REGULATORY IMPACT STATEMENT and COST-BENEFIT ANALYSIS PART 1: INTRODUCTION

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1 Michigan Department of Licensing and Regulatory Affairs Office of Regulatory Reinvention 611 W. Ottawa Street; 2nd Floor, Ottawa Building PO Box 30004; Lansing, MI Phone (517) FAX (517) REGULATORY IMPACT STATEMENT and COST-BENEFIT ANALYSIS PART 1: INTRODUCTION In accordance with the Administrative Procedures Act (APA) [1969 PA 306], the department/agency responsible for promulgating the administrative rules must complete and submit this form electronically to the Office of Regulatory Reinvention (ORR) no less than (28) days before the public hearing [MCL (3)-(4)]. Submissions should be made by the departmental Regulatory Affairs Officer (RAO) to The ORR will review the form and send its response to the RAO (see last page). Upon review by the ORR, the agency shall make copies available to the public at the public hearing [MCL (4)]. Please place your cursor in each box, and answer the question completely. ORR-assigned rule set number: LR ORR rule set title: Social Work General Rules Department: Licensing and Regulatory Affairs Agency or Bureau/Division Bureau of Health Care Services Name and title of person completing this form; telephone number: Elaine M. Barr, Policy Analyst Reviewed by Department Regulatory Affairs Officer: Liz Arasim Department of Licensing and Regulatory Affairs

2 Regulatory Impact Statement and Cost-Benefit Analysis Page 2 MCL a Small business defined. PART 2: APPLICABLE SECTIONS OF THE APA Sec. 7a. Small business means a business concern incorporated or doing business in this state, including the affiliates of the business concern, which is independently owned and operated and which employs fewer than 250 full-time employees or which has gross annual sales of less than $6,000, MCL Reducing disproportionate economic impact of rule on small business; applicability of section and MCL (3). Sec. 40. (1) When an agency proposes to adopt a rule that will apply to a small business and the rule will have a disproportionate impact on small businesses because of the size of those businesses, the agency shall consider exempting small businesses and, if not exempted, the agency proposing to adopt the rule shall reduce the economic impact of the rule on small businesses by doing all of the following when it is lawful and feasible in meeting the objectives of the act authorizing the promulgation of the rule: (a) Identify and estimate the number of small businesses affected by the proposed rule and its probable effect on small businesses. (b) Establish differing compliance or reporting requirements or timetables for small businesses under the rule after projecting the required reporting, record-keeping, and other administrative costs. (c) Consolidate, simplify, or eliminate the compliance and reporting requirements for small businesses under the rule and identify the skills necessary to comply with the reporting requirements. (d) Establish performance standards to replace design or operational standards required in the proposed rule. (2) The factors described in subsection (1)(a) to (d) shall be specifically addressed in the small business impact statement required under section 45. (3) In reducing the disproportionate economic impact on small business of a rule as provided in subsection (1), an agency shall use the following classifications of small business: (a) 0-9 full-time employees. (b) full-time employees. (c) full-time employees. (4) For purposes of subsection (3), an agency may include a small business with a greater number of full-time employees in a classification that applies to a business with fewer full-time employees. (5) This section and section 45(3) do not apply to a rule that is required by federal law and that an agency promulgates without imposing standards more stringent than those required by the federal law. MCL (3) Except for a rule promulgated under sections 33, 44, and 48, the agency shall prepare and include with the notice of transmittal a regulatory impact statement containing (information requested on the following pages). [Note: Additional questions have been added to these statutorily-required questions to satisfy the costbenefit analysis requirements of Executive Order ] MCL b Information to be posted on office of regulatory reinvention website. Sec. 45b. (1) The office of regulatory reinvention shall post the following on its website within 2 business days after transmittal pursuant to section 45: (a) The regulatory impact statement required under section 45(3). (b) Instructions on any existing administrative remedies or appeals available to the public.

