BILL ANALYSIS                                                                                                                                                                                                    Ó






                                 SENATE HEALTH
                               COMMITTEE ANALYSIS
                       Senator Ed Hernandez, O.D., Chair


          BILL NO:       SB 161                                      
          S
          AUTHOR:        Huff                                        
          B
          AMENDED:       March 9, 2011                               
          HEARING DATE:  April 6, 2011                               
          1
          CONSULTANT:                                                
          6              
          Trueworthy                                                 
          1               
                                    SUBJECT
                                         
            Schools: emergency medical assistance: administration of 
                              epilepsy medication


                                     SUMMARY
                                         
          This bill would allow non-medical school personnel who 
          undergo voluntary training to administer the drug Diastat 
          to a pupil suffering an epileptic seizure.
                                         

                            CHANGES TO EXISTING LAW  

          Existing federal law:
          The Americans with Disabilities Act of 1990 prohibits 
          discrimination on the basis of disability by employers, 
          public accommodations, state and local governments, public 
          and private transportation, and in telecommunications.

          The Individuals with Disabilities Education Act (IDEA) 
          governs Individualized Educational Programs (IEPs) and the 
          special education process. IDEA guarantees children with 
          disabilities a "free appropriate public education" (FAPE) 
          in the least restrictive environment (LRE).

          Section 504 of the Rehabilitation Act of 1973 (Section 504) 
          provides federal financial assistance to state and local 
          education agencies to guarantee special education and 
                                                         Continued---



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          related services to eligible children with disabilities. 

          Requires school districts to provide FAPE to each qualified 
          person with a disability who is in the school district's 
          jurisdiction, regardless of the nature or severity of the 
          person's disability, which includes reasonable 
          accommodations required for the management of chronic 
          medical conditions. 
          



          Existing state law:
          Requires the governing board of any school district to give 
          diligent care to the health and physical development of 
          students, which may include employing properly certified 
          persons.  

          Provides that each student who is required to take 
          prescribed medication by a physician, may be assisted by 
          the school nurse or other designated school personnel if 
          the school district receives a written statement from the 
          physician detailing the method, amount, and time schedules 
          by which the medication is to be taken, and a written 
          statement from the parent or guardian of the student, 
          indicating the desire that the school district assist the 
          pupil in the matters set forth in the physician's 
          statement.

          Provides that no school district, officer of any school 
          district, school principal, physician, or hospital treating 
          a student shall be held liable for the reasonable treatment 
          of a child without the consent of a parent or guardian, 
          when the child is ill or injured during regular school 
          hours, requires reasonable medical treatment, and the 
          parent or guardian cannot be reached, unless the parent or 
          guardian has previously filed with the school district a 
          written objection to any medical treatment other than first 
          aid.

          Authorizes non-medical school personnel to administer the 
          following medication to a student in an emergency, after 
          receiving specified training:
                 Emergency epinephrine auto-injectors.  A 
               prescription for an auto-injector for a specific 




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               student is not required; the prescription is for the 
               school.  
                 Glucagon may be administered to students with 
               diabetes suffering from severe hypoglycemia in the 
               absence of a credentialed school nurse or other 
               licensed nurse onsite at the school.

          Authorizes non-medical school personnel to assist or 
          administer medication to a student on a routine, 
          non-emergency basis the following:
                 Assisting in the administration of prescribed 
               medication, or in the self-administration of 
               prescription auto-injectable epinephrine.  
                 Assisting in administration of prescribed 
               medication or in the self-administration of 
               prescription inhaled asthma medication. 
                 Assisting if the health care provider gives a 
               written statement with specific information, such as 
               the medication the pupil is to take, the dosage, and 
               the period of time during which the medication is to 
               be taken, and if the parent provides a written 
               statement initiating a request to have the medication 
               administered or otherwise assisted in the 
               administration of the medication.  

