April 8, 2024  
Comments to Rule Set 2022-067 LR  
The Health Care Association of Michigan (HCAM), which represents 358 skilled nursing facilities across the  
state, would like to offer support for and suggested improvements to rule set 2022-067 LR.  
While HCAM supports the proposed rule set, including the education requirements, HCAM requests the new  
rules be implemented in a way that allows those currently receiving training through existing nursing home  
administrator programs to receive licensing. Recently, more than 50 individuals completed the course through  
Michigan State University, with nearly a dozen more scheduled to complete the course in December.  
Additionally, individuals who completed courses through Ferris State University and Madonna University.  
These individuals availed themselves to these programs under the current NHA rules, and should not be  
prevented from licensure with the implementation of the new rule set. It would be appropriate – especially  
given the current workforce challenges – to grandfather these students to further encourage participation and  
pursuit of a career in long-term care.  
To ensure these interested individuals are able to serve our state’s seniors, HCAM requests the clarifications  
stated above.  
Rich Farran  
V.P. Government Services  
Health Care Association of Michigan  
7413 Westshire Drive Â· Lansing, MI 48917 Â· P: (517) 627-1561 · F: (517) 627-3016 · www.hcam.org  
March 8, 2024  
Michigan Department of Licensing and Regulatory Affairs, Bureau of Professional Licensing  
The National Association of Long Term Care Administrator Boards (NAB) is pleased to offer our support  
for the proposed changes to the Administrative Rules for Nursing Home Administrators - General Rule  
Set 2022-67 LR.  
The NAB applauds the leadership of the Department of Licensing and Regulatory Affairs, Bureau of  
Professional Licensing, and the Michigan Board of Nursing Home Administrators in recognizing the  
qualification of candidates for licensure as Nursing Home Administrators that hold a current, valid health  
services executive designation (HSE) granted by the NAB as meeting the requirements of section  
16186(1)(b) of the code, MCL333.16186.  
The NAB established the HSE as an aspirational voluntary broad based qualification standard to support  
the following goals:  
•
•
Facilitate express licensure approval and transfer based on a common state standard  
Meet state licensure requirements for practice as an NHA, RCAL and/or HCBS administrator as  
required according to current state licensure requirements  
•
•
Promote consistency of the AIT and preceptor training experience across all jurisdictions  
Broaden academic programs to prepare graduates to meet the HSE qualification upon graduation  
Adoption of the proposed rule changes align with the White House Executive Order on Promoting  
Competition in the American Economy and the Federal Trade Commission’s Policy Perspectives on  
Options to Enhance Licensure Portability Options by removing barriers to licensure mobility.  
HSE Qualified Nursing Home Administrators have demonstrated a broad base of comprehensive  
knowledge through education, experience and examination, their qualification to practice as Nursing  
Home, Assisted Living and Home and Community based leaders. The proposed rule changes will  
facilitate express candidate qualification and welcome some of the most highly qualified nursing home  
administrators in the nation to practice in the state of Michigan.  
26 states have adopted the NAB HSE standard and we expect adoption in 30 states by June of 2024.  
Thank you for the opportunity to submit NAB’s comments in support of the proposed changes to the  
Administrative Rules for Nursing Home Administrators - General Rule Set 2022-67 LR.  
Respectfully submitted,  
Michelle Grachek, President and CEO  
Randy Lindner, CEO Emeritus  
1120 20th Street NW, Suite 750 | Washington, DC 20036-3441  
Phone: (202) 712-9040 | Fax (202) 216-9646 | www.nabweb.org | Email: nab@nabweb.org  
Archived: Wednesday, April 10, 2024 10:06:17 AM  
From: BPL-BoardSupport  
Sent: Tuesday, April 2, 2024 4:22:51 PM  
To: Marks, Dena (LARA)  
Subject: FW: Notice of Public Hearing - Nursing Home Administrators  
Response requested: No  
Sensitivity: Normal  
From: Rumsey, Dean H. <[email protected]>  
Sent: Tuesday, April 2, 2024 2:04 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Smith, Kimberly A.(Kim) <[email protected]>  
Subject: Notice of Public Hearing - Nursing Home Administrators  
CAUTION: This is an External email. Please send suspicious emails to [email protected]ov  
Hello, Iam writing to "comment" on the proposed rules elated to Nursing Home Administrators.  
As a nursing home administrator, the following feedback is not directly related to a portion of the proposed rule  
but more so suggestions related to how continuing education requirements are obtained.  
First, if possible, when MDHHS or any office constructs training opportunities for Nursing Homes in which the  
Nursing Home Administrator may attend, please consider obtaining continuing education units for this training.  
An example of this is the State funded Infection Control and Epidemiology training that MDHHS has arranged  
with the assistance of Association for Professionals in Infection Control and Epidemiology. This is very valuable  
and by offering CEU's, it may influence Administrators to attend. Imention this, as Idid attend and pass the  
course and inquired of MDHHS and learned they did not and would not attempt to gain CEU approval.  
Second, Iwould like to attend the meeting in person, but it is scheduled at the same date / time as the State of  
Michigan Joint Provider Surveyor Training session that is held by MDHHS and Administrators are influenced to  
attend. Hence, your schedules are in direct conflict, and this creates problems with our attendance.  
Third, as you finalize the administrative rules, is there a way in which the continuing education requirements could  
be clearly listed? Even through a portal in which a third party such as NAB could list and then as we obtain these  
continuing education requirements it would reflect. Especially as NAB is the body who grants permission for  
courses to award CEU's to attendees.  
Dean Rumsey, LHNA  
He, Him, His  
Director / Facility Administrator  
Corewell Health Rehabilitation and Nursing Center, Dearborn  
16391 Rotunda Drive  
Dearborn, MI 48120  
313.523.9024 Direct  
989.313.0785 Cell  
;