3 Regulatory Impact Statement and Cost-Benefit Analysis Page 3 (c) Instructions regarding the method of complying with the rules, if available. (d) Any rules filed with the secretary of state and the effective date of those rules. (2) The office of regulatory reinvention shall facilitate linking the information posted under subsection (1) to the department or agency website.

4 Regulatory Impact Statement and Cost-Benefit Analysis Page 4 PART 3: DEPARTMENT/AGENCY RESPONSE Please place your cursor in each box, and provide the required information, using complete sentences. Please do not answer the question with N/A or none. Comparison of Rule(s) to Federal/State/Association Standards: (1) Compare the proposed rule(s) to parallel federal rules or standards set by a state or national licensing agency or accreditation association, if any exist. Are these rule(s) required by state law or federal mandate? If these rule(s) exceed a federal standard, please identify the federal standard or citation, and describe why it is necessary that the proposed rule(s) exceed the federal standard or law, and specify the costs and benefits arising out of the deviation. The proposed rules rescind the existing Board of Social Work rules and reorganize the rules under new rule numbers using a logical format and concise language. The rules, in part, establish requirements for licensure, supervision, relicensure, and maintenance of licensure for social service technicians and bachelor s and master s level social workers. There are no parallel federal rules or standards or national licensing or accreditation agency. However, the rules do adopt by reference the accreditation standards of post-secondary accrediting organizations recognized by the Council for Higher Education Accreditation and the procedures and criteria of the U.S. Department of Education for post-secondary programs. Each state establishes its own requirements for the regulation of the practice of social work. These rules are required by the Michigan Public Health Code. The Department, in consultation with the board, is statutorily authorized to promulgate rules pursuant to: MCL (2) which states A board or task force may promulgate rules necessary or appropriate to fulfill its functions as prescribed in this article. MCL (3) which states Only a board or task force shall promulgate rules to specify requirements for licenses, registrations, renewals, examinations, and required passing scores. MCL (1) which states, in relevant part, The department shall promulgate rules to include training standards for identifying victims of human trafficking required for individuals licensed or registered under this article MCL : which states, in pertinent part, (1) Beginning the license renewal cycle after the effective date of the rules promulgated under this section, an individual licensed under this part shall meet the continuing education requirements of this section when renewing his or her license.(2) The department, in consultation with the board, shall promulgate rules to require a licensee seeking renewal to furnish evidence that during the 3 years immediately preceding application for renewal, the licensee attended continuing education courses or programs related to the practice of social work and designed to further educate licensees.(3) The department, in consultation with the board, shall establish by rule the total number of course or program clock hours at a minimum of 45 clock hours in any 3-year license renewal cycle. A portion of those clock hours must be in social work ethics

5 Regulatory Impact Statement and Cost-Benefit Analysis Page 5 MCL which states The department shall promulgate rules regarding the minimum training requirements for the practice of social work at the bachelor s level and for the practice of social work at the master s level. MCL The board shall promulgate rules requiring each applicant for license renewal to complete as part of the continuing education requirement of subsection (1) an appropriate number of hours or courses in pain and symptom management. (2) Compare the proposed rule(s) to standards in similarly situated states, based on geographic location, topography, natural resources, commonalities, or economic similarities. If the rule(s) exceed standards in those states, please explain why, and specify the costs and benefits arising out of the deviation. EXAMINATIONS: The proposed rules will add a requirement that to obtain a second master s level designation, the applicant must complete the approved examination that is applicable to the designation sought. The current rules do not require the completion of a second exam, but only completion of an additional 2,000 hours of post-degree social work experience in the second specialty designated area. All states that have an Advanced Generalist or Macro master s level licensure or designation available have a requirement that the applicant complete the second examination for the second licensure or designation, in addition to completion of the full supervised experiential requirements. CONTINUING EDUCATION: The required number of continuing education hours is set at a minimum by statute in Michigan in MCL The Board has retained the statutory minimum number of hours for license renewal and expanded the number and kind of opportunities that a licensee may seek to earn by including accredited colleges and universities as automatically approved providers of continuing education courses and materials. (3) Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed rule(s). Explain how the rule has been coordinated, to the extent practicable, with other federal, state, and local laws applicable to the same activity or subject matter. This section should include a discussion of the efforts undertaken by the agency to avoid or minimize duplication. The Department is not currently aware of any laws, rules, or legal requirements that duplicate, overlap, or conflict with the proposed rules. Purpose and Objectives of the Rule(s): (4) Identify the behavior and frequency of behavior that the proposed rule(s) are designed to alter. Estimate the change in the frequency of the targeted behavior expected from the proposed rule(s). Describe the difference between current behavior/practice and desired behavior/practice. What is the desired outcome? The Board of Social Work General Rules have not been revised since the licensure process was first implemented in The rules will be given new rule numbers and reorganized into logical parts. Additionally, the rules will be revised to conform to statutory requirements, to expand continuing education opportunities, and to clarify requirements for obtaining each master s level designation. Rules through will be rescinded. Some of the content of these rules will be added to new rules in R through R PART 1: General Provisions

