BILL ANALYSIS                                                                                                                                                                                                    






                                 SENATE HEALTH
                               COMMITTEE ANALYSIS
                        Senator Elaine K. Alquist, Chair


          BILL NO:       SB 442                                       
          S
          AUTHOR:        Ducheny                                      
          B
          AMENDED:       April 15, 2009                              
          HEARING DATE:  April 22, 2009                               
          4
          CONSULTANT:                                                 
          4
          Green/                                                      
          2              
                                        
                                     SUBJECT
                                         
                         Clinic corporation: licensing

                                     SUMMARY  

          Requires the Department of Public Health (DPH) to issue a  
          single, consolidated license to a clinic corporation that  
          operates one or more primary care or mobile clinics, and  
          meets specified licensure requirements. 

                             CHANGES TO EXISTING LAW  

          Existing law:
          Existing law defines a primary care clinic as an outpatient  
          health facility, operated by a nonprofit corporation, which  
          provides direct medical, surgical, dental, optometric, or  
          podiatric advice, services, or treatment to patients who  
          remain less than 24 hours.  Existing law requires primary  
          care clinics to be separately licensed and certified by  
          DPH.  

          Upon approval of a primary care clinic's initial license  
          application, existing law requires DPH to issue a  
          provisional license, good for six months from the date of  
          issuance.  DPH is then required to conduct an on-site  
          survey of the clinic within 30 days prior to the expiration  
          of the provisional license, and, if the clinic meets all  
          licensure requirements, issue a regular license.  If it is  
                                                         Continued---



          STAFF ANALYSIS OF SENATE BILL  SB 442 (Ducheny)Page 2


          

          determined during the on-site survey that the clinic does  
          not meet the requirements for licensure, but demonstrates  
          progress toward meeting the requirements, existing law  
          authorizes DPH to renew the provisional license for another  
          six months.
          
          Existing law authorizes a primary care clinic that has held  
          a valid, unrevoked, and unsuspended license, for at least  
          five years, that has no demonstrated history of repeated or  
          uncorrected licensing violations that pose immediate  
          jeopardy to a patient, and that has no pending suspension  
          or revocation actions, to file an application with DPH to  
          establish an "affiliate clinic" at a new site.  Upon  
          receipt of such an application, DPH is required to issue a  
          regular license for the affiliate clinic within 30 days,  
          without having to conduct an initial onsite survey, if the  
          parent clinic meets additional specified conditions.   
          Existing law does, however, authorize DPH to conduct a  
          licensing inspection at any time after receipt of the  
          affiliate clinic licensing application.  

          Existing law authorizes DPH to issue a special permit to a  
          clinic approved to provide one or more specified special  
          services, such as birthing services, for which the state  
          has established separate standards.  Existing law grants  
          DPH the authority to take various types of enforcement  
          actions against a primary care clinic that has violated  
          state law or regulation, including imposing fines,  
          sanctions, civil or criminal penalties, and suspension or  
          revocation of the clinic's license.

          Existing law also defines a mobile health care unit,  
          commonly referred to as a "mobile clinic," as a commercial  
          coach that is licensed by DPH as an independent  
          freestanding clinic, or approved by DPH as an adjunct of a  
          licensed parent health facility or clinic, and that  
          provides medical, diagnostic, and treatment services in  
          order to ensure the availability of quality health care  
          services for patients in remote or underserved areas, and  
          patients who need specialized types of medical care.  
          
          This bill:
          This bill would require DPH to issue a single, consolidated  
          license to a "clinic corporation," defined as a nonprofit  
          organization that operates more than one primary care  
          clinic and/or mobile clinic, if the clinic corporation  




          STAFF ANALYSIS OF SENATE BILL  SB 442 (Ducheny)Page 3


          

          meets specified requirements.  The bill would specify that  
          in order to qualify for a consolidated license, all of the  
          clinics included on the license application must have the  
          same corporate officers, be owned and operated by the same  
          board of directors, and have a single set of policies,  
          procedures, and standards under which all medical directors  
          operate.  Additionally, the clinic corporation must provide  
          evidence to the department, that each of the primary care  
          clinics that would be included on the license meets  
          applicable physical plant construction and safety  
          standards.  

          The bill would require DPH to issue a consolidated licensed  
          within 30 days of receipt of a completed application, or  
          within 7 days of the date the application is approved,  
          whichever is sooner.  If DPH determines that an applicant  
          does not meet the criteria for a consolidated license, it  
          would be required to identify, in writing, the grounds for  
          that determination, and proceed to process the application  
          as an individual license application.  

