June 25, 2025 • 20 mins
We break down how laws become rules, who enforces them, and how LARA makes sure they protect the public.
Administrative Rulemaking System (ARS) – https://ars.apps.lara.state.mi.us/
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Episode Transcript
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Anastasha Osborn (00:01):
Hello, Hello, welcome to episode three of the
LARA Living Room.
I am Anastasha Osborn, yourhost, and today we're breaking
down something that impactsevery Michigander, regulations.
And specifically, we're goingto talk about how LARA fits into
(00:23):
the big picture.
We'll answer questions likewhat branch of government is
LARA a part of, who makes lawsand who makes rules, and then of
course, how are these enforced?
To help me explain all of this,I'm going to be joined by Adam
Sandoval, who is LARA's chieflegal officer and deputy
director, as well as PaigeFoltz, who's the director LARA's
Office of Policy andLegislative Affairs.
(00:44):
So fill up your coffee, grab aseat, and get comfortable
because you are now in the Living Room.
Let's get started with someintroductions.
Adam, welcome to the LARALiving Room.
Can you tell us a little bitabout your role as Chief Legal
Officer and Deputy Director andhow your office supports the
department's regulatory work?
Adam Sandoval (01:05):
Yes, thank you so much, Anastasha, for having
Paige and I.
I have the privilege of being amember of Team LARA and working
in an important position thathas dual roles.
As Chief Legal Officer, I'mresponsible for overseeing
department-wide risk andcompliance.
Thank you so much for joiningus.
Anastasha Osborn (01:43):
Incredible.
Thank you for being here.
And Paige, welcome.
Can you tell our listeners alittle bit about yourself and
your background?
Paige Fults (01:51):
Yes, thanks for having me.
My background is very similarto Director Brown's, how he
discussed in the second episodeof The LARA Living Room.
As a child, I was aself-proclaimed political nerd.
How Director Brown enjoyedwatching the State of the Union,
I myself would sit and watchstates light up when it came
(02:14):
time to the presidentialcampaign.
So I've always really, reallyhad a fond interest in state
government, national government,anything that had to do with
politics and different piecesalong those lines.
As far as my career, I startedit just up the road at the House
of Representatives.
And then I worked the majorityof my time at the Michigan
(02:36):
Health and Hospital Associationin the advocacy division there
as their senior director forregulatory affairs for about 14
years.
Then I made the jump over toLARA in January of 2022.
Incredible.
Anastasha Osborn (02:51):
And can you share just a quick overview of
your office, OPLA, specificallyand what your office does and
then how does that fit into
Paige Fults (02:58):
LARA?
Yes, we monitor proposedlegislation and regulations that
impact LARA and the bureaus andthen our state licensee
holders.
We work with members of thelegislature and regulatory
entities and stakeholders.
We communicate LARA feelsabout this proposed legislation
(03:18):
and we identify potentialamendments to that legislation.
Our office genuinely believesthat each lawmaker wants to make
a positive impact on Michigan.
I think the big piece isthere's a difference on what
their priorities are and how toget there.
Anastasha Osborn (03:37):
Yeah, I agree.
And for those who don't know,how...
small but mighty, is your team?
Paige Fults (03:44):
There is a total of seven of us, but we do both law
and rules within our office.
So those individuals do notjust work on the legislative
proposals.
We house the regulatory affairsoffice.
With that, the regulatoryaffairs officer, and then we
have a JCAR specialist who alsointeracts and works with JCAR
(04:09):
and ensures that rules and theprocess go smoothly and can
answer questions for Jay Carralong with myself at the
Hospital Association.
I worked on rules when I wasover there too.
So we do both.
Anastasha Osborn (04:24):
That's incredible.
And I know we use a lot ofacronyms here, so I'm going to
make you pause and tell us whatJCAR stands for.
I'm
Paige Fults (04:31):
sorry.
Yes.
It stands for the JointCommittee of Administrative
Rules.
Anastasha Osborn (04:41):
Yes.
Thank you.
I know we have some listenersout there who are going to say,
what is JCAR?
Because we use a lot ofacronyms.
So if we say something,listeners, and you don't know
what it means, please let usknow and we'll be happy to drop
maybe an acronyms list of somekind.
Yes.
Paige Fults (04:54):
Joint Committee of Administrative Rules.