6 Regulatory Impact Statement and Cost-Benefit Analysis Page 6 R Definitions. Many of the definitions in the current rules will not be in the revised rules, as they are either not used in the rules or are duplicative of the statute. R Educational standards. This rule will set forth the adoption by reference of educational standards for social work programs. The references will be updated to reflect current standards. R Examination adoption. This rule adopts the Association of Social Work Boards (ASWB) examinations for bachelor s and master s level social workers. R Prohibited conduct. The revised rule will change the length of time before a social worker is permitted to be involved with or solicit a sexual relationship with a former client or members of a former client s family from 3 years to 7 years. This requirement is being changed to match the Social Work Code of Ethics. R Human trafficking training standards. This rule will be added to address the human trafficking training requirements created in 2014 PA 343, MCL PART 2: Social Service Technician Requirements R This rule will describe the limited social service technician registration requirements. This rule will be updated to comply with MCL R This rule will provide the requirements for social service technician registration. This rule will be revised to comply with MCL R Requirements for registration by endorsement. The rule will be revised to require that an applicant s license shall be verified by the licensing agency of all other states of the United States in which the applicant holds a current license or ever held a license as a social worker. If applicable, verification shall include the record of any disciplinary action taken or pending against the applicant. R Requirements for reregistration of a social service technician. The content of the rule will be the same, but will be updated to include the appropriate statutory citations. PART 3: Bachelor s Social Worker Requirements R Limited bachelor s social worker requirements. The rule will be updated to define an approved agency, in accordance with MCL of the Code. R Bachelor s social worker license by examination and limited license requirements. The rule will be edited to create conformity with the statute, specifically by removing the language providing for alternate supervision. However, this rule will be amended to make the individual supervision requirement less burdensome on the prospective licensee, as the supervision will no longer need to be completed strictly in person, but may instead be completed using a telecommunication method that provides for live, simultaneous contact. Additionally, the rule will be amended to clarify that experience in the limited license status can be earned in a volunteer or employment setting. R Licensure by endorsement. The rule will be revised to require that an applicant s license shall be verified by the licensing agency of all other states of the United States in which the applicant holds a current license or ever held a license as a social worker. If applicable, verification shall include the record of any disciplinary action taken or pending against the applicant. R Relicensure of bachelor s level social worker requirements. Currently, the administrative rules merely require adherence to MCL for applicants seeking relicensure. The revised rule will create a tiered system of requirements depending on how long the social worker has had his or her license lapsed. All applicants for relicensure must submit an application and fee and appropriate

