Archived: Tuesday, July 9, 2024 1:52:02 PM  
From: Walker, Dave A.  
Sent: Fri, 7 Jun 2024 15:28:04  
To: MacIntosh, Weston (LARA)  
Subject: Question on Psychology – General Rules  
Importance: Normal  
Sensitivity: None  
CAUTION: This is an External email. Please send suspicious emails to [email protected]  
Hi Weston,  
I am reviewing the draft Psychology – General Rules rule set and have two clarifying questions.  
1. 1. I am a bit confused by the changes in Rule 61. Specifically the difference between (1)(c)(i) and (1)(C)(ii). Is (i) related to the  
program/supervisor and (ii) related to the applicant? The RIS says “This rule pertains to application requirements for limited  
license psychologists. The rule revision clarifies the requirements for requesting approval of a post-degree practicum and the  
required credentials of a practicum supervisor.” So this seems to make sense.  
2. 2. Is the elimination of the continued education exemption for the period after initial licensure or pre-licensure? The way I am  
reading it (likely wrong) is that continued education must be completed before an applicant is even licensed, even if they just  
completed schooling (unless I missed another provision in the rule that discusses this.  
Thank you for any insights you could provide. This was the first time I had read this rule set, so I am unfamiliar. Have a great weekend!  
Best,  
Dave  
David A. Walker, MPA  
(He/him/his)  
Public Policy Advisor  
616.391.2043 Direct  
202.821.8217 Cell (preferred)  
corewellhealth.org  
648 Monroe Ave NW | MC 6841  
Grand Rapids, MI 49503  
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Archived: Tuesday, July 9, 2024 1:52:08 PM  
From: BPL-BoardSupport  
Sent: Mon, 8 Jul 2024 13:42:44  
To: MacIntosh, Weston (LARA)  
Subject: FW: Psychology – General Rules (MOAHR #2023-052 LR)  
Importance: Normal  
Sensitivity: None  
Attachments:  
MHA Comments_Psychology Proposed Rules_final.pdf;  
From: Kelsey Ostergren <[email protected]>  
Sent: Monday, July 8, 2024 8:47 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Lauren LaPine <[email protected]g>  
Subject: Psychology – General Rules (MOAHR #2023-052 LR)  
CAUTION: This is an External email. Please send suspicious emails to [email protected]ov  
Good Morning,  
On behalf of the MHA and its members, please see the attached comments on the psychology rule set (MOAHR #2023-052 LR).  
Best,  
Kelsey  
Kelsey Ostergren, MPH, CIC | Director, Health Policy Initiatives  
Michigan Health & Hospital Association  
Office: (517) 886-8405 | Cell: (517) 614-5454  
[email protected] | www.mha.org  
July 8, 2023  
Departmental Specialist  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing– Boards and Committees Section  
P.O. Box 30670  
Lansing, MI 48909-8170  
Re: Psychology – General Rules (MOAHR #2023-052 LR)  
Dear Department Specialist:  
On behalf of Michigan’s 130 community hospitals, the Michigan Health & Hospital Association (MHA)  
appreciates the opportunity to comment on the Department of Licensing and Regulatory Affairs  
(LARA) proposed rules for Psychology. The MHA is the statewide membership organization  
representing all community hospitals in Michigan. Membership ranges from critical access hospitals in  
rural areas of the Upper Peninsula to large, urban, tertiary care centers in the heart of Detroit – and  
everything in between. Our mission is to advance the health of individuals and communities.  
R 338.2553  
Reducing the number of times an educational limited license can be renewed, from 5 to 4, may limit  
the number of individuals who complete their postdoctoral experience and ultimately become  
licensed. Allowing an individual to use an educational limited license for less time will limit the hands-  
on experience obtained and may result in a lower pass rate for the licensure exam. Given ongoing  
healthcare provider shortages, particularly in behavioral-health related professions coupled with  
recruitment challenges for psychologists, this modification will inadvertently restrict the number of  
eligible applicants for a full licensure, thereby continuing to perpetuate these shortages. MHA  
strongly recommends that LARA does not reduce the number of times an educational limited  
license can be renewed to ensure everyone who can become fully licensed, does.  
R 338.2561  
MHA seeks additional clarity on who is subject to the requirements for board approval of a post-  
degree practicum. As written, there is conflicting information in the Regulatory Impact Statement (RIS)  
and the rule revision about whether this language applies to the program supervisor or the applicant.  
The remaining details to be included in the written submission to the board is appropriate and MHA  
supports the alignment of practicum requirements for post-master’s degree individuals with  
those in place for master’s degree students. This ensures that the training and experience of all  
limited license psychologists is consistent, regardless of when the practicum was completed.  
Regarding practicum supervision, MHA would encourage LARA to provide clarity around whether  
the practicum must be supervised by the same psychologist for 2 hours per week, or if it can be  
split between multiple individuals who meet the requirements. Member hospitals report that  
supervision of some practicums is split between a licensed psychologist at the graduate school and an  
on-site psychologist, and are unclear on whether that would be allowed under the new rule.  
R 338.2581  
The revision to require continuing education (CE) during the initial license cycle will enhance  
professional competency and ensure newly licensed individuals have the knowledge and skills  
needed to be successful throughout their career. It also provides standardization amongst  
MHA Comments – LARA Psychology – General Rules - MOAHR #2023-052  
July 8, 2024  
Page 2  
professionals, requiring all licensed psychologists must complete the same level of CEs, regardless of  
when licensure was obtained.  
MHA encourages LARA to revise this language so it is clear that CEs are required during the first  
two-years after licensure. As currently written, it was interpreted by hospital staff who thought the  
rule required obtaining CEs prior to applying for licensure, which MHA does not believe is the intent.  
R 338.2583  
MHA supports the inclusion of implicit bias training as an acceptable continuing education (CE) activity  
for psychologists and appreciates the inclusion of the Community Mental Health Association as an  
eligible CE provider. LARA should also consider adding a general clause that permits any entity  
meeting LARA-defined criteria, to offer CEs for psychologists that can be used towards  
recertification. Provision of high-quality programming is important to ensure psychologists are  
apprised of emerging literature and evidence-based practices in the field, and expansion of eligible  
providers who can offer these opportunities is important.  
Thank you for the opportunity to comment. MHA remains committed to expanding access to highly-  
trained behavioral health professions, recognizing the important role psychologists play in addressing  
the mental health crisis. MHA is available to discuss any of these comments further and look forward to  
continued partnership with LARA on the topic. Please contact MHA Director, Health Policy Initiatives,  
Kelsey Ostergren at kostergren@mha.org, with additional questions.  
Sincerely,  
Kelsey Ostergren  
Director, Health Policy Initiatives  
Michigan Health & Hospital Association  
;