Political Alert! Critical Social Justice Begins to Shape Licensure Requirements

The Michigan Licensing board (LARA) has just amended its licensure requirements based on recent changes to the state Public Health Code. Counselors are now required to undergo “Implicit Bias Training” to become licensed, and must continue to receive Implicit Bias Training (1 hour) every year.Strikingly, the state of Michigan has zero (0!) requirements for continuing education for therapists. So in the state of Michigan, it is now officially more important to be trained in Implicit Bias than it is to have ongoing development of oneself in how to do good therapy.

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS   BUREAU OF PROFESSIONAL LICENSING   PUBLIC HEALTH CODE—GENERAL RULES   (By authority conferred on the director of the department of licensing and regulatory   affairs by sections 16145, 16194, 16201, and 16221(e)(iv)(B) of the public health code,   1978 PA 368, MCL 333.16145, 333.16194, 333.16201, and 333.16221, and Executive   Reorganization Order Nos. 1991-9, 1996-2, 2003-1, and 2011-4, MCL 338.3501,   445.2001, 445.2011, and 445.2030

R 338.7004 Implicit bias training standards.   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

   

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  

3 comments

  1. This is so incredibly stupid. The implicit bias tests have zero predicitive validity and poor test-retest. Numerous studies show it does not work. Psychologists should know better. I need anger management!

  2. I think that I saw a comment the other day from a physician stating that he would let licensure lapse rather than comply with this requirement. A shame as far as I am concerned, but that is his choice.

    I anticipate similar requirements where I am for licensure. As matters now stand, my quick calculation is that more than one fourth of continuing education requirements are on topics mandated by the state/licensing board. It won’t take but a little tweak here or there to add new requirements. A lot is being required under the rubric of “public health.”

    There are so many things that I want to learn about, I regret the intrusion of the regulatory body into my ongoing education. Please don’t take that statement to an extreme. I understand there are basics that need to be learned and updated, as well as new developments. I just do not like the steady erosion of choice occurring in the professions and in life generally.

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