7 Regulatory Impact Statement and Cost-Benefit Analysis Page 7 continuing education. Applicants who have been lapsed for 3 years or longer must complete 1,000 hours of supervised experience under a licensed master s level social worker, and those who have been lapsed more than 7 years must retake the appropriate examination. Basically, the longer a licensee has been out of practice, the more stringent the requirements will be to gain re-entry to practice. PART 4: Master s Social Worker Requirements R Limited Master s social work license requirements. The revised rule will define when an agency is considered approved by the board, as required by MCL R Master s social worker licensure requirements, generally. This rule will be added to describe the general requirements for both master s social worker designations. This rule will also clarify that in order to obtain a second master s designation; the applicant must take the appropriate examination. Additionally, this rule will be amended to make the individual supervision requirement less burdensome on the prospective licensee, as the supervision will no longer need to be completed strictly in person, but may instead be completed using a telecommunication method that provides for live, simultaneous contact. R Master s social worker licensure requirements; macro designation. This rule will be added to address the specific requirements for licensure as a master s level social worker with a macro designation. The revised rule will also clarify the necessary experiential requirements for this designation. R Master s social worker licensure requirements; clinical designation. This rule will be added to address the specific requirements for licensure as a master s level social worker with a clinical designation. R Relicensure of a master s level social worker. Currently, the administrative rules merely require adherence to MCL and MCL for applicants seeking relicensure. The revised rule will create a tiered system of requirements depending on how long the social worker has had their license lapsed. All applicants for relicensure must submit an application and fee and appropriate continuing education. Applicants who have been lapsed for 3 years or longer must complete 1,000 hours of supervised experience under a licensed master s level social worker and those who have been lapsed more than 7 years must retake the appropriate examination. Basically, the longer a licensee has been out of practice, the more stringent the requirements will be to gain re-entry to practice. R Licensure by endorsement for master s social workers. The rule will be revised to require that an applicant s license shall be verified by the licensing agency of all other states of the United States in which the applicant holds a current license or ever held a license as a social worker. If applicable, verification shall include the record of any disciplinary action taken or pending against the applicant. PART 5: Continuing Education R license renewals; continuing education requirements. The amendments to this rule will increase the number of pain and symptom management credits from 1 to 2 every renewal cycle. R Acceptable continuing education. This rule will be revised to include documentation requirements in the event a licensee is audited, and will expand acceptable continuing education to include academic courses related to the practice of social work offered by an approved educational program. R Methods of approval for continuing education programs. The revised rule will adopt ASWB standards for co-sponsorship agreements, thereby easing the burden on applicants wishing to

8 Regulatory Impact Statement and Cost-Benefit Analysis Page 8 provide continuing education. The rule will add cultural competence and diversity to the list of topics that a course or program may address. (5) Identify the harm resulting from the behavior that the proposed rule(s) are designed to alter and the likelihood that the harm will occur in the absence of the rule. What is the rationale for changing the rule(s) and not leaving them as currently written? R : This rule will be added to ensure that applicants who are seeking a second master s level designation shall take the appropriate examination in addition to completing the experiential requirement. The current rule allows the addition of a second designation without having to take a second examination, and the board believes this loophole in the rules poses a danger to the public. All other states that have a Macro or Advanced Generalist Master s Level license or designation require applicants to have completed the Advanced Generalist examination, regardless of whether the applicant already holds a clinical license or designation. (6) Describe how the proposed rule(s) protect the health, safety, and welfare of Michigan citizens while promoting a regulatory environment in Michigan that is the least burdensome alternative for those required to comply. The proposed rules update adopted standards and update rule language which will make it easier for licensees and registrants to understand the requirements for licensure. The new requirement to achieve a passing score on a second master s level examination (for those seeking a second designation) is necessary to protect the public and is on par with the requirements of other states offering multiple designations of social work licensure. The new requirements for relicensure ensure that a social worker who has failed to maintain his or her Michigan license has the necessary knowledge and skills to return to practice. The new rule for training in recognizing the signs of human trafficking is the least burdensome method for license and renewal applicants to meet the requirements of section 16148, MCL Several, but not all training methods are available free of charge. (7) Describe any rules in the affected rule set that are obsolete, unnecessary, and can be rescinded. R concerning unprofessional advertising is unnecessary and must be rescinded. Fiscal Impact on the Agency: Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e. hiring additional staff, an increase in the cost of a contract, programming costs, changes in reimbursement rates, etc. over and above what is currently expended for that function. It would not include more intangible costs or benefits, such as opportunity costs, the value of time saved or lost, etc., unless those issues result in a measurable impact on expenditures. (8) Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential savings on the agency promulgating the rule). The Department does not expect the implementation of the proposed rules to result in additional costs or savings for the Department (9) Describe whether or not an agency appropriation has been made or a funding source provided for any expenditures associated with the proposed rule(s). The licensing and regulation of the profession, including the promulgation and implementation of rules, is funded by the licensing fees collected from social workers. As a result, there was no reason to make

