BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 682
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          Date of Hearing:   April 14, 2209

                        ASSEMBLY COMMITTEE ON HUMAN SERVICES
                                Jim Beall, Jr., Chair
                   AB 682 (Lowenthal) - As Amended:  March 26, 2009
           
          SUBJECT  :  In-Home Supportive Services:  Fraud.

           SUMMARY  :  Requires the state Department of Health Care Services  
          (DHCS) to evaluate implementation of provisions intended to  
          combat fraud in the In-Home Supportive Services (IHSS) program.   
          Specifically,  this bill  :

          1)Requires that, beginning January 1, 2010, DHCS dedicate an  
            unspecified number of positions to evaluate implementation of  
            five specific anti-fraud provisions of the Welfare and  
            Institutions Code related to the IHSS program and authorizes  
            DHCS to fill the positions either by using existing resources  
            or, if an appropriation is provided for that purpose, by  
            adding new positions.

          2)Requires DHCS, in consultation with the state Department of  
            Social Services (DSS), and stakeholders including IHSS  
            consumers and providers, to provide a report to the  
            Legislature by December 31, 2011, which shall do all of the  
            following with respect to IHSS-related fraud:

             a)   Identify the magnitude of fraud in terms of the total  
               dollars inappropriately spent or removed from the program,  
               and the number of consumers harmed or placed at risk of  
               harm as a result of fraudulent activity; 

             b)   Identify the number of people involved in fraud for each  
               of the following categories:  IHSS providers, IHSS  
               consumers, state workers, county workers, and others.  In  
               the case of "others," the report shall describe the  
               function of the persons committing fraud with specificity  
               but without revealing personal identifying information;  
               and,

             c)   Provide recommendations on the best means to combat IHSS  
               fraud.

          3)States legislative findings and declarations, as follows:









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             a)   The IHSS program is the one of the fastest growing  
               programs in the state, and will continue to grow.

             b)   Wage and benefit increases also contribute to overall  
               spending in the IHSS program; but, wages are, in most  
               instances, little more than minimum wages, benefits tend to  
               be fewer than in other jobs, and common benefits, such as  
               sick leave, are not available to IHSS workers.

             c)   While evidence of IHSS-related fraud is believed to be  
               very low, with such a large, growing program, it is  
               imperative that the state and stakeholders adhere to a  
               zero-tolerance policy on fraud because fraud has the  
               potential to harm the IHSS program by removing valuable  
               resources.

          4)States the Legislature's intent to determine the extent and  
            type of IHSS-related fraud in order to evaluate existing  
            antifraud provisions and make revisions as necessary to ensure  
            that the IHSS program carries out its mission of providing  
            services to seniors and people with disabilities.

          5)Provides that the provisions of the bill will sunset on  
            January 1, 2012 unless the sunset is deleted or extended by a  
            later enacted statute; but, also provides that, if the  
            provision requiring the report to the Legislature is repealed,  
            the report must nonetheless be prepared and delivered.

           EXISTING LAW  

          1)Establishes the IHSS program to provide personal services and  
            home care for 444,000 eligible poor, aged, blind and disabled  
            individuals by an average of 325,000 providers throughout the  
            state to enable recipients to remain in their own homes and  
            avoid institutionalization.

          2)Provides that DSS supervises the IHSS program at the state  
            level and that counties administer services at the local  
            level.

          3)Provides for funding of the IHSS program through a combination  
            of about 50% federal (Medicaid), 32% state, and 18% county  
            dollars. 

          4)Defines "fraud" for purposes of the IHSS program to mean:   








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            "the intentional deception or misrepresentation made by a  
            person with the knowledge that the deception could result in  
            some unauthorized benefit to himself or herself or some other  
            person.  Fraud also includes any act that constitutes fraud  
            under applicable federal or state law."

          5)Specifies the responsibilities of DSS, DHCS and the counties  
            for various quality assurance activities, including activities  
            to ensure program integrity, including fraud detection and  
            prevention.

