Michigan Implicit Bias Training Requirement — A Complete Guide

What Is the Michigan Implicit Bias Training Requirement?

Michigan requires all licensed and registered healthcare professionals to complete implicit bias training as a condition of licensure and renewal. The requirement went into effect on June 1, 2022, under Act 368 of 1978, Part 161 of the Michigan Public Health Code, and is governed by Administrative Rule R 338.7004. The rule's implementing standards were subsequently updated effective March 23, 2023, and remain in effect for all licensure and renewal cycles.


Implicit bias refers to the attitudes, beliefs, and stereotypes that influence our judgment and behavior toward others without conscious awareness. In healthcare settings, these biases can affect clinical decision-making, communication, and the quality of care patients receive, particularly patients from historically underserved communities.


The requirement exists because research consistently shows that implicit bias contributes to health disparities across race, ethnicity, gender, age, disability, and other dimensions. Michigan's mandate recognizes that addressing bias is not optional, it's a professional responsibility for every licensed clinician.

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Who Is Required to Complete It?

The requirement applies to all healthcare professionals licensed or registered under the Michigan Public Health Code, Article 15 — with the exception of veterinary medicine. If you hold an active Michigan healthcare license, you are required to complete this training.

Profession License Type
Registered NurseRN
Licensed Practical NurseLPN
Nurse PractitionerAPRN/NP
PhysicianMD, DO
Physician AssistantPA
PharmacistRPh
Pharmacy TechnicianCPhT
DentistDDS, DMD
Dental HygienistRDH
Physical TherapistPT
Occupational TherapistOT
Social WorkerLMSW, LCSW
PsychologistPhD, PsyD
Licensed Professional CounselorLPC, LLPC
Marriage and Family TherapistLMFT
Speech-Language PathologistSLP
AudiologistAuD
ChiropractorDC
OptometristOD
PodiatristDPM
Respiratory TherapistCRT, RRT
Athletic TrainerAT
Behavior AnalystBCBA
Massage TherapistLMT
AcupuncturistLAc
Genetic CounselorCGC
Nursing Home AdministratorNHA
SanitarianRS
MidwifeCPM, CM

If your profession is not listed here and you hold a Michigan healthcare license, check your specific licensing board's renewal requirements or contact LARA directly at bpl-info@michigan.gov.

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How Many Hours Are Required?

The number of hours required depends on whether you're completing initial licensure or renewing an existing license, and the length of your renewal cycle.

Situation Hours Required Timeframe
Initial Licensure 2 hours Completed within the 5 years before your license is issued
1-Year Renewal Cycle 1 hour Per renewal period
2-Year Renewal Cycle 2 hours Per renewal period
3-Year Renewal Cycle 3 hours Per renewal period

Implicit bias training hours count toward your total continuing education requirement for the renewal cycle, they are not additional hours on top of what your profession already requires. A 2-hour implicit bias course completed within a 2-year renewal cycle satisfies the entire implicit bias requirement for that cycle.

If you need a 2-hour course, CLU Academy's Michigan LARA implicit bias training satisfies the requirement for initial licensure and 2-year renewal cycles.

If you're completing a 2-hour course for a 1-year renewal cycle, the extra hour can be applied toward your general CE requirements. Check with your specific licensing board to confirm how surplus hours are handled for your profession.

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What Qualifies as an Acceptable Training Provider?

Not every training counts. Michigan Administrative Rule R 338.7004 specifies that implicit bias training must be provided by one of the following:

  • A nationally recognized health-related organization
  • A state or federal agency
  • A healthcare educational program approved by a Michigan licensing board
  • An accredited college or university
  • An organization that specializes in diversity, equity, and inclusion issues

LARA does not pre-approve or certify individual training providers. Whether a course qualifies is determined by whether the provider falls into one of the categories above and whether the training content addresses implicit bias as defined in the rule. Providers do not need to apply to LARA for approval, compliance is content-based and provider-category-based, not based on a pre-approved list.

This means that when choosing a course, you should confirm that the provider falls within one of these categories and that the course content specifically addresses implicit bias in a healthcare or professional context.

The CLU Academy is built by The CLU Studio, an organization specializing in diversity, equity, and inclusion issues, qualifying under the fifth category.

What Documentation Do You Need?

When you renew your Michigan license, you self-attest to completing the required implicit bias training. LARA may conduct a random audit of your renewal, if audited, you must provide a certificate of completion that includes all of the following fields:

Required Field What It Confirms
Your full name Identifies the license holder who completed the training
Date of training completion Confirms the training falls within the required timeframe
Program sponsor's name Identifies the training provider
Program or course title Confirms the training specifically addressed implicit bias

LARA may audit your continuing education compliance going back up to four years from your renewal date. Keep your implicit bias training certificate for at least four years after each renewal cycle. If you complete training this year and renew in two years, retain that certificate until at least four years after that renewal, not four years from completion. When in doubt, keep it indefinitely. Digital storage costs nothing and audit requests can come without warning.