So sorry about that.
Yes, acronyms are a lot easierwhen you have a mouthful.
Anastasha Osborn (05:02):
Awesome.
Thank you.
And Adam, I want to switch overto you really quickly.
Let's kind of talk a little bitabout outlining some of the
basics, right?
So what branch of governmentis LARA a part of?
We get this question a lot,usually for our new employees as
they kind of come in, and theydon't really know where we fall.
And then Also with that, whatdoes that mean really for the
(05:23):
type of work that we do forMichiganders?
Adam Sandoval (05:26):
Certainly.
So LARA is part of theexecutive branch of state
government.
And as a department within theexecutive branch, this means
that LARA is responsible forimplementing or enforcing the
laws that the legislatureenacts.
For example, LARA isresponsible for administering
the public health code and theoccupational code, which
establish licensing andregulation requirements for
(05:48):
numerous professions andoccupations like doctors No,
that's
Anastasha Osborn (05:55):
actually a good point.
I know we kind of talked abouta little bit in our first
episodes, kind of talking aboutall the different occupations
and licensees that we have.
So that's great to just knowthat there's a lot of different
codes that we are overseeing aswell.
I'm kind of going to jump intoa little bit.
some technicalities maybepossibly and that is kind of
like once a law is passed ormaybe we want to start before
(06:17):
then I keep thinking of like theschool of rock is that what
it's called right school of rocklike how a bill becomes a law
so Paige once a law is passedreally what happens next what
are those next steps and thenhow does LARA turn that law into
something actionable so ouroffice actually engages with
experts that are within ourbureaus through each step of the
(06:39):
legislative process we shareinformation information the
entire time with thelegislature.
The goal is to ensure when abill becomes a law, it reflects
what the department is able toimplement by the time it becomes
a law.
So bureaus have had time toprepare for administering the
(07:00):
new requirements for it.
And also when laws are crafted,frequently bureaus are granted
along with their professionallicensing boards, the ability to
make rules.
Rule sets provide more detailedinformation that laws simply do
not have the space to diveinto.
This is another step in thegoverning process that allows
(07:24):
for public input.
As you had mentioned earlier,when we discussed our team, and
that is something that our team,my team here handles, OPLA, we
handle the rules and, you know,the legislative process we work
on.
A question just popped into myhead.
And again, I might be going offscript here a little bit, but
you kind of mentionedprofessional licensing boards.
(07:47):
Can you talk a little bit moreabout what those are for those
who may not know that some ofour bureaus do have boards?
Paige Fults (07:54):
Yes.
So the professional licensingboards are housed within our
Bureau of ProfessionalLicensing.
And those are boards that areresponsible for ensuring that
rules are, they're responsiblefor making not only rules
through the rulemaking process,but they also handle
(08:18):
implementing and they, you know,run board meetings.
They have some of thedisciplinary actions that run
through them.
Adam might be able to speak abit more about the process
through them.
The boards are actually set upand designed through statutory
(08:40):
requirements.
Adam, anything you want to add?
Adam Sandoval (08:43):
Yes, I would add that the board's primary
function is to add subjectmatter expertise to the program
and to the process.
So the board composition And toPaige's point, you know, some
boards are charged with doingmore actions or decisions than
(09:04):
others, but ultimately it's agroup of officials who are
typically from the industry orhave experience in that area.
Anastasha Osborn (09:11):
All right, Paige.
So if I'm a licensee or aconcerned citizen, how do I get
involved or speak up during thatrulemaking process?
Paige Fults (09:18):
I would love it if more individuals take part in
the rulemaking process.
The first way would be joininga rulemaking work group.
The next would be take placeduring the public hearing
process.
So rulemaking work groupsactually do take place before
public hearings.
They are a series of meetingsthat individuals can attend and
(09:39):
provide input on.
before public hearings.
There also is an opportunity tosubmit comments regarding the
draft rule sets before that.
And then the public commentperiod at the public hearing is
another great way to speak up tohave your voice heard.
(10:02):
You can stay up to date on therules by signing up for email
alerts on LARA's website for allLARA rule sets.
There is a public website thathouses all rule sets that are
any agencies, that any agency ordepartment is currently working
on, not just LARA's.