          This bill would authorize a clinic corporation that is  
          issued a consolidated license to add or remove a primary  
          care or mobile clinic from the license at any time, as  
          specified. The bill would require DPH to develop a  
          single-page application form to add a clinic to the  
          consolidated license, including the name and address of the  
          clinic, and the services to be provided, and would require  
          a clinic corporation to pay a license fee for each added  
          clinic.  This bill would also allow a clinic corporation  
          that is issued a consolidated license to consolidate  
          administrative functions, as specified, and to transfer  
          special permits from one site to another included in the  
          license.

          The bill would specify that DPH may take any enforcement  
          action authorized by existing law with respect to a primary  
          care clinic included in a consolidated license, but would  
          prohibit an action against one or more clinics under the  
          license from being deemed an action against the clinic  
          corporation as a whole.  The bill would authorize DPH to  
          remove or suspend a clinic that is found to be deficient  
          from the consolidated license, and would authorize a clinic  
          corporation to voluntarily remove a deficient clinic from  
          its consolidated license prior to the assessment of a civil  
          penalty or initiation of removal or suspension by the  




          STAFF ANALYSIS OF SENATE BILL  SB 442 (Ducheny)Page 4


          

          department.  The bill would prohibit DPH from revoking or  
          suspending the consolidated license, unless each clinic  
          under the license is cited in the notice of deficiencies,  
          and the clinic corporation failed to correct deficiencies  
          in each clinic, as specified.

          The bill would specify that the business office of a clinic  
          corporation would not be required to be licensed as a  
          clinic, that a clinic included in the consolidated license  
          would be deemed licensed for the purposes of application  
          for enrollment as a provider in a public health program,  
          such as Medi-Cal, and that each clinic may separately apply  
          for enrollment as a provider in the Medi-Cal program, or  
          other health care program.  The bill would also specify  
          that consolidated licensure of a clinic corporation would  
          not affect federal payment rates for specified federally  
          recognized clinics.

          The bill would specify that clinics that are licensed and  
          in good standing as of December 31, 2009, and that are  
          included on a clinic corporation's consolidated license,  
          would not be subject to provisional licensing requirements.  
           

          The bill would require DPH to calculate the licensing fee  
          for a single consolidated license, based on a percentage of  
          the current primary care clinic fee, and apply it to each  
          primary care clinic included on the consolidated license.   
          The bill would also make various technical and conforming  
          changes.

                                  FISCAL IMPACT  

          Unknown.

                           BACKGROUND AND DISCUSSION  

          According to the author, community clinics are at the core  
          of the state's health care safety net and primary care  
          delivery systems.  The author states that, among the top  
          concerns for clinics in their day-to-day administration and  
          long-term planning are difficulties associated with state  
          licensing and certification.  The author asserts that the  
          current system for licensing and certification of clinics  
          is outdated and inefficient, which causes providers and the  
          state to waste scarce financial and human resources.  




          STAFF ANALYSIS OF SENATE BILL  SB 442 (Ducheny)Page 5


          


          The author states that most clinic organizations operate  
          multiple clinic sites, ranging in numbers from 2 to 25,  
          under the governance of a single board of directors and  
          medical directorship, using common business practices,  
          policies, and procedures, as well as medical oversight.   
          The author states that despite this, under current law,  
          each clinic site must be separately licensed, which  
          requires clinics to often submit the same information on  
          separate licensing applications, even when the information  
          is identical or unchanged.  The author states that this  
          process is not only administratively burdensome and  
          duplicative, it does not account for the role of the  
          governing clinic organization.  The author states that  
          delays in the processing of licensing applications often  
          inhibit clinics from providing and/or billing for  
          much-needed services in their communities.  The author  
          states that, to avoid the state licensing process, many  
          clinics are opting to open "intermittent clinics," which  
          operate at or less than 20 hours per week, and do not  
          require state licensure.  The author also states that a  
          precedent for consolidated health facility licensing has  
          been set by the consolidated licensure of California's  
          acute care hospitals.

          The author states that this bill seeks to find a balance  
          which acknowledges the impact licensing plays in provider  
          enrollment, and ensures the public's health and safety.   
          The author states that this bill will reform the current  
          system of clinic licensure from a physical plant-based  
          model, to a single consolidated license model in order to  
          streamline the clinic licensing process, and create program  
          efficiencies.  
          