          Sets forth the scope of practice for nursing through the 
          Nursing Practice Act, which includes the administration of 
          medication, and prohibits any person from engaging in the 
          practice of nursing without a license.
          
          This bill:
          Makes various legislative findings and declarations, 
          including the declaration that whenever possible, Diastat 
          should be administered by a school nurse who has been 
          trained in its administration.

          Authorizes a school district to provide school employees 
          with voluntary medical training to provide emergency 
          medical assistance to students suffering from an epileptic 
          seizure.

          Requires a school employee with voluntary emergency medical 
          training to provide this emergency medical assistance in 
          accordance with guidelines that the Epilepsy Foundation of 
          America is encouraged to develop.




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                 The guidelines may be developed in coordination 
               with the State Department of Education, the California 
               Nurses Organization, the California Medical 
               Association, and the American Academy of Pediatrics.

          Prohibits a school employee, who does not volunteer or who 
          has not been trained, from being required to provide 
          emergency medical assistance. 

          Authorizes a parent or guardian of a pupil with epilepsy 
          who has been prescribed Diastat to request the school have 
          one or more of its employees receive training in the 
          administration of Diastat.

          Requires, upon receipt of the parent's or guardian's 
          request, the school to notify the parent or guardian that 
          his or her child may qualify for services or 
          accommodations, pursuant to Section 504.  Requires the 
          school to assist in the exploration of that option.

          Authorizes a school to ask the parent or guardian to sign a 
          notice verifying they were given information about Section 
          504 and they understand it is their right to request a 
          Section 504 plan at any time.

          Authorizes a school to create an individualized health 
          plan, seizure action plan, or other appropriate health plan 
          designed to acknowledge and prepare for the child's health 
          care needs in school if the parent chooses to not have the 
          pupil assessed for a Section 504 plan. The plan may include 
          the involvement of trained volunteer school employees.

          Authorizes a school that decides to train voluntary school 
          employees to distribute an electronic notice to all staff 
          that states all of the following:
             1.   The notice is a request for volunteers to 
               administer Diastat to a pupil experiencing a severe 
               epileptic seizure, in the absence of a school nurse.
             2.   Diastat is an FDA-approved, pre-dosed, 
               rectally-administered gel that reduces the severity of 
               epileptic seizures.
             3.   A volunteer will receive training from a licensed 
               health professional regarding the administration of 
               Diastat.
             4.   Any agreement by an employee to administer Diastat 




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               is voluntary, and no employee of the school or 
               district shall directly or indirectly use or attempt 
               to use his or her authority or influence for the 
               purpose of intimidating, threatening, coercing, or 
               attempting to intimidate, threaten, or coerce, any 
               staff member who does not choose to volunteer.   

          Requires a school to re-notify the pupil's parent or 
          guardian of the Section 504 options if there are no 
          volunteers.

          Encourages the Epilepsy Foundation to develop guidelines 
          for training and supervision.

          Requires a school that chooses to train school employees to 
          have in place a school plan that includes:
             1.   Identification of existing licensed staff within 
               the district or region who could be trained in the 
               administration of Diastat and could be available to 
               respond to an emergency need to administer Diastat.   
             2.   Identification of pupils who may require the 
               administration of Diastat.   
             3.   Written authorization from the parent or guardian 
               for a non-medical school employee to administer 
               Diastat. 
             4.   A requirement that the parent or guardian notify 
               the school if the pupil has had Diastat administered 
               within the past four hours on a school day.
             5.   Notification to the parent or guardian that Diastat 
               has been administered.
             6.   A written statement from the pupil's health care 
               practitioner that shall include all of  the following:
                  a)        The pupil's name.
                  b)        The name and purpose of the medication.
                  c)        The prescribed dosage.
                  d)        Detailed seizure symptoms, including 
                    frequency, type, or length of seizures that 
                    identify when the administration of Diastat 
                    becomes necessary.
                  e)        The method of administration.
                  f)        The frequency with which the medication 
                    may be administered.
                  g)        The circumstances under which the 
                    medication may be administered.
                  h)        Any potential adverse responses by the 




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                    pupil and recommended actions, including when to 
                    call emergency services.
                  i)        A protocol for observing the pupil after 
                    a seizure.

