From:	rosebaran@ferris.edu
Sent:	Monday, November 6, 2023 1:08 PM
To:	Joint Committee on Administrative Rules
Cc:	rosebaran@ferris.edu
Subject:	JCAR Committee Comments

Person Completing Form
    Name : Rose Baran

    Phone : 517-339-7946

    Email Address : rosebaran@ferris.edu

    Rule : Pharmacy General Rules Set 2022-8 LR  Rules 338.501, R338.519, R338.521, R338.523, R338.525

    Comment : An applicant for a pharmacist license in Michigan must take and pass two board exams, 
the north American pharmacist licensure examination (NAPLEX), a clinical exam, and the multistate 
pharmacy jurisprudence exam (MPJE), a law exam. The board intends to eliminate the requirement for 
an applicant for licensure as a pharmacist to take and pass the MPJE exam in the pharmacy general rule 
set 2022-8 LR.

The regulatory impact statement (RIS) for rule set 2022-8 LR issued April 18, 2023 proposed the MPJE be 
eliminated for those applicants obtaining a pharmacist license in Michigan by endorsement. See pages 6, 
7, 8, and 9 of the RIS statement   
https://ars.apps.lara.state.mi.us/Transaction/RFRTransaction?TransactionID=1367.  There was no 
mention in the RIS that the MPJE would be removed as a licensure requirement by examination for a 
pharmacist.

Also, in the Notice of Public Hearing, dated April 20, 2023, for the pharmacy general rule set 2022-8 LR 
for the hearing on June 2, 2023 states that “applicants for licensure by endorsement will no longer have 
to take the MPJE and instead will submit knowledge of the laws and rules affidavit.”  There was no 
mention in the Notice of Public Hearing that the MPJE would be removed as a licensure requirement for 
a pharmacist by examination.

The Board of Pharmacy Rules Committee Work Group on June 7, 2023, worked on the comments 
submitted at the public hearing on June 2, 2023. The public attending the June 7, 2023, meeting we're 
told they could not comment on any rule that they did not make a comment on at the public hearing.  
You were not allowed to comment on another person's comment regarding the removal of the MPJE 
entirely from the rule set.  It was a surprise at the workgroup meeting that the MPJE would be removed 
entirely, and the public would not be able to have any comment on it. 

A review of a presentation, Pharmacy Inspections: Common Violations given by the pharmacy drug 
monitoring section of the Bureau of Professional Licensing to the board of pharmacy on February 15, 
2023, revealed most of the common violations were issues of the pharmacist not following the law as 
opposed to clinical errors. The most common violations are law violations, a reason to maintain the 
MPJE requirement for licensure as a pharmacist.

If the deletion to take and pass the MPJE for licensure as a pharmacist remains in the rule set Michigan 
would be the only state removing the MPJE without adequate reasons.  There are only 2 states that do 
not require the MPJE or their own pharmacy law exam, Idaho, and Vermont.  Idaho did a significant 
regulatory overhaul of its pharmacy regulations. Because of the rewrite of the Idaho regulations the 
majority of the MPJE questions would not be current and current questions would not be replenished 
quickly enough and vetted to ensure a valid MPJE examination.  Idaho eliminated the requirement to 
take the MPJE approximately in March of 2018. 

The Vermont Board of Pharmacy has waived the MPJE examination requirement in January 2022, 
pending adoption of the next iteration of the board's administrative rules.  

This 2022-8 LR rule set should go back to a public hearing, so the public has the opportunity to comment 
on the removal of the MPJE to determine if it is in the best interest of the public health for the citizens 
of Michigan. 




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