          Primary care clinic licensure
          According to DPH, there are currently 972 primary care  
          clinics currently licensed in California.  In order to  
          obtain a license, a primary care clinic must submit an  
          application and fee to DPH, and pass an initial licensure  
          survey conducted by DPH.  Upon receipt of a completed  
          application for a clinic license, DPH has up to 100 days to  
          either grant or deny the license.  

          Existing law requires DPH to issue a provisional license,  
          good for six months from the date of issuance, to a clinic  
          that has not been previously licensed.  DPH is required to  




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          inspect the clinic within 30 days prior to the termination  
          of the provisional license, and, if the clinic meets all  
          licensure requirements, issue a regular license.  Clinics  
          that do not meet the requirements for licensure, but make  
          progress toward meeting the requirements, may have their  
          provisional license renewed by DPH for another six months.

          According to DPH, there are currently seven completed  
          primary care clinic licensing or certification applications  
          pending.  Primary care clinics are currently required to  
          pay licensing fees in an amount of $600.  Under current  
          law, DPH is required to set licensing fees for health  
          facilities based largely on projected workload and costs  
          relating to the licensing activities for each facility  
          type.  For example, the current licensing fee for primary  
          care clinics is $600 per clinic.  This fee was calculated  
          by DPH, based on the workload and resources it dedicates to  
          licensing clinics, including processing licensing  
          applications, performing inspections, conducting complaint  
          investigations, and other activities.  
          
          Primary care clinics that wish to establish additional  
          clinic sites, referred to as "affiliate clinics" are  
          granted an expedited licensure process. Affiliate clinics  
          are eligible for licensure based upon their parent clinic's  
          compliance history.  In order to apply to establish an  
          affiliate clinic, a parent clinic is required to have held  
          a valid, unrevoked, and unsuspended license for the  
          preceding five years.  In addition, the parent clinic must  
          have no demonstrable history of repeated or uncorrected  
          violations that pose immediate jeopardy to patients, as  
          well as no pending action to suspend or revoke the parent  
          clinic's license.  

          The parent clinic is required to submit a completed  
          application and an application fee, establish that the  
          parent clinic and the affiliate clinic have the same  
          corporate officers and are owned and operated by the same  
          organization with the same board of directors, and provide  
          evidence of compliance with minimum safety standards  
          related to the affiliate clinic's physical plant.  If the  
          parent clinic meets these requirements, DPH is required to  
          issue a license to the affiliate clinic within 30 days.   
          Affiliate clinics are exempt from provisional licensure  
          requirements, and are not required to be surveyed to  
          qualify for licensure.  However, affiliate clinics must  




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          still pay license fees.
          
          General acute care hospital licensure
          The author states that the precedent for primary care  
          clinic consolidated licensure was set by the consolidated  
          licensure process for hospitals.  Under existing law, a  
          single consolidated license may be issued to a general  
          acute care hospital that includes more than one physical  
          plant maintained and operated on separate premises, or that  
          has multiple licenses for a single health facility on the  
          same premises, with exceptions.  To qualify for  
          consolidated licensure, the hospital must meet specified  
          criteria, including being nonprofit, and must share a  
          single governing body, administration, and medical staff  
          with any entity under its license.  Additionally all of its  
          separate physical plants must be no more than 15 miles  
          apart, with exceptions.

          General acute care hospitals are prohibited from  
          transferring any special services from one site to another  
          site on the consolidated license without prior approval  
          from DPH, and DPH is authorized to take enforcement action  
          against a licensee, including action to suspend or revoke a  
          consolidated license, for specified violations.

          Prior legislation
          AB 2010 (DeSaulnier), Chapter 90, Statutes of 2008, exempts  
          affiliate clinics from provisional licensure requirements.

          SB 1213 (Ducheny), Chapter 360, Statutes of 2008, requires  
          mobile clinics to notify DPH at least 24 hours prior to  
          providing services at a new site, and waives any notice  
          requirement in the event the mobile clinic is responding to  
          federal, state, or local public health emergencies. 

          SB 937 (Ducheny), Chapter 602, Statutes of 2003, revises  
          provisions relating to the licensure and operation of  
          clinics, and authorizes a primary care clinic that has been  
          licensed and in good standing for five years to file an  
          application to establish an affiliate clinic at an  
          additional site.