          Requires a school to compensate a volunteer when the 
          administration of Diastat and subsequent monitoring of a 
          pupil requires the person to work beyond his or her 
          normally scheduled hours.

          Requires the training to include the following:
             1.   Recognition and treatment of different types of 
               seizures.
             2.   Administration of Diastat.
             3.   Basic emergency follow-up procedures including, 
               calling 911 and contacting the pupil's parent or 
               guardian.
             4.   Techniques and procedures to ensure pupil privacy.

          Requires training to be conducted by one or more of the 
          following:
             1.   A physician and surgeon. 
             2.   A physician and surgeon's assistant.  
             3.   A credentialed school nurse. 
             4.   A registered nurse. 
             5.   A certificated public health nurse.

          Deems training provided in accordance with the 
          manufacturer's instructions, the pupil's health care 
          provider's instructions and guidelines as adequate 
          training.

          Requires a school employee to notify the credentialed 
          school nurse assigned to the school district if Diastat is 
          administered.  If a credentialed school nurse is not 
          assigned to the school district, the school employee shall 
          notify the superintendent of the school district, or his or 
          her designee.

          Requires a school to retain all records relating to the 
          administration of Diastat.

          Requires the pupil's parent or guardian to provide all 
          materials necessary to administer Diastat.





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          Defines "Diastat" as a diazepam rectal gel, marketed as 
          Diastat AcuDial, approved by the federal Food and Drug 
          Administration for patients with epilepsy for the 
          management of seizures.

          Sunsets the provisions of this bill on January 1, 2017,


                                  FISCAL IMPACT  

          This bill has not been analyzed by a fiscal committee.

                                         
                           BACKGROUND AND DISCUSSION
                                         
          According to the author, uncontrolled seizures can damage a 
          child's developing brain and can impact academic 
          performance, memory, learning, and result in 
          social-emotional challenges.  Some children with epilepsy 
          are susceptible to prolonged seizures and require access to 
          a life-saving emergency medication.  Diastat Acudial, a 
          pre-dosed preparation of diazepam gel, is the standard 
          out-of-hospital treatment for prolonged seizures.  Diastat 
          is a FDA-approved emergency medication and is a safe and 
          effective treatment, specifically designed to be 
          administered by people without medical training. 

          The author states that for over 10 years it was common in 
          California schools to have nurses, or where unavailable, 
          trained non-medical personnel to administer the 
          doctor-prescribed Diastat in an emergency situation to a 
          student when suffering a severe, possibly life-threatening 
          seizure.  In October 2009, however, a nursing education 
          consultant to the Board of Registered Nursing (BRN) advised 
          that there is no provision in the Nursing Practice Act for 
          unlicensed school personnel to administer Diastat.  The BRN 
          has further stated that absent an authorizing statute, 
          school nurses cannot train or supervise unlicensed 
          personnel to administer Diastat.  As a consequence, nurses 
          are refusing to train school personnel, and schools are 
          reluctant to have staff, even those already trained, 
          administer Diastat.  Some schools are telling parents they 
          must be available to come to the school to administer 
          Diastat or are calling 911 in an emergency. The author 
          contends that either of these solutions results in delays 




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          in treatment that places the child in danger of serious 
          injury, or worse.  SB 161 will allow schools to provide the 
          fastest, safest and most effective way of protecting the 
          health and safety of children with epilepsy in schools.

          Epilepsy background and statistics
          Epilepsy is defined as a chronic neurological condition in 
          which the individual is susceptible to several seizures.  A 
          seizure is a sudden, temporary interruption of the normal 
          electrical/chemical activity in the brain, resulting in a 
          change in sensation, awareness or behavior. A seizure can 
          range from a brief disruption of senses, muscle spasms, or 
          odd sensations to short periods of unconsciousness and 
          convulsions. Currently there is no known cure for epilepsy.