(10:22):
And it is the AdministrativeRulemaking System, or the ARS.
Anastasha, I made sure to letpeople know what the acronym was
there for you.
You can look up current drafts,public hearing information and
dates, and a status update onrules.
And all this information I cangive to you and you can provide
(10:45):
in the podcast show notes forlisteners.
Anastasha Osborn (10:47):
No, that'd be perfect.
We will drop those in the shownotes so people can easily
access that link.
I think it'll be great,especially for people who do
want to have their voices heard.
And you can get out there andyou can know when different rule
sets are being presented andfor you to have your voice heard
and get out there and make adifference too.
Adam, let's talk to you alittle bit about once a rule is
(11:08):
actually finalized and who isresponsible for making sure that
it's followed and what happensif it isn't.
Adam Sandoval (11:17):
Once a rule becomes effective, the agency
that made the rule isresponsible for ensuring that
it's followed.
If a rule isn't followed, theagency typically has many ways
it works with a person or anentity to obtain compliance,
such as education and outreachon the requirements of the rule,
settlement conferences wherenegotiations are had to ensure
compliance, or to take morestrict measures like issuing
(11:37):
fines, summary suspensions, oreven license revocations.
Anastasha Osborn (11:40):
And for those who maybe don't know, and maybe
you can just elaborate a littlebit more, LARA does have various
bureaus and agencies within ourdepartment itself.
And so when we're talking aboutwho's in charge of enforcing,
does this come down tospecifically those bureaus and
agencies?
And then when does it getescalated to you exactly?
Adam Sandoval (11:59):
Yes, it does come down to the individual or a
particular agency or bureautasked and charged with
administering that particularstatute or program.
So they will initiate aninvestigation, an inspection,
make a decision.
Depending on the nature of theviolation, some of the more
(12:19):
significant violations can beescalated to my attention.
And then what I typically dowith those types of actions or
decisions are just ensureconsistency.
We'll look at past precedent,and then also we'll brief the
executive office as well.
Anastasha Osborn (12:35):
We're still kind of on this rules, right?
Talking about these rules andthese rule sets.
So what happens specificallywhen a rule is outdated or it's
no longer serving its purposeanymore?
And how do we really go aboutchanging it?
Paige Fults (12:48):
Lawmakers grant LARA, the statutory authority,
to update rules through therulemaking process.
Anastasha Osborn (12:53):
Can you elaborate a little bit more on
that?
What does that mean for thepublic?
What does that mean for LARA
Paige Fults (12:58):
employees?
So I'm going to make sure Idon't use more acronyms here for
you.
There's a law that regulatesthe rulemaking process.
It is called the AdministrativeProcedures Act or the APA.
And that is what you have tofollow when doing the rulemaking
(13:21):
process.
So lawmakers have the abilityto hand over the authority to
some of our bureaus to providerulemaking.
So in that, they are allowed touse their discretion.
If a law is out, I mean, if arule, I'm sorry, if a rule is
(13:44):
outdated, they are allowed toresend it as needed.
And then also during that time,If a lawmaker, you know, and a
bill moves through thelegislative process and a new
law is signed and it isoutdated, the Bureau then is
required to update the rules atthat time to ensure that
(14:07):
outdated rules are now, youknow, following what the new law
is to ensure compliance.
Anastasha Osborn (14:15):
Okay, that makes a lot more sense.
So again, I wanted to build apicture.
So when we're talking aboutTalking about a bill is
presented and then becomes alaw?
Paige Fults (14:24):
Yes.
Anastasha Osborn (14:25):
Okay.
And then from a law, where dowe go from there?
Then we make our rule set?
Paige Fults (14:30):
If it's granted in the law that we have the
authority to make a rule set,then yes.
Anastasha Osborn (14:38):
Okay.
And then from there, if theydecide to change anything, then
they update the rules to matchwhatever the updates to the law
is.
Is this correct?
Okay.
Yes.
I'm trying to simplify itbecause I know when I started
working for state government,this was one of the hardest
parts, one of the biggest, thehardest concepts I think for me
to really grasp.
And it was really trying tofigure out what is a law and how
(15:01):
does it become a law?
And then what are all thesedifferent rule sets?
just trying to understand thatprocess itself.
And then how, just to kind ofsimplify it for people who don't
work in everyday, you know, youand Adam get the pleasure of
working in that world.