          6)Prohibits persons who have been convicted of certain crimes,  
            including fraud against a government health care or supportive  
            services program, within the preceding 10 years from providing  
            or receiving IHSS services.

          7)Provides for the recovery of overpayments to IHSS providers  
            and, if the overpayment is determined to be the result of  
            fraud by the service provider, prohibits future payments to  
            the provider for up to 10 years following conviction or the  
            term of incarceration following the conviction for fraud.

           FISCAL EFFECT :  Unknown






























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           COMMENTS  :

           Background  :  The IHSS Program helps pay for services so that the  
          elderly, disabled, or blind individuals can remain in their own  
          homes and avoid institutionalization.  IHSS services include,  
          but are not limited to, housecleaning, meal preparation,  
          laundry, grocery shopping, personal care services (such as bowel  
          and bladder care, bathing, grooming and paramedical services),  
          accompaniment to medical appointments, and protective  
          supervision for people with mental impairments.  IHSS consists  
          of four programs, including:  Personal Care Services Program  
          (PCSP), IHSS Plus Waiver Program (IPW), IHSS Residual Program  
          (IRP), and Medi-Cal Waiver Personal Care Program (MWPCS).  The  
          PCSP, IPW, and IRP are administered at the county level by  
          county welfare departments and at the State level by the Adult  
          Programs Division within DSS.  The Medi-Cal Waiver Personal Care  
          Services (MWPCS) Program is administered through Department of  
          Health Care Services.  A portion of the costs for IHSS services  
          are paid by federal funding.  The entire program consists of  
          over 444,000 recipients and on average 325,000 IHSS workers.

          In 2004, as part of the budget trailer bill, SB 1104, the  
          Legislature imposed a number of mandatory duties on DSS, DHCS  
          and the counties with respect to quality, cost controls and  
          program integrity within the IHSS program.  Among other things,  
          SB 1104 defined and distinguished between "fraud" and  
          "overpayments," with fraud being limited to traditional  
          prosecutable acts of intentional misrepresntation, while  
          overpayment was defined broadly to include all instances in  
          which providers are paid in excess of the amount for authorized  
          services, whether fraudulent or not.  SB 1104 authorized DHCS to  
          investigate fraud in the provision or receipt of supportive  
          services, and required counties to refer instances of suspected  
          fraud to DHCS for investigation.  It required DHCS to notify  
          DSS, the county, and the county's nonprofit consortium or public  
          authority, if any, of a determination that a provider has  
          engaged in fraud.

           Need for the bill  :  According to the author, notwithstanding  
          quality assurance measures implemented through SB 1104,  
          "insinuations of widespread fraud persist."  The author suggests  
          that these insinuations may be unjustified, noting that there is  
          a "disconnect between perception and fact" that is "not  
          acceptable for such a large and growing state program.  ... If  








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          we can identify fraud, we can stop it.  But we can't diminsh  
          funding for the program based on anecdotal evidence."  This bill  
          is intended to collect data and document instances of fraud  
          within the IHSS program.

           PROPOSED AMENDMENTS  :  "Fraud" has a specific meaning under the  
          IHSS statutes, and must involve an intentional deception or  
          misrepresentation.  Most overpayments, for example, are not the  
          result of fraud.  In addition, not all allegations of fraud are  
          substantiated.  Therefore, it is recommended that this bill be  
          amended to include the criterion that would be used to determine  
          the magnitude of IHSS fraud occuring during the reporting  
          period.  

          The author is reportedly agreeable to amending this bill:

          1)To explicitly say that the required report will apply to fraud  
            "  as defined in subdivision (a) of Section 12305.8 of the  
            Welfare and Institutions Code and which resulted in a  
            convition for fraud or incarceration following conviction for  
            fraud.  "  

          2)To state that the bill applies to fraud "  that resulted in  
            conviction  " within the five-year period covered by the report.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Aging Services of California 
          Service Employees International Union (SEIU) (sponsor)

           Opposition 
           
          None on file
           
          Analysis Prepared by  :    Eric Gelber / HUM. S. / (916) 319-2089