          Epilepsy is a complex condition and there are many types of 
          seizures associated with epilepsy.  The type of seizure a 
          person has depends on a variety of things, such as the part 
          of the brain affected and the underlying cause of the 
          seizure. The type of medicine individuals with epilepsy 
          take depends on the type of seizures. 

          Almost 3 million people in the U.S. have some form of 
          epilepsy. About 200,000 new cases of seizure disorders and 
          epilepsy are diagnosed each year.  According to the 
          Epilepsy Foundation, as many as 325,000 school-age 
          children, ages 5-14, have epilepsy.  Epilepsy affects over 
          90,000 children across California.  
          
          Diastat
          Diastat --diazepam rectal gel and its trademark 
          administration system-- was first approved for use by the 
          FDA in the United States in 1997 as a treatment for 
          breakthrough seizures in adults and children 2 years old 
          and over.  This is the only FDA-approved, at-home 
          medication for the treatment of cluster seizures. Diastat 
          was specifically developed to be administered by people 
          without medical training and is considered the fastest, 
          safest and most effective way to address epileptic 
          seizures.  It is often prescribed for people who have 
          experienced acute repetitive seizures, or "cluster" 
          seizures.  Dosages are determined on an individual basis, 
          depending upon the condition to be treated, the severity of 
          symptoms, the body weight of the patient, and any 
          comorbidity conditions the patient may have.  




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          Diastat is intended to be kept handy so that a caregiver 
          can attempt to stop the seizures by administering the drug 
          relatively quickly.  Diastat is a gel formulation of 
          Diazepam (valium) that is administered rectally.  The 
          delivery system includes a plastic applicator with a 
          flexible, molded tip and is provided in fixed unit-doses of 
          5, 10, 15 and 20 mg.  A pharmacist simply dials the syringe 
          to the physician's prescribed dosage before it is dispensed 
          to the patient.  

          The most common side effect is sleepiness. Other less 
          frequent side effects include skin rash, dizziness, pain, 
          headache, stuffy nose, abdominal pain, nervousness, 
          diarrhea, feeling unsteady or clumsy, and wheezing.

          Most seizure patients, no matter how well-managed through 
          maintenance medication, will likely experience breakthrough 
          seizures throughout their lifetime. Possibly as many as 35 
          percent of patients on anti-seizure medications may not be 
          adequately controlled.   Between 50,000 and 200,000 
          generalized convulsive status epilepticus seizures occur 
          every year in the United States, with an overall mortality 
          rate of 20 percent.  Additional statistics show that status 
          seizures lasting more than one hour have a mortality rate 
          of 32 percent, compared with 2.7 percent for seizures of 
          shorter duration. 

          Health care needs in schools
          In classrooms throughout California, there are numerous 
          children with special medical needs, including gastronomy 
          feeding tubes, oxygen administration, tracheal suctioning 
          and monitoring for seizures.  California's nurse-to-pupil 
          ratio is approximately 1:2,200.  According to the 
          California Basic Educational Data System (CBEDS), about 
          one-half of school districts do not have a school nurse.  

          Federal laws and 504 plans
          Two federal anti-discrimination statutes, Section 504 of 
          the Rehabilitation Act of 1973 (Section 504) and Title II 
          of the Americans with Disabilities Act of 1990 (ADA), 
          together establish rights for eligible students in 
          California's public schools. They serve to protect students 
          from discrimination based upon their disability.  In 
          general, a student will be determined to have a disability 




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          under Section 504 if he/she has a mental or physical 
          impairment that substantially limits one or more major life 
          activities, such as eating, breathing, caring for oneself, 
          performing manual tasks, hearing, speaking, walking, and 
          learning. 

