Archived: Monday, July 28, 2025 4:11:02 PM

From: BPL-BoardSupport

Sent: Fri, 25 Jul 2025 11:49:50

To: MacIntosh, Weston (LARA)

Subject: FW: Oakland University DPT Program Comment for public hearing 7.25.25 on Proposed PT Rules – Rule Set 2023-

53 LR (R 338.7132)

Importance: Normal

Sensitivity: None

Attachments:

OU DPT comments on proposed PT Rules R 338.7132 on 7.25.25.pdf;

Hi Wes,

Does this email go to you?

From: Sara Arena <[email protected]>

Sent: Thursday, July 24, 2025 9:18 AM

To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>

Cc: John Krauss <[email protected]>; Kevin Ball <[email protected]>

Subject: Oakland University DPT Program Comment for public hearing 7.25.25 on Proposed PT Rules – Rule Set 2023-53 LR (R

338.7132)

CAUTION: This is an External email. Please send suspicious emails to [email protected]v

Dear Department of Licensing and Regulatory Affairs Bureau of Professional Licensing (Attention:

Departmental Specialist),

Attached please find Oakland University’s comments regarding the proposed changes to the Physical Therapy

General Rules, specifically Rule R 338.7132. Iam submitting this on behalf of the Doctor of Physical Therapy

Program as part of the public hearing scheduled for July 25, 2025.

Please let me know if any additional information is needed.

Best regards,

Dr. Sara Arena

--

Sara Arena PT, MS, DScPT

Pronouns: she/her

Professor

Physical Therapy Program Director

Oakland University

School of Health Sciences

Physical Therapy Program

E-mail: arena@oakland.edu

Cell: 586-212-8117

July 25, 2025

Re: Public Hearing – Administrative Rules for Physical Therapy, Rule Set 2023-53 LR

Dear Michigan Department of Licensing and Regulatory Affairs,

Thank you for the opportunity to provide comments on the proposed changes to the Physical Therapy General Rules.

Oakland University, located in Rochester, Michigan, is a nationally recognized public doctoral research institution serving

nearly 16,000 students. The university offers more than 275 undergraduate and graduate programs, including the Doctor

of Physical Therapy. With a 17:1 student-to-faculty ratio, Oakland emphasizes personalized instruction, experiential

learning, and preparation for success in a global society. Its mission is to cultivate the full potential of a diverse and

inclusive community. As a public doctoral institution, Oakland advances education, research, scholarship, and creative

activity to benefit Michigan and the broader world.

On behalf of the Oakland University Physical Therapy Program, I respectfully submit the following recommendations

related to R 338.7132 – Licensure by Examination; Physical Therapist:

Recommendation 1:

Add a new subsection to Rule 32:

(d) The department will include an attestation requiring the applicant’s signature indicating that they have reviewed and

understand the Michigan Public Health Code and all other rules and regulations impacting physical therapy practice in

Michigan.

Rationale:

If the Michigan Physical Therapist Jurisprudence Exam is being eliminated, it remains essential to ensure that new

licensees understand the legal framework for practice. Attestation serves as a minimum safeguard to uphold public

protection and promote legal, ethical practice. Our DPT curriculum currently includes education on Michigan-specific laws

and regulations, and we believe all new graduates should be held to this same understanding.

Recommendation 2:

Include parallel attestation language in R 338.7145 – Licensure by Examination; Physical Therapist Assistant,

requiring PTA applicants to affirm their understanding of applicable laws and rules. The same rationale outlined above

applies.

Please feel free to contact me directly should you need further clarification or support regarding these recommendations.

Sincerely,

Sara Arena, PT, MS, DScPT

Professor and Director

Doctor of Physical Therapy Program

Oakland University

Archived: Monday, July 28, 2025 4:14:29 PM

From: Craig Miller

Mail received time: Fri, 25 Jul 2025 15:53:35

Sent: Friday, July 25, 2025 11:53:36 AM

To: BPL-BoardSupport BPL-BoardSupport

Cc: MacIntosh, Weston (LARA)

Subject: PT - General Rules comment

Importance: Normal

Sensitivity: None

Attachments:

LARA Public Comment.docx;

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Please see the attached written comments addressing the PT General Rules.

