Sept. 21, 2020  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing  
Boards and Committees Section  
Genetic Counseling – General Rules  
ARS #2020-37 LR  
Attention: Policy Analyst  
P.O. Box 30670  
Lansing, MI 48909  
Dear Policy Analyst:  
On behalf of the Michigan Health & Hospital Association (MHA), we respectfully submit the  
following comments on the proposed Genetic Counseling – General Rules.  
Under the Rule 338.2473, Rule 173 (2)(a), the MHA recommends adding the following to the  
acceptable continuing education organizations list:  
American College of Obstetricians and Gynecologists  
Society for Maternal Fetal Medicine  
American Society for Reproductive Medicine  
Also, the MHA would request adding language in this section giving the Board the ability to  
approve other educational organizations in the future. This will grant the Board flexibility and  
ensure the rules remain modern to keep up with the changing environment of genetic  
counseling.  
Thank you for your consideration of our comments. Please reach out to Paige Fults  
(pfults@mha.org) with questions.  
Respectfully submitted,  
Adam Carlson  
Senior Director, Government & Political Affairs  
Michigan Health & Hospital Association  
Desk: (517) 886-8245 | Cell: (269) 757-2479  
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