          Section 504 requires school districts to provide FAPE to 
          each qualified pupil, regardless of the nature or severity 
          of the disability. An appropriate education may comprise of 
          education in regular classes, education in regular classes 
          with the use of related aids and services, or special 
          education and related services in separate classrooms for 
          all or portions of the school day. 

          A "504 plan" differs from an individualized education 
          program (IEP) in that an IEP provides for specialized 
          instruction while a 504 plan provides for accommodation due 
          to a physical or mental impairment that does not require 
          specialized instruction.  

          The Nursing Practice Act and the Bureau of Registered 
          Nursing (BRN)
          The Nursing Practice Act (NPA) specifies that medication 
          administration is a nursing function that may not be 
          performed by unlicensed personnel unless expressly 
          authorized by statute.  

          The BRN has issued a legal opinion stating the NPA does not 
          permit unlicensed school personnel to administer Diastat 
          and the administration of Diastat constitutes the practice 
          of nursing.  The legal opinion further states that the NPA 
          does not permit a nurse to train unlicensed school 
          personnel knowing that the purpose for the training is to 
          enable the administration of Diastat.

          Exceptions to the Nursing Practices Act
          Current law authorizes non-medical school personnel to 
          administer emergency epinephrine auto-injectors in an 
          emergency after receiving specified training.  Current law 
          also allows Glucagon to be administered to students with 
          diabetes suffering from severe hypoglycemia in the absence 
          of a credentialed school nurse or other licensed nurse 
          onsite at the school.

          The NPA does not prohibit nursing services in the case of 




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          an emergency. 
          
          Lawsuit specific to the administration of insulin.  
          In 2005, the American Diabetes Association (ADA) sued the 
          State of California (K.C., et al. vs. Jack O'Connell, et 
          al) asking the court to compel public school officials to 
          comply with federal law by providing the assistance that 
          California students with diabetes require to manage their 
          diabetes during the school day. The California Department 
          of Education (CDE) entered into a settlement with them and, 
          as a part of the settlement, CDE issued a legal advisory 
          that declared unlicensed but adequately trained school 
          employees may administer insulin under the treating 
          physician's orders and in accordance with the student's 
          Section 504 Plan or IEP, in the absence of available 
          licensed health care professionals. 

          Several nursing groups sued to overturn this portion of the 
          legal advisory (American Nurses Assoc. v. Jack O'Connell), 
          and in November 2008, a trial court judge ruled in their 
          favor. Following the court ruling, ADA and CDE filed an 
          appeal of the court ruling, and in April 2009, a California 
          Court of Appeals ruled that the lower court's ruling is 
          "stayed" during the appeal. While this is not a decision on 
          the merits of the case, it does mean that the lower court's 
          ruling has no effect until the appeal is decided.  

          Therefore, the CDE may continue to advise districts that 
                  non-medical school personnel are authorized to administer 
          insulin.

          Related bills
          SB 65 (Strickland) would authorize any pupil who has been 
          diagnosed with cystic fibrosis and is required to take, 
          during the regular school day, medication prescribed for 
          him or her by a physician or surgeon, to be assisted by the 
          school nurse or other designated school personnel, or may 
          carry and self-administer prescription pancreatic enzymes 
          if the school district receives specified written 
          statements.  SB 65 is pending before the Senate Education 
          Committee.

          Prior legislation
          SB 1051 (Huff) of 2010 was very similar to this bill.  SB 
          1051 was held on the Senate Appropriations Committee's 




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          suspense file.

          AB 1802 (Hall) of 2010 would authorize a parent or guardian 
          of a pupil with diabetes
          to designate one or more school employees as 
          parent-designated school employees for the purpose of 
          administering insulin to the pupil as necessary during the 
          regular school day when a credentialed school nurse or 
          other health care professional is not immediately available 
          onsite at the school. Failed passage in Assembly Business, 
          Professions, and Consumer Protection Committee. 
          