9 Regulatory Impact Statement and Cost-Benefit Analysis Page 9 an agency appropriation or provide a funding source. Also, the Department does not expect the proposed rules to increase expenditures. (10) Describe how the proposed rule(s) is necessary and suitable to accomplish its purpose, in relationship to the burden(s) it places on individuals. Burdens may include fiscal or administrative burdens, or duplicative acts. So despite the identified burden(s), identify how the requirements in the rule(s) are still needed and reasonable compared to the burdens. The new human trafficking rule and the amended continuing education rules implement the statute in the least burdensome way. Some of the methods of meeting these rules include free offerings. The board feels that requiring an additional exam for additional master s level designations is necessary to protect the public. This is underscored by the fact that Michigan is the only state that has not heretofore required a second exam. Regarding the relicensure rules, the current rules treat a relicensed practitioner the same, whether he or she has been out of practice for 3 years or 20 years. The new tiered relicensure rules will assure that a practitioner who is coming back into practice after longer periods of time is required to complete higher levels of competency. Impact on Other State or Local Governmental Units: (11) Estimate any increase or decrease in revenues to other state or local governmental units (i.e. cities, counties, school districts) as a result of the rule. Estimate the cost increases or reductions on other state or local governmental units (i.e. cities, counties, school districts) as a result of the rule. Please include the cost of equipment, supplies, labor, and increased administrative costs, in both the initial imposition of the rule and any ongoing monitoring. There are no anticipated increases or decreases in revenues for other state or local governmental units (12) Discuss any program, service, duty or responsibility imposed upon any city, county, town, village, or school district by the rule(s). Describe any actions that governmental units must take to be in compliance with the rule(s). This section should include items such as record keeping and reporting requirements or changing operational practices. The proposed rules do not impose a program, service, duty, or responsibility on any city, county, town, village, or school district. (13) Describe whether or not an appropriation to state or local governmental units has been made or a funding source provided for any additional expenditures associated with the proposed rule(s). The Department does not expect state or local governmental units to incur additional expenditures because of the proposed rules. Therefore, there was no reason to make an appropriation or provide a funding source for state or local governmental units. Rural Impact: (14) In general, what impact will the rules have on rural areas? Describe the types of public or private interests in rural areas that will be affected by the rule(s). The Department does not expect the proposed rules to impact rural areas or interests any greater than urban areas or interests. The proposed rules will ensure that applicants for licensure have the education necessary to practice in a safe and competent manner, which will benefit consumers in all geographic areas. Environmental Impact:

10 Regulatory Impact Statement and Cost-Benefit Analysis Page 10 (15) Do the proposed rule(s) have any impact on the environment? If yes, please explain. No, the rules will not have an impact on the environment. Small Business Impact Statement: [Please refer to the discussion of small business on page 2 of this form.] (16) Describe whether and how the agency considered exempting small businesses from the proposed rules. The agency did not consider exempting small businesses from the proposed rules. (17) If small businesses are not exempt, describe (a) the manner in which the agency reduced the economic impact of the proposed rule(s) on small businesses, including a detailed recitation of the efforts of the agency to comply with the mandate to reduce the disproportionate impact of the rule(s) upon small businesses as described below (in accordance with MCL (1)(A-D)), or (b) the reasons such a reduction was not lawful or feasible. The rules do not exempt small businesses because the rules do not directly relate to small businesses, only individuals with licenses or registrations. (A) Identify and estimate the number of small businesses affected by the proposed rule(s) and the probable effect on small business. The department does not collect or have access to information that would allow it to identify and estimate the number of small businesses that may be affected. (B) Describe how the agency established differing compliance or reporting requirements or timetables for small businesses under the rule after projecting the required reporting, record-keeping, and other administrative costs. The proposed rules do not establish differing compliance or reporting requirements or timetables for small businesses under the rules, as the rules do not directly relate to small businesses, but instead individuals. (C) Describe how the agency consolidated or simplified the compliance and reporting requirements and identify the skills necessary to comply with the reporting requirements. The proposed rules impose requirements on individual licensees and registrants rather than small businesses. A social work licensee would be required to obtain continuing education and maintain records in accordance with the Public Health Code, regardless of if his or her practice was considered a small business or works for a major healthcare provider. (D) Describe how the agency established performance standards to replace design or operation standards required by the proposed rules. The proposed rules affect individual licensees and registrants rather than small businesses. It is not possible to establish requirements based solely on performance standards. (18) Identify any disproportionate impact the proposed rule(s) may have on small businesses because of their size or geographic location. The proposed rules will not have a disproportionate impact on small businesses because of their size or geographic location. (19) Identify the nature of any report and the estimated cost of its preparation by small business required to comply with the proposed rule(s). The proposed rules affect individual licensees and registrants rather than small businesses. Therefore, the proposed rules do not require that small businesses prepare any reports. (20) Analyze the costs of compliance for all small businesses affected by the proposed rule(s), including costs of equipment, supplies, labor, and increased administrative costs. The proposed rules regulate individual licensees rather than small businesses.

11 Regulatory Impact Statement and Cost-Benefit Analysis Page 11 (21) Identify the nature and estimated cost of any legal, consulting, or accounting services that small businesses would incur in complying with the proposed rule(s). The rules affect individuals. Therefore, the Department expects that small businesses will not incur any additional legal, consulting, or accounting costs as a result of these rules. (22) Estimate the ability of small businesses to absorb the costs without suffering economic harm and without adversely affecting competition in the marketplace. The rules affect individual licensees and registrants rather than small businesses. Since the rules affect all licensees and registrants, the Department does not expect any adverse effects to competition in the marketplace for a licensee whose practice qualifies as a small business. (23) Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser standards for compliance by small businesses. Exemptions to the rules or lesser standards for small businesses will not be established. The rules will apply to all licensees and registrants. (24) Identify the impact on the public interest of exempting or setting lesser standards of compliance for small businesses. If the Department exempts or sets lesser standards for small business, it will result in a disparity in the regulation of a profession and may have a negative impact on public safety. (25) Describe whether and how the agency has involved small businesses in the development of the proposed rule(s). If small business was involved in the development of the rule(s), please identify the business(es). The proposed rules impose requirements on individual licensees and registrants rather than small businesses. Cost-Benefit Analysis of Rules (independent of statutory impact): (26) Estimate the actual statewide compliance costs of the rule amendments on businesses or groups. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the proposed rule(s). What additional costs will be imposed on businesses and other groups as a result of these proposed rules (i.e. new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and number of businesses and groups. Be sure to quantify how each entity will be affected. The Department does not expect either businesses or groups to incur any new or additional compliance costs because of the proposed rules. (27) Estimate the actual statewide compliance costs of the proposed rule(s) on individuals (regulated individuals or the public). Please include the costs of education, training, application fees, examination fees, license fees, new equipment, supplies, labor, accounting, or recordkeeping). How many and what category of individuals will be affected by the rules? What qualitative and quantitative impact does the proposed change in rule(s) have on these individuals? Additional compliance costs will be incurred for individuals whose license has been lapsed for more than 7 years and who have not been actively practicing in another state in the years preceding the application date. Under the proposed rules, these individuals will be required to retake the applicable licensure examination in order to qualify for relicensure, whereas the current rule merely requires completion of 45 continuing education hours. Depending on the level of licensure sought, the Bachelor s exam costs $230 and the Master s Level exams cost $260. There may also be costs associated with the completion of the 1,000 hour experiential requirement for relicensure for individuals whose licenses have been lapsed 3 or more years, as these individuals may not be earning a full wage or the employing agency may not be able to fully bill an insurance company for this time.