          AB 2404 (Reyes), Chapter 111, Statutes of 2002, prohibits  
          the Department of Health Services (DHS), now referred to as  
          DPH, from requiring the licensure of each site where a  
          mobile clinic provided services, and instead requires a  




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          mobile clinic to report to DHS at least 15 days prior to  
          its first visit to a new site, and to report to local  
          authorities to obtain necessary approvals

          AB 951 (Florez), Chapter 525, Statutes of 2001, requires  
          the Department of Health Services, now referred to as DPH,  
          to establish a centralized licensing application unit to  
          review applications, and train clinic surveyors in order to  
          process license applications in a more timely, uniform, and  
          cost-effective manner.

          AB 2259 (Woodruff), Chapter 1020, Statutes of 1993,  
          provides for the licensure of mobile clinics to ensure the  
          availability of quality health care services for patients  
          in remote or underserved areas, and imposed various  
          licensure requirements and safety standards on mobile  
          clinics.

          SB 1140 (Royce), Chapter 1456, Statutes of 1987, requires  
          provisional licensure for clinics, and other types of  
          health facilities.

          Arguments in support
          The California Primary Care Association (CPCA) states that  
          this bill would eliminate unnecessary administrative  
          barriers to increasing access to care by allowing primary  
          care clinics to operate multiple sites under one  
          consolidated license.  CPCA states that moving to a  
          consolidated licensure will streamline the licensing  
          process, reduce duplication, and promote administrative  
          efficiency, and thereby maximize the ability of safety net  
          providers to meet the growing health care needs of  
          individuals and families in their communities.

          Planned Parenthood Affiliates of California (PPAC) states  
          that each time a clinic corporation applies for a new  
          clinic, numerous documents must be submitted to DPH, many  
          of which are duplications of paperwork already filed with  
          the department.  PPAC states that significant time and  
          money is expended on these cumbersome licensing activities  
          that take away from the critical services clinic staff  
          should be providing.  PPAC states that this bill would  
          streamline and modernize the current overly burdensome  
          processes and eliminate duplication.
          
                                     COMMENTS




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          1.  Bill should clarify that clinic corporations must have  
          no significant enforcement actions against its license in  
          order to be eligible to apply for a consolidated license.   
          Under current law, a parent clinic may not be eligible to  
          establish affiliate clinic sites unless it has held a  
          valid, unrevoked and unsuspended license, as specified, has  
          no demonstrated history of repeated or uncorrected  
          violations, and has no pending suspension or revocation  
          action against its license.  Since the clinic corporation  
          model proposed by this bill is similar to the parent clinic  
          model established by existing law, a suggested amendment  
          would be to require clinic corporations to meet the same  
          licensing standards as parent clinics when applying for a  
          consolidated license.
          
          Proposed amendment:

          Page 6, line 28, insert:

           (1) The clinic corporation applying for the consolidated  
          license must have held a valid, unrevoked, and unsuspended  
          license for at least the immediately preceding five years,  
          with no demonstrated history of repeated or uncorrected  
          violations of this chapter, or any regulation adopted under  
          this chapter, that pose immediate jeopardy to a patient, as  
          defined in subdivision (d) of section 1218.1, and have no  
          pending action to suspend or revoke its license.
           
          2.  Bill limits DPH's enforcement authority.  The bill  
          would prohibit an enforcement action by DPH against a  
          clinic included in a consolidated license from being deemed  
          an action against the clinic corporation as a whole.   
          However, as the sole licensee, the clinic corporation would  
          be responsible for the compliance of the clinics on its  
          consolidated license.  DPH should have the authority to  
          take action against the license of a clinic corporation, if  
          a clinic on the license fails to comply with licensing  
          requirements.
          Further, the bill would prohibit DPH from revoking or  
          suspending a consolidated license unless all of the clinics  
          under the license are cited in the notice of deficiencies,  
          and the clinic corporation failed to correct the  
          deficiencies in every clinic.  Under these provisions, a  
          clinic corporation with 10 clinics on its consolidated  
          license could have uncorrected deficiencies in 9 out of the  




          STAFF ANALYSIS OF SENATE BILL  SB 442 (Ducheny)Page 10


          

          10 clinics, and DPH would not be able to take action to  
          revoke or suspend the consolidated license if deemed  
          appropriate.  The intent of the author is to ensure that an  
          action by DPH to remove or suspend a clinic under a  
          consolidated license does not automatically apply to all of  
          the clinics under the license.  The bill should be amended  
          to reflect the author's intent.  Additionally, to ensure  
          patient safety, DPH should have the authority to take  
          action to initiate revocation or suspension action against  
          clinic corporations if the department determines that  
          failure to do so will result in patient harm.