          SB 1200 (Leno) of 2010 would have required the Department 
          of Managed Health Care and the Insurance Commissioner to 
          develop regulations to ensure timeliness of care for school 
          age children who must receive medically necessary services 
          during school hours. Failed passage in the Assembly 
          Appropriations Committee. 

          AB 2454 (Torlakson) of 2010 would have required the 
          governing board of a school district to employ at least one 
          school nurse, registered nurse, or licensed vocational 
          nurse for every 750 pupils on and after July 1, 2020. The 
          bill would have required registered nurses and licensed 
          vocational nurses to provide health care services to pupils 
          under the supervision of a school nurse. Failed passage in 
          Assembly Appropriations Committee.

          AB 1430 (Swanson) of 2009 would have required, with certain 
          exceptions, that any medication that is administered to a 
          pupil who is required to take, during the regular school 
          day, medication prescribed for him or her by a physician or 
          surgeon be administered by a health care professional 
          operating within the scope of his or her
          practice. Failed passage in Assembly Business and 
          Professions Committee.

          AB 426 (Hall) of 2009 would have required the Department of 
          Education, in consultation with specified entities, to 
          recommend to the Legislature ways to address specific 
          health-related needs of pupils on school campuses, 
          including but not limited to, diabetes, asthma and 
          obesity-related diseases.  AB 426 was never heard.

          AB 942 (Leno) Chapter 684, Statutes of 2003, authorizes 




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          each school district to provide voluntary emergency medical 
          training to school personnel, as defined, to administer 
          emergency medical assistance to pupils with diabetes 
          suffering from severe hypoglycemia, if certain performance 
          standards for training and supervision are developed by the 
          American Diabetes Association in cooperation with several 
          other entities for approval and distribution by the State 
          Department of Health Services' Diabetes Control Program, in 
          the absence of a credentialed school nurse or other 
          licensed nurse. 

          AB 559 (Wiggins), Chapter 458, Statutes of 2001, authorizes 
          a school district or county office of education to provide 
          emergency epinephrine auto-injectors to trained personnel, 
          and authorizes the trained personnel to utilize those 
          epinephrine auto-injectors to provide emergency medical aid 
          to persons suffering from an anaphylactic reaction.

          Arguments in support
          Supporters write that Diastat is a safe and effective drug 
          and allowing trained school personnel to administer Diastat 
          could save an epileptic child from very serious injury.  
          The Health Officers Association of California (HOAC) writes 
          that without SB 161, school personnel would have to wait 
          for the child's parent or an ambulance to arrive in order 
          for the drug to be administered.  Epilepsy California 
          writes a student suffering from prolonged seizures that is 
          prescribed and yet denied access to Diastat risks permanent 
          brain damage or death.  After five minutes, seizures are 
          life threatening.  The California Association of Suburban 
          School Districts writes that Diastat is the first and only 
          FDA-approved, acute layperson-administered medication and 
          is the best option for providing a safe educational 
          environment for students.  

          Disability Rights of California (DRC) contends SB 161 is an 
          important step to providing children with epilepsy with a 
          free appropriate education.  DRC writes access to 
          medication is important for children with disabilities who 
          need it to be able to receive an education in the least 
          restrictive environment with their peers.  Riverside 
          Unified School District writes SB 161 is a critical 
          component of the overall medical and welfare care the 
          district provides to special needs students.





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          The Riverside County School Superintendents' Association 
          writes that it is the unfortunate fiscal reality that we 
          will not have nurses in our schools and we must adapt to 
          that fiscal reality in a manner that provides the most 
          health protection to the students.

          Supporters state that it has been common practice for over 
          10 years for trained non-medical personnel to have the 
          authority to administer doctor-prescribed Diastat to a 
          student suffering a severe and possibly life threatening 
          seizure.  Supporters further contend that SB 161 is 
          patterned after two existing laws which allow non-medical 
          school personnel to administer drugs, Epinephrine and 
          Glucagon.  Supporters argue these medications must also be 
          given in a specified and extremely short amount of time 
          from the onset of the episode.  Supporters argue Diastat, 
          like Epinephrine and Glucagon, is a life-saving measure.  
          If Diastat is administered incorrectly, the medication is 
          not life-threating, but a significant delay in receiving 
          treatment can be.