The CLU Academy certificates include all four required fields and are formatted specifically to meet these documentation requirements.

R 338.7004 — What the Rule Actually Says

Michigan Administrative Rule R 338.7004 is the specific regulation that governs the implicit bias training requirement. Here's a plain-language breakdown of what it requires, without the regulatory language.

Who it applies to
All individuals licensed, certified, or registered under Article 15 of the Michigan Public Health Code, except veterinary medicine professionals. This covers more than 25 healthcare professions regulated by LARA.

What the training must cover
The rule requires training that includes: the definition and sources of implicit bias, how implicit bias affects healthcare treatment and outcomes, the relationship between implicit bias and health disparities, and strategies to address and reduce bias in clinical settings.

How compliance is verified
Compliance is self-reported at renewal. LARA may audit renewal applicants at random. Audited licensees must provide documentation, a certificate of completion, showing they completed qualifying training within the required period.

The full rule text is available directly from LARA at: https://ars.apps.lara.state.mi.us/AdminCode/DownloadAdminCodeFile?FileName=R%20338.7001%20to%20R%20338.7005.pdf

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Contact LARA's Bureau of Professional Licensing

For questions about the implicit bias training requirement, your specific renewal cycle, or audit documentation:

Email: bpl-info@michigan.gov
Phone: (517) 241-0199
Website: michigan.gov/lara

When contacting LARA, reference Michigan Administrative Rule R 338.7004 in your message. Response times vary,allow 3–5 business days for email replies.

Frequently Asked Questions

What are Michigan's implicit bias training hour requirements for healthcare professionals?

It depends on your situation. If you're applying for initial licensure, you need 2 hours completed within the 5 years before your license is issued. For renewal, the number of hours equals the number of years in your renewal cycle — 1 hour for a 1-year cycle, 2 hours for a 2-year cycle, and 3 hours for a 3-year cycle.

Which healthcare professionals are covered by Michigan's implicit bias training requirement?

All professions licensed, certified, or registered under Article 15 of the Michigan Public Health Code, except veterinary medicine. This includes nurses, physicians, pharmacists, social workers, counselors, therapists, dentists, physical therapists, occupational therapists, respiratory therapists, psychologists, optometrists, chiropractors, and many others.

Does a 2-hour course satisfy a 2-year renewal requirement?

Yes. For a 2-year renewal cycle, the requirement is 2 hours total, one hour per year of the cycle. A single 2-hour course completed anytime during the cycle satisfies the full implicit bias requirement for that renewal period.

What does my certificate need to include for LARA audits?

Your certificate must include your full name, the date you completed the training, the name of the training provider, and the title of the course or program. Keep this document after you complete the course, you'll need it if LARA audits your renewal. The CLU Academy certificates include all four required fields and are available for download immediately upon course completion. See a sample certificate.

How long do I need to keep my completion certificate?

LARA may audit your CE compliance going back up to 4 years from your renewal date. Keep your certificate for at least 4 years after each renewal cycle. When in doubt, keep it indefinitely.

Does Michigan LARA maintain an approved provider list for implicit bias training?

No. LARA does not maintain an approved provider list and does not pre-approve or certify individual training providers. Compliance is determined by whether the provider falls within one of the five categories defined in R 338.7004 and whether the course content addresses implicit bias in a healthcare context.

What happens if I don't complete the training before renewing?

Your license renewal may be denied or conditioned on completing the training. LARA enforces compliance through the renewal process and random audits. Renewing without completing required training and falsely attesting to compliance creates additional legal exposure.

What is the LARA audit period for implicit bias training?

LARA may audit your CE compliance going back up to 4 years from your renewal date. This means you should retain your certificate of completion for at least 4 years after each renewal cycle. Keeping certificates indefinitely is the safest practice.

When did the Michigan implicit bias training requirement take effect?

The requirement took effect June 1, 2022, established under Public Health Code Act 368 of 1978, Article 15. Updated standards under Michigan Administrative Rule R 338.7004 became effective March 23, 2023. Both initial licensure applicants and renewal applicants are subject to the requirement.

How do I attest to completing implicit bias training when I renew my Michigan license?

Michigan uses a self-attestation model. When you renew your license online through LARA's system, you'll be asked to confirm that you completed the required implicit bias training. You do not upload your certificate during renewal, you simply attest that you have it. LARA may later request your certificate during a random audit, which is why retaining it is essential.

Can I complete the implicit bias training in multiple sessions?

