LARA Updates Implicit Bias Training Rules

The Michigan Department of Licensing and Regulatory Affairs (LARA) recently released the final draft of the Public Health Code – General Rules to allow asynchronous teleconference or webinars as acceptable modality of training as part of the implicit bias training standards. Webinars and asynchronous teleconference were previously prohibited because they didn’t allow for interaction between students and the instructor. These rules will be filed with the Joint Committee on Administrative Rules and become effective March 23, 2023

Under the updated rules, individuals applying to renew their license will be allowed to satisfy the implicit bias training standard through webinars offered by acceptable sponsors. Another positive rule change is the allowance of implicit bias training to satisfy other training or continuing education requirements.

Members with questions should contact Renée Smiddy at the MHA.

LARA Rules Requiring Implicit Bias Training Take Effect June 1

The Department of Licensing and Regulatory Affairs (LARA) revised Public Health Code Rules requiring implicit bias training for all professions licensed or registered under the Public Health Code, except for Veterinary Medicine, effective June 1.

First-time applicants for licensure or registration must have completed a minimum of two hours of implicit bias training within the previous five years.

Beginning June 1, those renewing licenses or registrations must complete one hour of implicit bias training for each year of their license or registration cycle. However, for renewal applications submitted between the rule’s promulgation date of June 1, 2021, and May 31, 2022, only one hour of training is required. This includes licensees whose 90-day renewal window includes June 1, 2022. For example, a license scheduled for renewal in August 2022 can be renewed in May, requiring only one hour of training regardless of the length of the license or registration cycle. Subsequent renewals would require an hour of training for each year of the license or renewal cycle.

Documentation of this training must be retained for six years from the date of applying for licensure, registration or renewal. The department retains the right to audit licensees or registrants and request documentation of completion of training.

The department released a frequently asked questions document for implicit bias training, which includes clarification that trainings with prerecorded videos must also provide opportunities for interaction between participants and the instructor. Therefore, prerecorded videos without instructor interaction would not satisfy the implicit bias training standard.

Members with questions related to implicit bias training requirements may contact the Bureau of Professional Licensing. For more information, contact Renée Smiddy at the MHA.