Thank you,

Craig Miller, PT, MPH

July 25, 2025

To: Department of Licensing and Regulatory Affairs Bureau of Professional Licensing

Re: Administrative Rules for Physical Therapy – General Rules

From: Craig T. Miller, PT, MPH

My name is Craig Miller, and I am respectfully submitting this written feedback along with my

verbal comments regarding the proposed changes to the Administrative Rules for Physical

Therapy. I want to make it clear that while I am a member and the current chairperson of the

Michigan Board of Physical Therapy, I am not providing these comments on behalf of the Board,

rather as a constituent and licensed physical therapist of Michigan. I received my degree in

physical therapy from Wayne State University in 1994, have been continuously licensed as a PT

in Michigan since 1995, and I received my master’s in public health from Eastern Washington

University in 2024. I have previously served as the Legislative Director for APTA-Michigan and

currently serve as a member of the Board of Directors for the Federation of State Boards of

Physical Therapy (FSBPT) which is the national organization that promotes safe and competent

physical therapy practice and is explicitly mentioned in the Administrative Rules. The focus of

my comments relates to the proposed removal of the jurisprudence examination in the PT

Administrative Rules. This is a proposal that I am opposed to and will provide several points as

to my reasoning why. The particular rule(s) in question are R338.7133(2) and R338.7145(2), as

well as the additional rules that would be affected including 7132(d), 7142(1)(d), 7134(3),

7136(1)(e), 7137(2)(d), 7146(3), 7148(1)(e), 7149(2)(d)



The principal tenet of the Public Health Code (PHC) and the Rules is to protect the

public. The RIS has a potential flaw in its summary which is that the question is asked

whether the proposed rules “exceed” that of other jurisdictions. However, in the view of

public protection it should also be examined whether the proposed rules significantly

undercut a level of safety as compared to other jurisdictions. The proposed removal of the

jurisprudence examination would be an example of this.



While the RIS correctly points to other jurisdictions that don’t have a jurisprudence

“examination,” what is missed in that statement is that all but 1 of those has a continuing

education requirement to satisfy that includes the jurisdictional laws & rules relating to

the practice of physical therapy. The only jurisdiction that deviates from this is New York

state, but it is notable that New York state provides a self-assessment/self-study on

jurisprudence that not only scores the outcome but also provides answers and points to

references for the rationale of the correct answers. Therefore, all but 1 of the Great Lakes

states noted in the RIS do have some form of jurisprudence requirement. Some of which

are not only at the time of initial licensure but at renewal as well. Removing the

jurisprudence requirement in Michigan would place Michigan at the lowest level as

compared to the others.



Michigan is the only jurisdiction in the U.S. that allows for endorsement of Canadian

physiotherapists and assistants. LARA does not report how many licensees have been

endorsed through this route. The province of Ontario requires a jurisprudence assessment

for initial licensure and at renewal.

The Commission on Accreditation of Physical Therapy Education (CAPTE) is the

accrediting body in the U.S. for PT and PTA programs. CAPTE does have a standard that

indicates programs are to provide education on a jurisdiction’s laws and rules, but this is

applicable only to the jurisdiction of the program. It is not reasonable to expect CAPTE

programs outside of Michigan to adequately train on our laws and rules. LARA does not

report what number or percent of licensees received their PT/PTA training outside of

Michigan.



Anyone who graduates from a non-CAPTE program has no expectation for training on

the laws & rules in Michigan. This is applicable to those trained outside of the U.S. and

according to the 2024 analysis by the FSBPT, between 15-16% of PT licensees in

Michigan graduated from non-CAPTE programs. This places Michigan near the top 5 of

states by percentage of non-CAPTE graduates receiving a license. Without a

jurisprudence requirement in some form, these individuals would never have been

required or given as a component of their education information on the laws and rules

governing PT practice in Michigan.



Public meetings were held by the Michigan Board of PT Rules Committee as well as the

Michigan Board of PT in October 2024 and April 2025 respectively. Both publicly held

meetings included discussion regarding the proposal for removal of the jurisprudence

examination. Both meetings resulted in the same recommendation, which was to NOT

remove the jurisprudence examination, except for those submitting for re-licensure in

cases where the license was lapsed for no more than 3-years.

. The following questions were raised; 1) what percentage of licensees

received their PT/PTA training at CAPTE programs outside of Michigan,

2) what percentage of licensees received their training at non-domestic

(non-CAPTE accredited) programs, and 3) is there a reportable number of

licensees obtained through endorsement for Canadian trained individuals?

