Calling for Public Comment on Discriminatory MDHHS Standards

discriminatory MDHHS DEI standards

Recent campus displays of woke antisemitism have ignited public opposition to discriminatory Diversity, Equity, and Inclusion (DEI) policies across the U.S.

Unfortunately, the State of Michigan is doubling down on discriminatory DEI policies through its bureaucratic branch. The Department of Health and Human Services (MDHHS) recently proposed standards that target minorities in our state for data collection.

Earlier this year, American journalist Bari Weiss described DEI as “an ideological movement bent on recategorizing every American not as an individual, but as an avatar of an identity group, his or her behavior prejudged accordingly, setting all of us up in a kind of zero-sum game.”

DEI history in Michigan government

Michigan’s most visible health policy plunge into DEI was forcing licensed health professionals to take annual Implicit Bias Training (IBT), starting last year.

However, the proposed new MDHHS standards will be administered by a DEI agency in Michigan government going all the way back to the 1980s.

Policy expert Christopher Rufo could have meant Michigan in this passage of his new book..

… the critical race theorists proposed a three-part overhaul of the American system of governance: abandoning the “colorblind” notion of equality, redistributing wealth along racial lines, and restricting speech that is deemed “hateful.” …
This movement seeks to establish itself in every layer of the public and private administration, which will … replace governance by the Constitution with governance by the bureaucracy. … normalize the regime of group-based rights, active discrimination, speech suppression, and racialist redistribution of resources through small administrative decisions, which can, over time, legitimize broader policies.

In a related pivot away from health and towards power politics, MDHHS last week announced state Medicaid payments to community organizers health workers, effective January 1. Rather than providing care, most workers will enroll people in state programs. Perversely, growing state bureaucracy this way effectively diverts MDHHS funds from patient care to state paychecks.

Medical school professor and kidney specialist Dr. Stanley Goldfarb maintains that “the likeliest basis for healthcare disparities is not racism, but patients presenting late in the course of their illness, too late to achieve best outcomes.”

Dr. Goldfarb opposes DEI. “We believe that focusing on racial identity will harm healthcare, divide us even more, and reduce trust between patients and physicians, all of which will lead to even worse outcomes.” Instead, he recommends healthcare institutions reach out to improve minority access to care.

Public comments on MDHHS proposed data-collection standards.

Suggested talking points:

  • Skin color and ethnicity are not diseases. For MDHHS to track such characteristics at all is dubious for multiple reasons. In particular, it invades privacy and takes away resources from actual care.
  • No ethnicity predicts disease for 100% of that population. Data from the proposed standards is at best a wide net for scattered, indirect measures of so-called social determinants of health.
  • The most obvious use of Michigan minority data is for political influence, not health.
  • The new standards are likely to increase discord in healthcare, where violence is already a growing problem.


Click here to enter your Public Comments. 

Addendum on January 3.

This was my first public comment on a state rulemaking, and it was very different from my past experiences on federal sites. For one thing, unlike federal rules, I could find no state law or rule directing rulemakers to read all comments or respond to them. But more about that later.

It may be helpful for other commenters to know going in that MDHHS uses a Qualtrix survey format. The survey is limited for the most part to one question per page, with pre-determined multiple-choice answers. Pages advance only after answers are complete. In contrast, federal comments are just a blank form for the public to write whatever comments they choose.

I was able to write one freeform comment, since MDHHS included one broad question with a comment space. Feel free to copy, paste, and modify for your own comment.

MDHHS should focus on the most direct path to healthcare for those who need it, regardless of race and ethnicity.
Race and ethnicity are not health problems. Nor are they a good proxy for health problems. And data collection about them is in no way the equivalent of healthcare.
Instead, date collection about race and ethnicity amplifies societal differences and political conflict. These have no place in healthcare.
MDHHS should leave such questions, when necessary for individual care, to patients’ personal clinicians.