And so for you guys, it's likesecond nature, right?
You're like, well, yes, I knowthis.
It would almost, the bestanalogy I can think of is
(15:24):
thinking about when, let's sayyou run track, right?
You're an Olympian, you runtrack.
Running is so different fromhow like you and I might run
versus how, an all-star olympianathlete will run right there's
different techniques there'sdifferent things that they know
how to do how to you know lifttheir knees or there's like all
these weird things right that wedon't really understand because
(15:46):
they're so technical and i knowmaybe it's a far-fetched
analogy but it's kind of thesame concept right we have we
know the concept of like thereare some laws out there that we
have to follow but we don't knowthe intricate details of how
those laws are becoming a lawand how they can be changed how
they can be updated how theyimpact us or how they might
(16:08):
change in the future and justthat whole process.
So I'd appreciate you bothbeing here and kind of giving us
that behind the scenes, youknow, just peek behind the
curtain of what that looks likeand simplifying it for, you
know, the public.
And then also, like Imentioned, for also our law
employees who do work here, butthey may not totally understand
(16:30):
exactly how their job isimpacted by all these different
laws and rules.
So I think I'll just open it upif there's anything else that
you guys would like to closewith.
Anything else you'd like to addthat you would like, you know,
either the public to know aboutregulations or laws or rules or
anything of that?
Adam Sandoval (16:47):
Yes, I would like to add that it's a great
discussion.
And, you know, kind of taking astep back, when I think of law
versus rule, it's plainlanguage, big picture, the law
really establishes the what, andthen the rule establishes the
how.
So, for example, thelegislature makes the laws, it's
going to establish the what,for example, thou shall
(17:09):
individual shall be licensed tobe a doctor.
And then we go over to the ruleand the agency that makes the
rule will tell us how thatindividual should obtain
license.
So it'll establish thequalifications, the education,
the training components, etcetera.
So kind of bigger picture,start with that mindset, and
that might help.
You kind of distinguish thedistinction between a law and a
(17:29):
rule.
And then kind of shifting gearson compliance, we talked a
little bit earlier about whathappens if someone doesn't
follow a rule. LARA is big intoeducating before we regulate.
And one of the four strategicgoals that we have is compliance
through education andconsultation.
So it's this notion that it'smore cost effective and
(17:54):
certainly increases safety andhealth for our licensees to
comply So the more that we caneducate and train and consult
with our licensees on the frontend of the process, the better
off everybody is.
Anastasha Osborn (18:06):
Yeah, I agree.
And I love it.
That is one of our biggestthings, one of our our strategic
goals.
And I also feel like we we uselike the phrase, right, the
quote of educate before weregulate.
We use that all the time.
And it is really important tous here at LARA that that we do
that and that we help licenseesunderstand what it is that they
are required to do and whatthey're not allowed to do.
(18:27):
Right.
So, yes.
Well, anything else before weclose out?
Paige Fults (18:32):
Yes, I was just going to say, I want to make
sure that individuals understandthat the legislature really is
a partner in providing licensureand regulation.
You know, they are one of thekey pieces to ensure that things
(18:53):
do run smoothly.
Sometimes we do hit a bump inthe road and we do need updates
and improvements made andlawmakers are who we need to
turn on to make thoseadjustments and improvements.
And without them and thestakeholders and the
partnerships that we have witheveryone and those individuals,
(19:16):
it wouldn't be possible.
So our office greatlyappreciates As I'd mentioned
before, we want more publicinput, and we do appreciate the
amount of effort thatstakeholders put in, that
lawmakers put in, and everyoneto make the state government
tick.
So just a thank you for all theeffort that comes from not only
(19:40):
our state employees, but thoselawmakers and stakeholders that
take the time to provide inputand work with us on legislation.
Yes,
Anastasha Osborn (19:51):
I agree.
Thank you, Paige, for sayingthat.
Wow, I didn't know that that'show that worked.
You are not alone.
As I mentioned kind ofthroughout the episode, I always
(20:12):
learn something new throughoutthese.
So I appreciate this and Iappreciate the behind the scenes
process and why it's soessential and really just the
impact that it's going to haveon all of us here in Michigan.
So be sure to follow the LARALiving Room for more behind the
scenes stories from people likePaige and Adam who get to make
it all happen.