          Support if amended
          The California Association of Joint Powers Authorities 
          (CAJPA) writes that SB 161 does not contain needed "Good 
          Samaritan" liability immunity for the school employee or 
          the school who agrees to participate in the volunteer 
          program to help epileptic students in need.  In these 
          litigious times, CAJPA believes that adding this important 
          liability protection is critical to the ultimate success of 
          the proposed program.  Otherwise, volunteers and schools 
          will be very reluctant to agree to take on such important 
          duties and responsibilities as proposed in SB 161.

          Arguments in opposition
          A coalition of union groups including, the California 
          Teachers Association, California School Employees 
          Association, American Nurses Association-California, 
          California Nurses Association, California Labor Federation, 
          Service Employees International Union - Nurses Alliance of 
          California, and the California Federation of Teachers are 
          opposed to SB 161 writing that Diastat is a dangerous 
          medication that must be administered rectally to control 
          seizures.  The coalition writes that because a seizure is 
          unpredictable, providing for any level of privacy is nearly 
          impossible.  The coalition further argues that school 




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          employees face legal liability if something goes wrong as 
          school districts generally do not cover punitive damages.  
          Opponents also argue that SB 161 does not require 911 to be 
          called and in medical emergencies, a 911 call must be 
          required.

          The coalition supports having licensed, appropriately 
          trained health care personnel provide the high quality care 
          that is required to assure that not only children with 
          disabilities but all school children have access to a free, 
          fair and appropriate education.
          The United Nurses Association of California-Union of Health 
          Care Professionals writes in opposition to SB 161, arguing 
          the bill will "deskill the role of school nurses" at a risk 
          to children.  

          Opponents further argue that if an employee is named in a 
          lawsuit, they will have to go to court to defend themselves 
          and there are no protections against punitive damages or 
          criminal prosecution.

          The California School Employees Association (CSEA) argues 
          that training will be inadequate if provided at all, as the 
          bill does not provide funding for any training.  CSEA 
          writes that if a Registered Nurse is not available to 
          perform this duty, Licensed Vocational Nurses (LVNs) can 
          and should be used as they are appropriately licensed and 
          have the skills and ability to help epileptic students.
          




                                     COMMENTS

           1)Amendments in Education Committee.  The following 
            amendments were agreed to in the Senate Education 
            committee to be taken in the Senate Health Committee: 
             a)   Clarification that a school is required to provide 
               information about the possibility of eligibility for a 
               504 plan to a parent once the parent requests the 
               school to have an employee receive training in the 
               administration of Diastat.  

             b)   Delete reference to "a physician and surgeon's 




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               assistant" and only reference "physician assistant" as 
               those who may provide training to school employees.  
               There is no such position as a surgeon's assistant.

          2)Coercion issue.  Concern has been raised that employees 
            will face coercion and possible retaliation under SB 161. 
             While Section 49414.7 (b) of the bill states that a 
            school employee who does not volunteer or who has not 
            been trained shall not be required to provide emergency 
            medical assistance, staff recommends the following 
            amendments to clarify this issue:
               i)     Prohibit a face-to-face request for volunteers 
                 or face-to-face follow-up requesting volunteers.

               ii)    State that no response to the notice is 
                 required from school employees unless they are 
                 affirmatively volunteering.

               iii)   Add language to allow a school employee who has 
                 volunteered to opt-out by submitting written 
                 notification.

          3)Volunteers.  Staff recommends adding language in 
            subsection (f) of the bill to encourage schools to first 
            utilize LVNs prior to asking school employees to 
            volunteer for training.

