Implicit bias training is now a state requirement for all healthcare professionals in Michigan. Last September 21, 2021, the Bureau of Professional Licensing (BPL) within the Department of Licensing and Regulatory Affairs (LARA) of Michigan revised the Michigan Public Health Code – General Rules to include mandatory training on implicit bias for all healthcare professionals.
The new requirement applies to both new applicants and those renewing their existing licenses or registrations, starting on June 1, 2022.
This article explains all you need to know about this new Michigan requirement: what implicit bias training is, what professions need the training, and the specifics required to satisfy the new state requirement.
What is Implicit Bias Training?
According to the new rule added to Michigan’s Public Health Code, implicit bias is defined as “an 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 characteristics."
Starting June 1, 2022, applicants for renewal, reregistration, or re-licensure for all healthcare professions must complete a minimum of 1 hour of implicit bias training for each year of the applicant’s license cycle. This is on top of any continuing education requirement already set by the various boards of healthcare professionals in the state of Michigan.
For example, if you are a pharmacist, you renew your license every 2 years. This means that on top of the 30 contact hours of continuing education that is required of pharmacists for every renewal, you must also complete 2 hours of training on implicit bias.
Training on implicit bias is also required as a condition for initial licensure.
Who needs to comply with the new rule?
All professions licensed or registered under the Michigan Public Health Code (except for Veterinary Medicine) are required to undergo training on implicit bias once a year.
This includes the following healthcare professions:
Dental Hygienist CE Requirements
Dental Assistant CE Requirements
Medical Doctor CME Requirements & Physician Assistant CME Requirements
Osteopathic Physician CME Requirements
Registered Nurse CE Requirements
Licensed Practical Nurse CE Requirements
Advanced Practice Registered Nurse CE Requirements
Pharmacist CE Requirements & Pharmacy Technician CE Requirements
Physical Therapist CE Requirements
Physical Therapy Assistant CE Requirements
When does this requirement begin?
The new requirement took effect on June 1, 2022, a year after the rule's promulgation. If you renew your license on or after June 1, 2022, training is required.
The training is also mandatory for all new applications for licensure or registrations received on or after June 1, 2022.
How many hours of implicit bias training do I need?
New applicants for licensure or registration must complete 2 hours of implicit bias training within 5 years immediately before they are issued a license or registration.
Those renewing their licenses or registrations must complete 1 hour of the training for every year of their license cycle.
However, since this new rule has only been promulgated last June 1, 2021, for the first renewal after June 1, 2021, licensees will only need to complete 1 hour for each renewal cycle. For example, if you are on a 3-year license renewal cycle and you are scheduled to renew in September 2022, you will only be required to renew 1 hour of the required training. Licensees will only need to have 1 hour for each year since the rule’s promulgation last June 1, 2021.
Subsequent renewals will require 1 hour of training for each year of the license or registration cycle.
The rule does not require one hour of training IN each year of the license cycle, only one hour FOR each year of the license or registration cycle. This means that if you have a 3-year license renewal cycle, you have the option to complete all 3 hours of training required in one sitting or to break the training into one 1-hour session per year.
Who can provide training?
Licensees may satisfy the new training requirement through an approved continuing education program.
The new rule has outlined accepted sponsors of the new continuing education requirement. The following trainings and its sponsors are accepted in the new rule:
Training offered by a nationally-recognized or state-recognized health-related organization.
Training offered by, or with, a state or federal agency.
Training obtained in an educational program that has been approved by any board
Training offered by an accredited college or university.
An organization specializing in diversity, equity, and inclusion issues.
The new rule also requires licensees to 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.
What kind of training satisfy the new requirement?
Effective March 23rd, 2023, Rule 338.7004(3)(d) now states the following:
(d) Acceptable modalities of training include any of the following: (i) A teleconference or webinar that allows live synchronous interaction that provides for the opportunity for participants to interact with the instructor and other participants. (ii) A live presentation that provides for the opportunity for participants to interact with the instructor and other participants. (iii) An asynchronous teleconference or webinar
This means that online methods (or asynchronous) webinars are acceptable to complete your implicit training hours.
How will this new rule be enforced?
During application or renewal, an applicant, licensee, or registrant will attest to compliance with the new rule. The department may select and audit a sample of licensees or registrants and request documentation of proof of compliance with the rule. If audited by the department, a licensee or registrant shall provide proof of completion of training. This proof can be either a completion certificate issued by the training program that includes the date of the training, the program sponsor’s name, the program's title, and the licensee’s or registrant’s name or it can be a completion record reported to CE Broker on your behalf. CE Broker is the official CE and CME tracking system for Michigan LARA. While not mandated to prove CE or CME compliance before license renewal, audits are handled through the CE Broker platform. AchieveCE automatically reports all CE completions to CE Broker within 24 business hours where the state uses the platform. In the event of an audit, your CE records will be in CE Broker proactively. Be sure to enter the right license information for fast and accurate reporting.
Where can I find courses that meet this new requirement?
As a Michigan Board-recognized provider, AchieveCE can meet your needs for the implicit bias training requirement! Courses like Michigan Implicit Bias Training - 3 Credits & Paths Forward for Diversity, Equity, and Inclusion in Healthcare - 2 CE presented by Andrea Sikora, PharmD, MSCR, BCCCP, FCCM are now available to take for Michigan healthcare professionals looking to complete their biennial or triannual cycle obligations.
Luke Porter
Founder