And I will close out with fromour living room to yours.
(20:35):
We'll see you next time.
Hello, Hello, welcome to episode three of the
LARA Living Room.
I am Anastasha Osborn, yourhost, and today we're breaking
down something that impactsevery Michigander, regulations.
And specifically, we're goingto talk about how LARA fits into
(00:23):
the big picture.
We'll answer questions likewhat branch of government is
LARA a part of, who makes lawsand who makes rules, and then of
course, how are these enforced?
To help me explain all of this,I'm going to be joined by Adam
Sandoval, who is LARA's chieflegal officer and deputy
director, as well as PaigeFoltz, who's the director LARA's
Office of Policy andLegislative Affairs.
(00:44):
So fill up your coffee, grab aseat, and get comfortable
because you are now in the Living Room.
Let's get started with someintroductions.
Adam, welcome to the LARALiving Room.
Can you tell us a little bitabout your role as Chief Legal
Officer and Deputy Director andhow your office supports the
department's regulatory work?
Adam Sandoval (01:05):
Yes, thank you so much, Anastasha, for having
Paige and I.
I have the privilege of being amember of Team LARA and working
in an important position thathas dual roles.
As Chief Legal Officer, I'mresponsible for overseeing
department-wide risk andcompliance.
Thank you so much for joiningus.
Anastasha Osborn (01:43):
Incredible.
Thank you for being here.
And Paige, welcome.
Can you tell our listeners alittle bit about yourself and
your background?
Paige Fults (01:51):
Yes, thanks for having me.
My background is very similarto Director Brown's, how he
discussed in the second episodeof The LARA Living Room.
As a child, I was aself-proclaimed political nerd.
How Director Brown enjoyedwatching the State of the Union,
I myself would sit and watchstates light up when it came
(02:14):
time to the presidentialcampaign.
So I've always really, reallyhad a fond interest in state
government, national government,anything that had to do with
politics and different piecesalong those lines.
As far as my career, I startedit just up the road at the House
of Representatives.
And then I worked the majorityof my time at the Michigan
(02:36):
Health and Hospital Associationin the advocacy division there
as their senior director forregulatory affairs for about 14
years.
Then I made the jump over toLARA in January of 2022.
Incredible.
Anastasha Osborn (02:51):
And can you share just a quick overview of
your office, OPLA, specificallyand what your office does and
then how does that fit into
Paige Fults (02:58):
LARA?
Yes, we monitor proposedlegislation and regulations that
impact LARA and the bureaus andthen our state licensee
holders.
We work with members of thelegislature and regulatory
entities and stakeholders.
We communicate LARA feelsabout this proposed legislation
(03:18):
and we identify potentialamendments to that legislation.
Our office genuinely believesthat each lawmaker wants to make
a positive impact on Michigan.
I think the big piece isthere's a difference on what
their priorities are and how toget there.
Anastasha Osborn (03:37):
Yeah, I agree.
And for those who don't know,how...
small but mighty, is your team?
Paige Fults (03:44):
There is a total of seven of us, but we do both law
and rules within our office.
So those individuals do notjust work on the legislative
proposals.
We house the regulatory affairsoffice.
With that, the regulatoryaffairs officer, and then we
have a JCAR specialist who alsointeracts and works with JCAR
(04:09):
and ensures that rules and theprocess go smoothly and can
answer questions for Jay Carralong with myself at the
Hospital Association.
I worked on rules when I wasover there too.
So we do both.
Anastasha Osborn (04:24):
That's incredible.
And I know we use a lot ofacronyms here, so I'm going to
make you pause and tell us whatJCAR stands for.
I'm
Paige Fults (04:31):
sorry.
Yes.
It stands for the JointCommittee of Administrative
Rules.
Anastasha Osborn (04:41):
Yes.
Thank you.
I know we have some listenersout there who are going to say,
what is JCAR?
Because we use a lot ofacronyms.
So if we say something,listeners, and you don't know
what it means, please let usknow and we'll be happy to drop
maybe an acronyms list of somekind.
Yes.
Paige Fults (04:54):
Joint Committee of Administrative Rules.
So sorry about that.
Yes, acronyms are a lot easierwhen you have a mouthful.
