Implicit Bias Training – Requirements for License Renewal

Dear Licensee –

The Bureau of Professional Licensing (BPL) within the Department of Licensing and Regulatory Affairs (LARA) would like to inform you that the Public Health Code – General Rules have been revised which will require implicit bias training for your profession, effective June 1, 2022.

The new training requirements are the product of numerous workgroup meetings over the past year and represent feedback from 86 organizations including our health professional boards, insurance providers, health systems, health care associations, legislators, state agencies, higher education, and community and advocacy groups. The requirements apply to both new applicants as well as those renewing their existing licenses or registrations.

Below are the changes in the rules that pertain to the new training requirements:

• The term “implicit bias” is defined as:

(A)n attitude or internalized stereotype that affects an individual’s perception, action, or decision making in an unconscious manner and often contributes to unequal treatment of people based on race, ethnicity, nationality, gender, gender identity, sexual orientation, religion, socioeconomic status, age, disability, or other characteristic. (R 338.7001 (c) )

• Specifically, the new rule (R 338.7004) requires the following:

Rule 4. (1) Beginning 1 year after promulgation of this rule, an applicant for licensure or registration under article 15 of the code, MCL 333.16101 to 333.18838, except those seeking to be licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall have completed a minimum of 2 hours of implicit bias training within the 5 years immediately preceding issuance of the license or registration.

(2) Beginning 1 year after promulgation of this rule and for every renewal cycle thereafter, in addition to completing any continuing education required for renewal, an applicant for license or registration renewal under article 15 of the code, MCL 333.16101 to 333.18838, except those licensed under part 188 of the code, MCL 333.18801 to 333.18838, shall have completed a minimum of 1 hour of implicit bias training for each year of the applicant’s license or registration cycle.

(3) The implicit bias training must be related to reducing barriers and disparities in access to and delivery of health care services and meet all of the following requirements:

(a) Training content must include, but is not limited to, 1 or more of the following topics:

(i) Information on implicit bias, equitable access to health care, serving a diverse population, diversity and inclusion initiatives, and cultural sensitivity.
(ii) Strategies to remedy the negative impact of implicit bias by recognizing and understanding how it impacts perception, judgment, and actions that may result in inequitable decision making, failure to effectively communicate, and result in barriers and disparities in the access to and delivery of health care services.
(iii) The historical basis and present consequences of implicit biases based on an individual’s characteristics.
(iv) Discussion of current research on implicit bias in the access to and delivery of health care services.

(b) Training must include strategies to reduce disparities in access to and delivery of health care services and the administration of pre- and post-test implicit bias assessments.

(c) Acceptable sponsors of this training include any of the following:

(i) Training offered by a nationally-recognized or state-recognized health-related organization.
(ii) Training offered by, or in conjunction with, a state or federal agency.
(iii) Training obtained in an educational program that has been approved by any board created under article 15 of the code, MCL 333.16101 to 333.18838, except under part 188 of the code, MCL 333.18801 to 333.18838, for initial licensure or registration or for the accumulation of continuing education credits.
(iv) Training offered by an accredited college or university.
(v) An organization specializing in diversity, equity, and inclusion issues.

(d) Acceptable modalities of training include any of the following:

(i) A teleconference or webinar that permits live synchronous interaction.
(ii) A live presentation.
(iii) Interactive online instruction.

(4) Submission of an application for licensure, registration, or renewal constitutes an applicant’s certificate of compliance with the requirements of this rule. A licensee or registrant shall retain documentation of meeting the requirements of this rule for a period of 6 years from the date of applying for licensure, registration, or renewal. The department may select and audit a sample of a licensees or registrants and request documentation of proof of compliance with this rule. If audited by the department, a licensee or registrant shall provide the proof of completion of training, including either of the following:

(a) A completion certificate issued by the training program that includes the date of the training, the program sponsor’s name, the title of the program, and licensee’s or registrant’s name.

(b) A self-attestation by the licensee or registrant that includes the date of the training, the program sponsor’s name, the title of the program, and licensee’s or registrant’s name.

Please send any questions you may have about these revised rules to BPLHelp@michigan.gov .

Thank you,

Debra Gagliardi, Director
Bureau of Professional Licensing
Department of Licensing and Regulatory Affairs

LARA is an equal opportunity employer/program.

Auxiliary aids, services and other reasonable accommodations are available upon request to individuals with disabilities.

BUREAU OF PROFESSIONAL LICENSING
P.O. BOX 30670· LANSING, MICHIGAN 48909
www.michigan.gov/bpl

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