Archived: Wednesday, March 20, 2024 10:37:56 AM
From: BPL-BoardSupport
Sent: Tue, 27 Feb 2024 16:48:03
Subject: FW: Chiropractic Rule Comments
Importance: Normal
Sensitivity: None
From: Martha O'Connor <[email protected]>
Sent: Tuesday, February 27, 2024 11:30 AM
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>
Subject: Chiropractic Rule Comments
CAUTION: This is an External email. Please send suspicious emails to [email protected]ov
Dear Bureau of Professional Licensing:
I have reviewed the proposed changes to the Chiropractic – General Rules and have the following comments related to
satisfying continuing education requirements for both relicensure and renewal of a license.
Under R 338.12036(1)(c)(ii), it says “Not more than 15 continuing education hours in distance learning programs.” This
limitation on the use of distance learning programs for satisfying continuing education requirements is overly burdensome
and unnecessary for relicensure applicants, requiring the expenditure of extra money, time, and travel, and is unlike the
continuing education requirements for most other professions. The Department should strike this requirement and remove
it from the rules. The removal of this requirement would accordingly move the content of R 338.12036(1)(c)(i), with proper
editing, to R 338.12036(1)(c).
Under R 338.12036(2)(d)(i)(C), it says “Not more than 15 continuing education hours in distance learning programs.” This
limitation on the use of distance learning programs for satisfying continuing education requirements is overly burdensome
and unnecessary for relicensure applicants, requiring the expenditure of extra money, time, and travel, and is unlike the
continuing education requirements for most other professions. The Department should strike this requirement and remove
it from the rules.
Under R 338.12041(1)(b), it says “Not less than 15 hours of continuing education must be completed by attending a live, in-
person program.” This live, in-person requirement for satisfying continuing education requirements is overly burdensome
and unnecessary for license renewals, requiring the expenditure of extra money, time, and travel, and is unlike the
continuing education requirements for most other professions. The Department should strike this requirement and remove
it from the rules.
Under R 338.12041(2)(a), it says, “Attendance at or participation in a continuing education program or activity related to the
practice of chiropractic, or any non-clinical subject relevant to the practice of chiropractic education, administration,
management, or science, which includes, but is not limited to, live in-person programs, interactive or monitored
teleconferences, audio-conferences, web-based programs, online programs, and review of journal articles or other self-study
programs approved or offered by the Michigan Association of Chiropractors (MAC) according to the following:”. This
provision places the MAC at an unfair, competitive advantage over other providers of continuing education both inside and
outside this state and is overly burdensome to licensees, especially licensees found outside this state. Approximately 75% of
states throughout the country currently recognize Providers of Approved Continuing Education (PACE) of the Federation of