          Proposed amendments:

             a.   Page 9, lines 4-6:

           An action against one or more clinics included in the  
          consolidated license shall not be deemed an action against  
          the clinic corporation as a whole.

              b.    Page 14, lines 11-19:

           Action taken by the department to suspend or remove one or  
          more clinics from a consolidated license shall not result  
          in the automatic suspension or revocation of the  
          consolidated license, unless the department determines that  
          failure to do so would result in the immediate jeopardy, as  
          defined in subdivision (d) of Section 1218.1, of a patient.  
            In no case shall the department initiate an action to  
          revoke or suspend the single consolidated license for  
          uncorrected deficiencies outlined in a written notice of   
          deficiencies, in one or more clinics included in a single  
          consolidated license, unless each clinic, including a  
          mobile health care unit, that is included in the single  
          consolidated license is cited in the notice of deficiencies  
          and the clinic corporation failed to correct the  
          deficiencies in every clinic within the allotted time  
          period according to the plan of correction.
           
          3.  Consolidated license fee calculation unclear.  In its  
          current form, the bill's provision pertaining to the  
          calculation of licensing fees for a consolidated license is  
                                                                                   unclear.  The author and sponsor intend to work with DPH to  
          develop a method by which to calculate fees for  
          consolidated licensure that reflects DPH's workload and  
          costs, which for most licensing activities, such as  




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          inspections and enforcement, will likely remain steady, but  
          that also reflects potential cost savings from a  
          streamlined licensure process.  In the meantime, the author  
          should amend the bill to remove the current unclear  
          language requiring the calculation of the estimated fee. 

          Page 15, lines 31-38:

          (d) Commencing February 1, 2010, and every February  
          thereafter, the department shall publish the estimated fee  
          for a single consolidated license issued under Section  
          1212.5 pursuant to this section. The  calculation of the   
          estimated fee  shall be based on a percentage of the fee for  
          primary care clinics,  for each primary care clinic included  
          in a single consolidated license  , and  shall be included in  
          the report and list of estimated fees required by  
          subdivisions (c) and (e).
          
          4.  Consolidated license should specify name, location, and  
          other basic information about each clinic on the license.   
          When introduced, this bill contained a requirement for the  
          department to include the name, location, hours of  
          operation, and services of each clinic included on a  
          consolidated license.  The current version of the bill does  
          not contain this provision.  However, for the purposes of  
          basic identification of clinics on a consolidated license,  
          this provision should be added back into the bill.
          
          Proposed amendment:

          Page 7, after line 4, insert:

           (e) A single consolidated license issued by the department  
          shall specify the name, location, hours of operation, and  
          services of each clinic included in the license.

           5.  DPH should give approval for transfer of special  
          permits.  This bill would allow a clinic corporation to  
          transfer a special permit from one clinic site to another  
          included in the consolidated license.  The bill should  
          specify that a clinic corporation may conduct such a  
          transfer only after obtaining approval from DPH.
          
          Proposed amendment:

          Page 8, lines 22-27:




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          (k) Upon written notice to the department, a clinic  
          corporation that has been issued a single consolidated  
          license may apply for one or more special permits pursuant  
          to Section 1202. A clinic corporation that is issued one or  
          more special permits may,  with approval from the  
          department,  transfer the special permits from one clinic  
          site to another site that is included in the single  
          consolidated license.

          6.  Clinics added to an existing consolidated  license  
          would not have to prove compliance with minimum  
          construction and physical plant standards.  To qualify for  
          consolidated licensure, a clinic corporation must submit  
          evidence that each of the primary care clinics on its  
          license meet specified construction and physical plant  
          standards.  However, the bill would require a clinic that  
          is added to an existing consolidated license, to simply  
          self-attest that it meets such standards.  These provisions  
          appear to be in conflict, and in order to ensure patient  
          safety, the bill should require a clinic corporation to  
          prove that all of its clinics, including those that are  
          added to an existing license, meet these standards.  

