides some recognifion of the value of this role. Changing this from 5 hours to 1 hour  
per 120 hours of precepfing is a take-away and hardly makes it worth using this toward confinuing educafion,  
essenfially devaluing the contribufions of preceptors. 120 hours of a preceptor relafionship is preꢀy typical of  
working with 1-2 students per semester.  
When this rule was added a few years ago during my tenure as the MIBON Chair and Rules Commiꢀee Chair, it  
was based loosely on the Kentucky Board of Nursing’s confinuing educafion requirements (even used some of  
the KY language verbafim in wrifing the rule). In Kentucky, nurses must complete 14 confinuing educafion hours  
annually, and are allowed to use 120 hours of precepfing to safisfy this requirement for the full 14 hours each  
year.  
I would urge you to either maintain the status quo and clarify that 120 hours of precepfing is worth 5 contact  
hours per cycle if there is confusion on this point, or even consider increasing this for a total of 10 or even 15  
hours per licensing cycle (which is sfill significantly less than KY=28 hrs/2 yrs). Many of our preceptors are  
precepfing constantly throughout the year, and would benet from this, as well as encourage more nurses to  
precept. Preceptors working with students or new employees are much needed, work hard, and must stay up to  
date on best pracfices for their department or specialty area to be able to mentor and teach  
others. Maintaining this level of experfise requires ongoing educafion and familiarity with best pracfices to be  
able to effecfively serve in this role and properly train and mentor other nurses and students. Preceptors are  
oꢁen our highest performing and most professionally developed nurses. They are essenfial to maintaining and  
expanding the pipeline of qualified nurses needed to combat the nursing shortage.  
Kentucky Board of Nursing references:  
hꢀps://kbn.ky.gov/educafion/Pages/Confinuing-Educafion-Competency.aspx  
hꢀps://kbn.ky.gov/KBN%20Documents/ce-preceptor-vericafion-form.pdf  
4. Similar to preceptors, there is a significant nursing faculty shortage. I would encourage you to consider allowing  
nursing clinical instructors that are directly supervising and training nursing students in clinical seꢂngs to claim  
some of their fime spent teaching toward their 25 contact hour relicensure requirement in a future rule set  
revision. Similar arguments could be made regarding the level of clinical experfise needed by instructors to  
maintain competency in teaching nursing students in the clinical seꢂng.  
Thank you for your considerafion of my comments and suggesfions, and for your service in protecfion of the public.  
Joshua Meringa, MPA, MHA, MBA, BSN, RN, NPD-BC  
Nurse Educator & Academic Liaison  
Nursing Practice & Development  
Corewell Health West  
616.391.1528 Direct  
616.301.4663 Cell  
2
corewellhealth.org  
100 Michigan St NE | MC 018  
Grand Rapids, MI 49503  
As a nursing professional development practitioner, I facilitate the development of nurses and allied health personnel from novice to expert. I achieve  
this by being a learning facilitator, change agent, leader, mentor, champion of scientific inquiry and partner for practice transitions.  
3
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Monday, October 16, 2023 7:02 AM  
Shaltry, Jennifer (LARA); Przybylo, Kerry (LARA)  
FW: A Few comments on CEU Changes  
Subject:  
From: Savalle, Jacqueline <jacqueline.[email protected]>  
Sent: Friday, October 13, 2023 9:57 AM  
To: BPL-BoardSupport <BPL-BoardS[email protected]>  
Subject: A Few comments on CEU Changes  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello Michigan Board of Nursing,  
It has come to my attention of discourse surrounding some changes to the CEU requirements for Michigan RN licensees.  
I would like to offer a few comments as you deliberate these decisions.  
I greatly support the 2 contact hours of implicit bias training to be included in the 25 continuing education requirements  
for each licensing cycle. This specific training is very important but it feels untruthful saying “you need 25 hours for  
continuing education PLUS two more of implicit bias training” While the pain management requirement falls under the  
25 hours.  
I would also like to express NOT supporting cutting 120 hours of precepting from 5 CEUs to 1 CEU. Precepting a new  
employee requires a wealth of knowledge and experience, as well as interprofessional collaboration skills. While I think  
5 is reasonable for that amount of time precepting, 1 CEU feels almost insulting. Can you imagine doing something like  
this for 120 hours and at the end being given a participation sticker? 5 CEUs is an appropriate amount of  
“compensation” for the intense amount of work it requires to be a preceptor. It is not a secret the nursing profession is  
drastically understaffed, and we are losing many senior RNs who are able to help us train, this is one of the ways we can  
show our support to our fellow colleagues.  
I appreciate your work and time in keeping our profession strong in the state of Michigan! And appreciate you listening  
to comments on this matter  
Best,  
Jacqueline Savalle MS, RN, CMSRN  
She/Her/Hers  
Adult Medical Surgical Nurse Educator  
Nursing Practice and Development  
248.756.6970-Cell  
corewellhealth.org  
1
1840 Wealthy St SE  
Grand Rapids, MI 49506  
As a nursing professional development practitioner, I facilitate the development of nurses and allied health  
personnel from novice to expert. I achieve this by being a learning facilitator, change agent, leader, mentor,  
champion of scientific inquiry and partner for practice transitions.  
2