Anastasha Osborn (05:02):
Awesome.
Thank you.
And Adam, I want to switch overto you really quickly.
Let's kind of talk a little bitabout outlining some of the
basics, right?
So what branch of governmentis LARA a part of?
We get this question a lot,usually for our new employees as
they kind of come in, and theydon't really know where we fall.
And then Also with that, whatdoes that mean really for the
(05:23):
type of work that we do forMichiganders?
Adam Sandoval (05:26):
Certainly.
So LARA is part of theexecutive branch of state
government.
And as a department within theexecutive branch, this means
that LARA is responsible forimplementing or enforcing the
laws that the legislatureenacts.
For example, LARA isresponsible for administering
the public health code and theoccupational code, which
establish licensing andregulation requirements for
(05:48):
numerous professions andoccupations like doctors No,
that's
Anastasha Osborn (05:55):
actually a good point.
I know we kind of talked abouta little bit in our first
episodes, kind of talking aboutall the different occupations
and licensees that we have.
So that's great to just knowthat there's a lot of different
codes that we are overseeing aswell.
I'm kind of going to jump intoa little bit.
some technicalities maybepossibly and that is kind of
like once a law is passed ormaybe we want to start before
(06:17):
then I keep thinking of like theschool of rock is that what
it's called right school of rocklike how a bill becomes a law
so Paige once a law is passedreally what happens next what
are those next steps and thenhow does LARA turn that law into
something actionable so ouroffice actually engages with
experts that are within ourbureaus through each step of the
(06:39):
legislative process we shareinformation information the
entire time with thelegislature.
The goal is to ensure when abill becomes a law, it reflects
what the department is able toimplement by the time it becomes
a law.
So bureaus have had time toprepare for administering the
(07:00):
new requirements for it.
And also when laws are crafted,frequently bureaus are granted
along with their professionallicensing boards, the ability to
make rules.
Rule sets provide more detailedinformation that laws simply do
not have the space to diveinto.
This is another step in thegoverning process that allows
(07:24):
for public input.
As you had mentioned earlier,when we discussed our team, and
that is something that our team,my team here handles, OPLA, we
handle the rules and, you know,the legislative process we work
on.
A question just popped into myhead.
And again, I might be going offscript here a little bit, but
you kind of mentionedprofessional licensing boards.
(07:47):
Can you talk a little bit moreabout what those are for those
who may not know that some ofour bureaus do have boards?
Paige Fults (07:54):
Yes.
So the professional licensingboards are housed within our
Bureau of ProfessionalLicensing.
And those are boards that areresponsible for ensuring that
rules are, they're responsiblefor making not only rules
through the rulemaking process,but they also handle
(08:18):
implementing and they, you know,run board meetings.
They have some of thedisciplinary actions that run
through them.
Adam might be able to speak abit more about the process
through them.
The boards are actually set upand designed through statutory
(08:40):
requirements.
Adam, anything you want to add?
Adam Sandoval (08:43):
Yes, I would add that the board's primary
function is to add subjectmatter expertise to the program
and to the process.
So the board composition And toPaige's point, you know, some
boards are charged with doingmore actions or decisions than
(09:04):
others, but ultimately it's agroup of officials who are
typically from the industry orhave experience in that area.
Anastasha Osborn (09:11):
All right, Paige.
So if I'm a licensee or aconcerned citizen, how do I get
involved or speak up during thatrulemaking process?
Paige Fults (09:18):
I would love it if more individuals take part in
the rulemaking process.
The first way would be joininga rulemaking work group.
The next would be take placeduring the public hearing
process.
So rulemaking work groupsactually do take place before
public hearings.
They are a series of meetingsthat individuals can attend and
(09:39):
provide input on.
before public hearings.
There also is an opportunity tosubmit comments regarding the
draft rule sets before that.
And then the public commentperiod at the public hearing is
another great way to speak up tohave your voice heard.
(10:02):
You can stay up to date on therules by signing up for email
alerts on LARA's website for allLARA rule sets.
There is a public website thathouses all rule sets that are
any agencies, that any agency ordepartment is currently working
on, not just LARA's.
(10:22):
And it is the AdministrativeRulemaking System, or the ARS.
Anastasha, I made sure to letpeople know what the acronym was
there for you.
