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New Implicit Bias Training Requirement

New Implicit Bias Training Requirement

Thursday, June 2, 2022

The Michigan Department of Licensing and Regulatory Affairs (LARA) will require implicit bias training for physicians (and other health care professionals), effective June 1, 2022.  The requirements apply to both new applicants as well as those renewing their existing licenses or registrations.  

An applicant for license renewal shall have completed a minimum of 1 hour of implicit bias training for each year of the applicant’s license or registration cycle. An applicant for new licensure, both limited and medical, shall have completed a minimum of 2 hours of implicit bias training within the 5 years immediately preceding issuance of the license or registration.

Physicians will need to report implicit bias credit when they renew their license.  Those who renewed in January 2022, needed no training.  Physicians who renew in 2023, will need to report 1 hour.  Physicians who renew in 2024, will need to report 2 hours.  Physicians who renew in 2025, will need to report the full 3 hours. Then after, every 3-year renewal cycle will need to report 3 hours.  Training that was taken prior to June 1, 2021, and within the license cycle that is up for renewal, qualifies toward the requirement for renewals.  The rule also allows new applicants for licensure or registration to complete the training within the 5 years immediately preceding issuance of the license or registration.

Please note, the implicit bias training for licensure has additional requirements and differs from the other mandated CME areas.  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.  Acceptable modalities of training are a teleconference or webinar that permits live synchronous interaction, a live presentation or an interactive online instruction.  Solely recorded or archived content is not allowable, a live component is required.

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

  • Information on implicit bias, equitable access to health care, serving a diverse population, diversity and inclusion initiatives, and cultural sensitivity.  
  • 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.  
  • The historical basis and present consequences of implicit biases based on an individual’s characteristics.  
  • Discussion of current research on implicit bias in the access to and delivery of health care services.  

BUYERS BEWARE!!  Many professional medical education companies are racing to provide implicit bias content to meet Michigan relicensure requirements.  While they claim they meet Michigan LARA requirements, most do not.  Please make sure your class has a live component (meaning in-person) and a pre AND post implicit bias assessment is included. 

MSMS has researched and contacted a dozen of these companies informing them of their program’s shortcomings. MSMS has also contacted LARA to request an official mechanism for these organizations to be reported and that LARA also provide outreach notifying them of non-compliance. And that physicians who in good faith completed implicit bias content not be penalized for inaccurate marketing. 

In the meantime, MSMS is happy to review any course you may consider taking for compliance.   

For more information on the implicit bias requirement or any other issues regarding physician licensing, please contact Rebecca Blake, MSMS's Senior Director, Education, Foundation, and Subsidiaries, at (517) 336-5729.

The MSMS Foundation worked with state-wide experts in diversity and equity on a brand-new two-part monthly series, titled, “Reducing Unconscious Bias - an Imperative (RUBI): Foundation and Impacts on Patient Care,” which includes a one-hour on-demand video followed by a half-hour live webinar.  To meet the implicit bias requirement, physicians will need to complete Part 1 and Part 2 to receive 1.5 AMA PRA Category Credit(s)™.  The first live session will be held on Wednesday, June 15, from 12:00-12:30 pm.

View our MSMS Implicit Bias Monthly Series>> 

Download our license renewal guide>> 


Statement of Accreditation:
The Michigan State Medical Society (MSMS) is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education for physicians.

AMA Credit Designation Statement:
The MSMS designates this live activity for a maximum of 1.5 AMA PRA Category 1 Credit(s)™.  Physicians should claim only credit commensurate with the extent of their participation in the activity.

Nurses: The ACCME is approved by the Board of Nursing as an acceptable provider of continuing education for license renewal or relicensure.