12 Regulatory Impact Statement and Cost-Benefit Analysis Page 12 Additionally, compliance costs will be increased for individuals adding a second master s level designation, as those individuals will be required to complete a second master s level examination. This exam will cost an additional $260. (28) Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result of the proposed rule(s). The Department does not expect the proposed rules to result in any significant cost reductions for businesses, individuals, or groups of individuals. (29) Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rule(s). Please provide both quantitative and qualitative information, as well as your assumptions. The proposed rules adopt the most recent standards for social work education and continuing education. The proposed rules regarding relicensure ensure that a social worker who allows his or her license to lapse has the necessary knowledge and skills to return to practice. The proposed rules will expand the opportunities for obtaining continuing education by clarifying that approved social work education programs are permitted to offer continuing education opportunities. The proposed human trafficking rule is designed in the least burdensome way, offering many free options for social workers to meet this training requirement, and also ensuring the profession becomes more aware and knowledgeable about the signs and dangers of human trafficking. (30) Explain how the proposed rule(s) will impact business growth and job creation (or elimination) in Michigan. The Department does not expect the rules to have a direct impact on business growth, job growth, or job elimination. (31) Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their industrial sector, segment of the public, business size, or geographic location. The Department does not expect an individual or business to be disproportionately impacted based on size, industrial sector, segment of the public, or geographic location. (32) Identify the sources the agency relied upon in compiling the regulatory impact statement, including the methodology utilized in determining the existence and extent of the impact of a proposed rule(s) and a cost-benefit analysis of the proposed rule(s). How were estimates made, and what were your assumptions? Include internal and external sources, published reports, information provided by associations or organizations, etc., which demonstrate a need for the proposed rule(s). Association of Social Work Boards: ASWB Cultural Competency as a Regulatory Issue: ASWB States Using the Advanced Generalist Exam: Alternatives to Regulation: (33) Identify any reasonable alternatives to the proposed rule(s) that would achieve the same or similar goals. In enumerating your alternatives, please include any statutory amendments that may be necessary to achieve such alternatives. The Public Health Code could be amended to include the provisions of the current administrative rules or the proposed changes to the administrative rules. Otherwise, there is no reasonable alternative to

13 Regulatory Impact Statement and Cost-Benefit Analysis Page 13 the proposed rules. (34) Discuss the feasibility of establishing a regulatory program similar to that proposed in the rule(s) that would operate through private market-based mechanisms. Please include a discussion of private market-based systems utilized by other states. The licensure and regulation of social workers and social service technicians are state functions, so a regulatory scheme that is independent of state intervention cannot be established. (35) Discuss all significant alternatives the agency considered during rule development and why they were not incorporated into the rule(s). This section should include ideas considered both during internal discussions and discussions with stakeholders, affected parties, or advisory groups. There were no significant alternatives that the Department needed to consider in order to achieve the intended changes. Additional Information (36) As required by MCL b(1)(c), please describe any instructions regarding the method of complying with the rules, if applicable. No further instructions are necessary. PART 4: REVIEW BY THE ORR Date Regulatory Impact Statement (RIS) received: Date RIS approved: ORR assigned rule set number: LR Date of disapproval: Explain: More information needed: Explain: (ORR-RIS March 2014)