These questions were felt to be important as that would give a potential

percentage of licensees who may have not been exposed to Michigan laws

and rules were the jurisprudence requirement removed.



There seems to be nominal if any burden on a applicant as the RIS notes the cost is $53,

and candidates can take the exam as many times as they need to “pass” with a score of at

least 75. Should there be burdens due to testing processes, then that should be looked at

to determine potential options such as an on-line Jurisprudence Assessment Module as

used in several U.S. jurisdictions, including Ohio, or some other alternatives to

demonstrate competency.



Another consideration is R338.7163 (4)(s) and (5)(s) regarding “Number of PDR credits

earned for activity”

o The self-assessment tool developed with the FSBPT was recently updated to have

9 active modules with the 10^thand final module expected to be available this year.

Therefore, I would propose that LARA consider accepting the full potentially

allowable PDRs of 10 during a licensee’s renewal period for both PTs and PTAs.

I am sincerely grateful for the time allowed to express these points. In summary, it would seem

to be ill-advised at this time to remove the jurisprudence examination as doing so would

eliminate the one method in establishing a minimal competency in knowledge of the laws and

rules governing the practice of physical therapy in Michigan. While I accept there is evidence

that accessibility to healthcare, including physical therapy is compromised, the public health

significance of providing assurance to Michiganians (Michiganders) as to the adequacy of

physical therapy providers knowledge of the laws and rules is of the utmost importance.

Respectfully submitted,

Craig T. Miller, PT, MPH

REFERENCES

Bolter, Kathleen, Timothy Bartik, Brad Hershbein, Michelle Miller-Adams, Lee Adams, Brian

Asquith, Alfonso Hernandez, Kyle Huisman, Iryna V. Lendel, Gabrielle Pepin, Bridget

Timmeney, Beth Truesdale, and Yulya Truskinovsky. 2024. "Policies for Place: How to Make

Sustainable Investments in Communities." Report prepared for the W.E. Upjohn Institute for

Employment Research. https://research.upjohn.org/reports/295

Commonwealth of Pennsylvania. (2025). 49 Pa. Code § 40.67. Continuing education for

licensed physical therapist. Pacodeandbulletin.gov.

https://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/049/chapter40/s40.

67.html

Federation of State Boards of Physical Therapy. (2024). FSBPT Census of Licensed Physical

Therapists and Physical Therapist Assistants in the United States 2024 (pgs. 23-25).

Granger, B. (2016). CLOSUP Student Working Paper Series Number 6 Policy Analysis: Brain

Drain in The State of Michigan. https://closup.umich.edu/sites/closup/files/uploads/student-

working-papers/closup-swp-6-Granger-Policy-Analysis-Brain-Drain-in-State-of-Michigan.pdf

Illinois Department of Financial and Professional Regulation. Continuing Education (C.E.) Hour

Requirements. (n.d.).

https://idfpr.illinois.gov/content/dam/soi/en/web/idfpr/renewals/apply/forms/ce-pt.pdf

Illinois Physical Therapy Association. Meeting the New Jurisprudence Requirement - Illinois

Physical Therapy Association. (2023). Ipta.org. https://www.ipta.org/news/654726/Meeting-the-

New-Jurisprudence-Requirement.htm

Indiana Professional Licensing Agency. (2022, December 20). Physical Therapy Licensing

Information. PLA. https://www.in.gov/pla/professions/physical-therapy-home/physical-therapy-

licensing-information/#Continuing_Competency_Information

New York State. (2025). NYS Physical Therapy: Laws, Rules & Regulations: Test Your

Knowledge. Nysed.gov. https://www.op.nysed.gov/professions/physical-therapists/laws-rules-

regulations/test-your-knowledge-law-and-practice

Ontario Legislative Assembly. (2014, July 24). Physiotherapy Act of 1991 – Ontario Regulation

532/98. Ontario.ca. https://www.ontario.ca/laws/regulation/980532

Saskatchewan College of Physical Therapists. (2024). Annual Individual License Renewal -

SCPT Saskatchewan College of Physical Therapists. Scpt.org.

https://www.scpt.org/site/individualrenewal?nav=sidebar

Archived: Monday, July 28, 2025 4:17:52 PM

From: BPL-BoardSupport

Sent: Fri, 25 Jul 2025 13:22:15

To: MacIntosh, Weston (LARA)

Subject: FW: Comments for LARA Public Hearing July 25, 2025

Importance: Normal

Sensitivity: None

Attachments:

25 LARA Public Hearing Jurispudence Exam 7 25 2025.pdf;

Here’s another!