You can look up current drafts,public hearing information and
dates, and a status update onrules.
And all this information I cangive to you and you can provide
(10:45):
in the podcast show notes forlisteners.
Anastasha Osborn (10:47):
No, that'd be perfect.
We will drop those in the shownotes so people can easily
access that link.
I think it'll be great,especially for people who do
want to have their voices heard.
And you can get out there andyou can know when different rule
sets are being presented andfor you to have your voice heard
and get out there and make adifference too.
Adam, let's talk to you alittle bit about once a rule is
(11:08):
actually finalized and who isresponsible for making sure that
it's followed and what happensif it isn't.
Adam Sandoval (11:17):
Once a rule becomes effective, the agency
that made the rule isresponsible for ensuring that
it's followed.
If a rule isn't followed, theagency typically has many ways
it works with a person or anentity to obtain compliance,
such as education and outreachon the requirements of the rule,
settlement conferences wherenegotiations are had to ensure
compliance, or to take morestrict measures like issuing
(11:37):
fines, summary suspensions, oreven license revocations.
Anastasha Osborn (11:40):
And for those who maybe don't know, and maybe
you can just elaborate a littlebit more, LARA does have various
bureaus and agencies within ourdepartment itself.
And so when we're talking aboutwho's in charge of enforcing,
does this come down tospecifically those bureaus and
agencies?
And then when does it getescalated to you exactly?
Adam Sandoval (11:59):
Yes, it does come down to the individual or a
particular agency or bureautasked and charged with
administering that particularstatute or program.
So they will initiate aninvestigation, an inspection,
make a decision.
Depending on the nature of theviolation, some of the more
(12:19):
significant violations can beescalated to my attention.
And then what I typically dowith those types of actions or
decisions are just ensureconsistency.
We'll look at past precedent,and then also we'll brief the
executive office as well.
Anastasha Osborn (12:35):
We're still kind of on this rules, right?
Talking about these rules andthese rule sets.
So what happens specificallywhen a rule is outdated or it's
no longer serving its purposeanymore?
And how do we really go aboutchanging it?
Paige Fults (12:48):
Lawmakers grant LARA, the statutory authority,
to update rules through therulemaking process.
Anastasha Osborn (12:53):
Can you elaborate a little bit more on
that?
What does that mean for thepublic?
What does that mean for LARA
Paige Fults (12:58):
employees?
So I'm going to make sure Idon't use more acronyms here for
you.
There's a law that regulatesthe rulemaking process.
It is called the AdministrativeProcedures Act or the APA.
And that is what you have tofollow when doing the rulemaking
(13:21):
process.
So lawmakers have the abilityto hand over the authority to
some of our bureaus to providerulemaking.
So in that, they are allowed touse their discretion.
If a law is out, I mean, if arule, I'm sorry, if a rule is
(13:44):
outdated, they are allowed toresend it as needed.
And then also during that time,If a lawmaker, you know, and a
bill moves through thelegislative process and a new
law is signed and it isoutdated, the Bureau then is
required to update the rules atthat time to ensure that
(14:07):
outdated rules are now, youknow, following what the new law
is to ensure compliance.
Anastasha Osborn (14:15):
Okay, that makes a lot more sense.
So again, I wanted to build apicture.
So when we're talking aboutTalking about a bill is
presented and then becomes alaw?
Paige Fults (14:24):
Yes.
Anastasha Osborn (14:25):
Okay.
And then from a law, where dowe go from there?
Then we make our rule set?
Paige Fults (14:30):
If it's granted in the law that we have the
authority to make a rule set,then yes.
Anastasha Osborn (14:38):
Okay.
And then from there, if theydecide to change anything, then
they update the rules to matchwhatever the updates to the law
is.
Is this correct?
Okay.
Yes.
I'm trying to simplify itbecause I know when I started
working for state government,this was one of the hardest
parts, one of the biggest, thehardest concepts I think for me
to really grasp.
And it was really trying tofigure out what is a law and how
(15:01):
does it become a law?
And then what are all thesedifferent rule sets?
just trying to understand thatprocess itself.
And then how, just to kind ofsimplify it for people who don't
work in everyday, you know, youand Adam get the pleasure of
working in that world.
And so for you guys, it's likesecond nature, right?
You're like, well, yes, I knowthis.