          Proposed amendment:

          Page 8, lines 13-16:

          (4) A self-attestation that each clinic site added meets  
          the requirements of Section 1212,  including  and evidence  
          that each clinic site meets minimum construction standards  
          for adequacy and safety of physical plant, pursuant to  
          subdivision (b) of Section 1226.
          7.  Proposed technical and clarifying amendments.
          
          a.  Page 2, lines 27-33 and Page 3, lines 13-15:

          (3) "Clinic corporation" means a nonprofit organization  
          that operates one or more primary care clinics, as defined  
          in paragraphs (1) and (2) of subdivision (a) of Section  
          1204, that are required to be licensed under Section 1205,  
           that may include  one or more mobile health care units  
          required to be licensed or approved pursuant to the Mobile  
          Health Care Services Act (Chapter 9 (commencing with  
          Section 1765.101)) and operated as primary care clinics, or  
          one or more primary care clinics and one or more mobile  




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          health care units.

          b.  Page 6, lines 2-3:

          ?primary care clinic, as defined in  paragraphs   paragraph  
           (1) and  (2)  of subdivision (a) of section 1240   1204,  the  
          department shall issue a single?

          Page 6, line 39:

          ?subdivision (b) of Section  1126   1226  , for each primary  
          care clinic?

          c.  Page 7, lines 2-4:

          (5) There are one or more medical directors operating under  
          a single set of policies, procedures, and standards for all  
          the primary care clinics  and mobile health care units   
          maintained and operated by the licensee.

          d.  Page 7, line 32:

          ?was submitted on the date the denial  of the consolidated  
          license  was  released   issued.
           
          e.  Page 7, line 33:

          (h) Upon application to the department,  a  clinic  
          corporation that?
           
           f.  Page 8, line 6:

          ?for adding  or removing  a clinic between renewal periods  
          that includes all of?

          g.  Page 8, lines 31-33:

          ? Failure by the clinic corporation to make timely payment  
          of the renewal fee shall result in the expiration of  its  
          consolidated license   any licenses  and  any  special permits?

          h.  Page 9, line 2:

          ?1240 with respect to a primary care clinic,  mobile health  
          care unit,  or special services?
          




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          i.  Page 12, lines 4-11:

          1219. (a) Except for an affiliate clinic, as defined in  
          Section 1218.1, or a  clinic corporation that includes, in  
          its application for a single consolidated license, one or  
          more  primary care clinic  clinics, including a one  or more   
          mobile health care  units   unit,  that  were   was  licensed and  
          in good standing as of December 31, 2009,  and included in  
          an application by a clinic corporation for a single  
          consolidated license  , if a clinic or an applicant for a  
          license has not been previously licensed, the department  
          may only issue a provisional license to the clinic as  
          provided in this section.

                                    POSITIONS  

          Support:   California Primary Care Association (co-sponsor)
                 Planned Parenthood Affiliates of California  
          (co-sponsor)
                 Alliance Medical Center 
                 Alliance for Rural Community Health
                 Alta Med Health Services
                 Anderson Valley Health Center
                 California Family Health Council
                 Central Valley Health Network
                 Chinatown Service Center
                 Clinicas del Camino Real, Incorporated
                 Clinica de Salud del Valle de Salinas
                 Clinica Sierra Vista
                 Community Clinic Association of Los Angeles County
                 East Community Health Center, Inc.
                 Eisner Pediatric and Family Medical Center
                 Family HealthCare Network
                 Family Health Centers of San Diego
                 Imperial Beach Health Center
                 LifeLong Medical Care
                 Long Valley Health Center
                 MayView Community Health Center
                 Mendocino Coast Clinics, Inc.
                 Mendocino Community Health Clinics, Inc.
                 Neighborhood Healthcare
                 North Coast Clinics Network
                 North County Health Services
                 Northeast Valley Health Corporation
                 Open Door Community Health Centers
                 Petaluma Health Center




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                 Planned Parenthood Mar Monte 
                 Planned Parenthood of San Diego and Riverside  
          Counties
                 Planned Parenthood of Santa Barbara, Ventura and San  
          Luis Obispo
                 Planned Parenthood: Shasta-Diablo
                 Potter Valley Community Health Center
                 Redwood Coast Medical Services
                 Saban Free Clinic
                 Salud Para La Gente
                 Shasta Community Health Center
                 Shasta Consortium of Community Health Centers
                 Shingletown Medical Center
                 Six Rivers Planned Parenthood
                 Southern Trinity Health Services
                 UMMA Community Clinic
                 Venice Family Clinic
                 West County Health Centers, Inc.
                  One individual

          Oppose:  None received


                                   -- END --