From: Susan Talley <[email protected]>

Sent: Friday, July 25, 2025 8:01 AM

To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>

Subject: Comments for LARA Public Hearing July 25, 2025

CAUTION: This is an External email. Please send suspicious emails to [email protected]v

Department of Licensing and Regulatory Affairs

Bureau of Professional Licensing-Boards and Committees Section

P.O. Box 30670

Lansing, MI 48909-8170

Attention: Department Specialist

Email: BPL-BoardSupport@michigan.gov

Please see attached

Sue

July 24, 2025

Department of Licensing and Regulatory Aﬀairs

Bureau of Professional Licensing-Boards and Commiꢀees Secꢁon

P.O. Box 30670

Lansing, MI 48909-8170

Aꢀenꢁon: Department Specialist

Email: BPL-BoardSupport@michigan.gov

I am wriꢁng as a stakeholder, providing comments on the proposed amendments to the Physical Therapy

– General Rules. My comments speciﬁcally speak to the secꢁon that would disconꢁnue the use of a

Jurisprudence Exam as a requirement for physical therapist (PT) and physical therapist assistant (PTA)

licensure (R338.7133).

To provide some context: I have been a physical therapist for 49 years. I was a member of the PT faculty

at Wayne State University for 34 years (10 years as Program Director) as well as 7 years as Chair of the

PT Department at the University of Michigan-Flint. I have taught legal and ethical content relative to the

practice of physical therapy in both programs for many years. I have also been a guest speaker on the

topic. I was responsible for assisting students navigate the process of becoming a licensed PT. I have

actively advocated for legislative issues related to improving public health and safety, individually and as

well as a member of my professional association. My comments are developed within this context,

but to be clear, I am speaking for myself, do not represent the APTA Michigan nor any academic

insꢁtuꢁon.

I support the recommendaꢀon that the Michigan Jurisprudence exam for PT/PTAs, as it exists, be

disconꢀnued as a requirement for licensure. I do not say this lightly and agree that individuals applying

for PT/PTA licensure, as well as all those who are currently licensed, must pracꢁce within the legal

framework of the jurisdicꢁon and relevant federal and state requirements and there should be some

process at the state level to facilitate or measure this.

It is clear to me that the Jurisprudence Exam, in its present format, is one more barrier that

students/graduates face when applying for licensure. It is cumbersome for students to schedule, while

oꢂen having to rearrange their paꢁent schedules in the clinic during internships, ﬁnding ꢁme to travel to

a tesꢁng center and the ﬁnancial costs are burdensome.

I am uncomfortable with conꢁnuing to require the Jurisprudence exam for PT without evidence that it

makes a diﬀerence. LARA notes that only 3 of 28 health disciplines in the Michigan PHC require a

jurisprudence exam. There has not been an increased rate of complaint for those disciplines that don't

require it. Twenty-seven jurisdicꢁons in the US require a jurisprudence "exam" varying in rigor. As it

stands, it seems to me that the jurisprudence exam is more of a hoop to jump through rather than an

evidence-based approach to improve public health and safety.

I am conﬁdent that new PT and PTA graduates have suﬃcient understanding of jurisdicꢁonal and federal

laws to shape their professional pracꢁce. Accreditaꢁon standards require this as part of the explicit

curriculum. Although I am advocaꢁng disconꢁnuaꢁon of the current PT/PTA Jurisprudence exam, I

encourage LARA to collect data to clarify how well PTs and PTAs pracꢁce within the relevant laws and

regulaꢁons, deﬁne any problems idenꢁﬁed and develop evidence-based strategies to ensure conꢁnuing

competency in pracꢁcing within jurisdicꢁonal laws and rules in Michigan.

Thank you for your ꢁme. Please feel free to contact me if you have any quesꢁons or comments.

Sincerely,

Susan Ann Talley, PT, DPT, PhD

Physical Therapist, Reꢁred

248.854.5287

[email protected]