Yes. The training does not need to be completed in one sitting. An online self-paced course allows you to stop and resume as your schedule permits. What matters is that the total required hours are completed before your license renewal date.

Is there a specific deadline for completing implicit bias training?

The training must be completed before you renew your license. For initial licensure, it must be completed within the 5 years immediately before your license is issued. There is no specific calendar deadline beyond those tied to your personal renewal cycle.

Do implicit bias training hours come out of my existing CE requirement or are they extra?

It counts toward your total. The hours are not added on top of your existing continuing education requirement, they come out of the hours you're already required to complete for renewal. A 2-hour implicit bias course can satisfy 2 of your required CE hours for the cycle.

Do I need an active Michigan license before completing the implicit bias training?

No. You do not need an active license to complete the training. For initial licensure, the training must be completed within the 5 years before your license is issued. Completing it while in school or before your application is processed is acceptable as long as it falls within that 5-year window.

Does CLU Academy's course satisfy the requirement for all license types?

CLU Academy's course satisfies the implicit bias training requirement under R 338.7004 for healthcare professionals on 2-year renewal cycles whose licensing board accepts asynchronous training. Some licensing boards — including those governing physicians (MD) and osteopathic physicians (DO) — have adopted additional requirements beyond the base rule, including a live synchronous training component. If you hold an MD or DO license, confirm your board's specific requirements before enrolling. For all other LARA-regulated professions on 2-year cycles, the course satisfies the full requirement.

Is an online self-paced course acceptable?

Yes. The rule does not specify that training must be completed live, in-person, or synchronously. Online self-paced courses qualify as long as the provider falls within one of the five accepted sponsor categories and the content addresses implicit bias as defined in the rule. The CLU Academy's course is fully online and self-paced, accepted for all LARA-regulated healthcare professions. View course details.

Does the training need to be specific to healthcare?

The rule requires training that addresses implicit bias in a healthcare context, specifically how bias affects treatment, outcomes, and health disparities. A general workplace DEI training that doesn't address clinical or healthcare-specific scenarios may not satisfy the requirement. Look for training built specifically for healthcare professionals.

Who do I contact at LARA for questions about the requirement?

You can reach LARA's Bureau of Professional Licensing at bpl-info@michigan.gov or by calling 517-241-0199. For rule-specific questions, reference Administrative Rule R 338.7004.

Can employers complete the training on behalf of their staff?

No. The requirement is an individual obligation. Each licensed professional must personally complete the training and hold their own certificate of completion. Employers cannot complete training on behalf of employees, though they can facilitate group access or reimburse the cost.

Is the implicit bias training requirement the same for all healthcare professions?

The hour requirement varies by renewal cycle length, which differs by profession. The content and provider requirements are the same across all covered professions. Check with your specific licensing board if you have questions about how the requirement applies to your renewal cycle.

Does my implicit bias training certificate expire?

For renewal purposes, the training must have been completed during the current renewal cycle, hours from a previous cycle do not carry forward. For initial licensure, the training must fall within the 5 years before licensure. There is no separate expiration date on the certificate itself.

What is the difference between implicit bias and explicit bias?

Explicit bias refers to conscious attitudes and beliefs about a group that a person is aware of and can articulate. Implicit bias refers to unconscious associations and attitudes that influence perception and behavior without conscious awareness. Michigan's training requirement specifically addresses implicit bias because it operates below conscious awareness and is therefore harder to recognize and address without specific training.

Does Michigan's implicit bias training requirement apply to telehealth providers?

Yes. The requirement applies to the license, not the practice setting. If you hold a Michigan healthcare license and practice via telehealth, you are subject to the same implicit bias training requirement as in-person providers.

What if I completed implicit bias training through my employer — does that count?

It depends on the provider. Training completed through an employer qualifies if the employer's training program falls within one of the five accepted sponsor categories under R 338.7004 and the content specifically addresses implicit bias as defined in the rule. You should confirm the provider category and obtain a certificate of completion that includes all required documentation fields.

Does the training need to address Michigan-specific content?

No. The rule requires training that addresses implicit bias, its impact on healthcare outcomes, and strategies to reduce it, but does not require Michigan-specific content. A course addressing implicit bias in healthcare generally satisfies the content requirement as long as the provider falls within an accepted sponsor category.

Ready to Complete Your Requirement?

If you've found the information you needed here, the next step is completing the training itself. CLU Academy offers a 2-hour online course built specifically for Michigan's healthcare licensure requirement under R 338.7004. It's self-paced, accepted for all LARA-regulated healthcare professions, and your certificate is available for download the same day you complete it.


The course goes beyond checkbox compliance, it was designed to give you practical tools for listening differently and reducing bias in real patient interactions, not just language to satisfy an auditor.