          4)Definitions.  
             a)   Concern has been raised about who the bill applies 
               to.  Staff recommends adding language to clarify the 
               term "school employee" to mean any one or more 
               employees of a school district who volunteer to be 
               trained to administer emergency medical assistance to 
               a pupil suffering an epileptic seizure.

             b)   Staff recommends defining "emergency medical 
               assistance" to mean the administration of Diastat to a 
               pupil suffering from an epileptic seizure.
               
             c)   Concern has been raised about using a brand name 
               drug in legislation.  Staff recommends using a broader 
               definition and not the brand name drug.
          
          5)Liability Concerns.  Concern has been raised that 
            employees will not be afforded the same protections they 




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            currently have because the employee is volunteering.  
            While Section 49414.7(j) of the bill states that a school 
            that chooses to allow volunteers to administer Diastat 
            shall compensate a volunteer when the administration of 
            Diastat and subsequent monitoring of a pupil requires a 
            volunteer to work beyond his or her normally scheduled 
            hours, staff recommends adding language to clarify that 
            any actions undertaken as part of this section is 
            considered to be within the current scope of their 
            employment.

          6)School Plan. Section 49414.7(i) outlines the requirements 
            a school plan must include for school's choosing to 
            participate.  Staff recommends adding language to require 
            a 911 call in the school plan.  Training requirements 
            outlined in (k)(2)(C) of the bill already include calling 
            911 as basic emergency follow-up procedures.  

          7) Training.  
             a)   Section 49414.7 (k)(2) describes what the training 
               shall include.  Staff recommends adding language to 
               require written materials covering the information 
               described in this subsection to also be included and 
               to require a school to retain the written materials. 

             b)   Section 49414.7 (k) in subsections (1), (2), (3), 
               and (4) outline the training components.  Staff 
               recommends adding language to require documentation of 
               a completed training by a school employee be 
               maintained by both the school and school district.

             c)   Section 49414.7 (k)(1) only encourages the Epilepsy 
               Foundation of America to develop guidelines for 
               training and supervision.  The language is silent on 
               what will occur in the absence of such development.  
               i)     Staff recommends adding language to clarify 
                 that until such training guidelines are established 
                 and approved, the bill shall not take effect.  

               ii)    Staff also recommends adding language to 
                 require the Department of Education to approve any 
                 guidelines used for training.

             d)   Staff recommends adding language to require school 
               employees who have volunteered for training to be 




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               required to receive updated training on an annual 
               basis.

             e)   Staff recommends adding language to clarify that a 
               volunteer must receive training prior to administering 
               Diastat in Section 49414.7(g)(3) of the bill.
                                        
                                         
                                   POSITIONS  

          Support:  Association of Regional Center Agencies
                    The California Association of Joint Powers 
               Authorities (If Amended)
                    California Association of School Business 
                    Officials
                    California Association of Suburban School 
               Districts
                    California School Boards Association
                    Democrats for Education Reform
                    Disability Rights California
                    Epilepsy Foundation, California
                    Health Officers Association of California
                    Humboldt County Office of Education
                    Kern County Superintendent of Schools
                    Los Angeles County Office of Education
                    Los Angeles Unified School district
                    Orange County Department of Education
                    Riverside County School Superintendents' 
               Association
                    Riverside Unified School District
                    Saddleback Valley Unified School District
                    San Bernardino County District Advocates for 
               Better Schools
                    Small School Districts' Association
                    35 individuals
          
          Oppose:   American Nurses Association-California, 
                    California Labor Federation
                    The California Federation of Teachers
                    California Association for Nurse Practitioners
                    California Nurses Association
                    California School Employees Association 
                    California School Nurses Organization
                    California School Employees Association
                    California Teachers Association




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                    Laborers International Union of North America, 
               Local 777
                    Service Employees International Union-Nurses 
                    Alliance of California
                    United Nurses Associations of CA-Union of Health 
                    Care Professionals
                    United Teachers Los Angeles


                                   -- END --