It would almost, the bestanalogy I can think of is
(15:24):
thinking about when, let's sayyou run track, right?
You're an Olympian, you runtrack.
Running is so different fromhow like you and I might run
versus how, an all-star olympianathlete will run right there's
different techniques there'sdifferent things that they know
how to do how to you know lifttheir knees or there's like all
these weird things right that wedon't really understand because
(15:46):
they're so technical and i knowmaybe it's a far-fetched
analogy but it's kind of thesame concept right we have we
know the concept of like thereare some laws out there that we
have to follow but we don't knowthe intricate details of how
those laws are becoming a lawand how they can be changed how
they can be updated how theyimpact us or how they might
(16:08):
change in the future and justthat whole process.
So I'd appreciate you bothbeing here and kind of giving us
that behind the scenes, youknow, just peek behind the
curtain of what that looks likeand simplifying it for, you
know, the public.
And then also, like Imentioned, for also our law
employees who do work here, butthey may not totally understand
(16:30):
exactly how their job isimpacted by all these different
laws and rules.
So I think I'll just open it upif there's anything else that
you guys would like to closewith.
Anything else you'd like to addthat you would like, you know,
either the public to know aboutregulations or laws or rules or
anything of that?
Adam Sandoval (16:47):
Yes, I would like to add that it's a great
discussion.
And, you know, kind of taking astep back, when I think of law
versus rule, it's plainlanguage, big picture, the law
really establishes the what, andthen the rule establishes the
how.
So, for example, thelegislature makes the laws, it's
going to establish the what,for example, thou shall
(17:09):
individual shall be licensed tobe a doctor.
And then we go over to the ruleand the agency that makes the
rule will tell us how thatindividual should obtain
license.
So it'll establish thequalifications, the education,
the training components, etcetera.
So kind of bigger picture,start with that mindset, and
that might help.
You kind of distinguish thedistinction between a law and a
(17:29):
rule.
And then kind of shifting gearson compliance, we talked a
little bit earlier about whathappens if someone doesn't
follow a rule. LARA is big intoeducating before we regulate.
And one of the four strategicgoals that we have is compliance
through education andconsultation.
So it's this notion that it'smore cost effective and
(17:54):
certainly increases safety andhealth for our licensees to
comply So the more that we caneducate and train and consult
with our licensees on the frontend of the process, the better
off everybody is.
Anastasha Osborn (18:06):
Yeah, I agree.
And I love it.
That is one of our biggestthings, one of our our strategic
goals.
And I also feel like we we uselike the phrase, right, the
quote of educate before weregulate.
We use that all the time.
And it is really important tous here at LARA that that we do
that and that we help licenseesunderstand what it is that they
are required to do and whatthey're not allowed to do.
(18:27):
Right.
So, yes.
Well, anything else before weclose out?
Paige Fults (18:32):
Yes, I was just going to say, I want to make
sure that individuals understandthat the legislature really is
a partner in providing licensureand regulation.
You know, they are one of thekey pieces to ensure that things
(18:53):
do run smoothly.
Sometimes we do hit a bump inthe road and we do need updates
and improvements made andlawmakers are who we need to
turn on to make thoseadjustments and improvements.
And without them and thestakeholders and the
partnerships that we have witheveryone and those individuals,
(19:16):
it wouldn't be possible.
So our office greatlyappreciates As I'd mentioned
before, we want more publicinput, and we do appreciate the
amount of effort thatstakeholders put in, that
lawmakers put in, and everyoneto make the state government
tick.
So just a thank you for all theeffort that comes from not only
(19:40):
our state employees, but thoselawmakers and stakeholders that
take the time to provide inputand work with us on legislation.
Yes,
Anastasha Osborn (19:51):
I agree.
Thank you, Paige, for sayingthat.
Wow, I didn't know that that'show that worked.
You are not alone.
As I mentioned kind ofthroughout the episode, I always
(20:12):
learn something new throughoutthese.
So I appreciate this and Iappreciate the behind the scenes
process and why it's soessential and really just the
impact that it's going to haveon all of us here in Michigan.
So be sure to follow the LARALiving Room for more behind the
scenes stories from people likePaige and Adam who get to make
it all happen.
And I will close out with fromour living room to yours.
(20:35):
We'll see you next time.
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