BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  SB 1089
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          Date of Hearing:   June 26, 2012

                        ASSEMBLY COMMITTEE ON HUMAN SERVICES
                                Jim Beall Jr., Chair
                     SB 1089 (Liu) - As Amended:  April 17, 2012

           SENATE VOTE  :  39-0
           
          SUBJECT  :  Child Day Care Facilities

           SUMMARY  :  This measure would exclude facilities that provide 
          behavioral programming services to minors from child care 
          licensing requirement exemptions unless they are under the 
          jurisdiction of specified state or county agencies.  
          Specifically,  this bill  :   

          1)States legislative findings and declarations, including the 
            following:

             a)   Finds that youth  boot camps and other like programs 
               operate as non-profit organizations under Section 501(c)(3) 
               of the federal Internal Revenue Code, which utilize 
               non-traditional behavioral treatment methodologies and are 
               intended to provide services in a less restrictive 
               environment for children with significant behavioral 
               issues.

             b)   These programs advertise themselves as alternative 
               behavioral treatment programs for youth with significant 
               behavioral issues who may feel they have few other options.

             c)   The growth of youth boot camps that employ high-risk 
               tactics on children, such as extreme physical exertion, 
               began in the 1990s, which has led to thousands of 
               allegations of abuse, neglect and death.

             d)   In 2011 a youth boot camp in Pasadena, California was 
               alleged to have kidnapped, abused, endangered, extorted, 
               and impersonated law enforcement authorities to youth in 
               their programs. 

             e)   A few youth boot camp programs in California operate 
               without a license, which place children under their care at 
               risk. 








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             f)   It is the Legislature's role to ensure proper licensing 
               and regulation of social service providers for the 
               protection and care of all citizens. 

          2)Prohibits the exemption from state licensing requirements of 
            entities that provide behavioral programming to address 
            conduct described in Section 601 of the Welfare and 
            Institutions Code (WIC), unless the facility is:

             a)   Under the jurisdiction of the California Department of 
               Corrections and Rehabilitation, Division of Juvenile 
               Facilities;

             b)   Under the jurisdiction of the California Department of 
               Education; or

             c)   A County-operated facility. 

          3)Adds to the list of facilities exempted from licensure by the 
            California Department of Social Services (DSS) outpatient 
            behavior programs for children with developmental disabilities 
            that are a vendor of a regional center. 

           EXISTING LAW  

          1)Establishes the California Child Day Care Facilities Act 
            (CCDCFA) to provide a comprehensive, quality system for 
            licensing child care facilities to ensure a quality day care 
            environment and states that good quality child care services 
            are essential services for working parents.

          2)Sets licensing requirements and provides authority to DSS to 
            develop and adopt regulations to administer the CCDCFA, 
            including the authority to set licensing standards for 
            facilities that provide nonmedical care to children under the 
            age of 18.

          3)Defines a "day care center" as any child day care facility 
            other than a family day care home, and includes infant 
            centers, preschools, extended day care facilities, and school 
            age child care centers.

          4)Defines a "family day care home" as a home that regularly 
            provides care, protection and supervision for 14 or fewer 
            children for periods of less than 24 hours per day.







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          5)By regulation, prohibits any adult, general partners of a 
            partnership, controlling partners in a limited liability 
            corporation, county, city, public agency or other governmental 
            entity from operating, establishing, managing, conducting, or 
            providing care and supervision, as defined, without a valid 
            license issued by DSS. 

          6)Requires a criminal record clearance or a criminal record 
            exemption from DSS for any person who works in a child day 
            care facility.

          7)Exempts from state licensure requirements the following 
            facilities:

             a)   Health facilities

             b)   Clinics

             c)   Community Care Facilities

             d)   Family day care homes providing care for the children of 
               one family in addition to the provider's own children. 

             e)   Cooperative child care arrangements in family homes, as 
               specified.

             f)   Child care provided by a relative.

             g)   Public recreation programs, as specified.

             h)   Extended day care programs operated by public or private 
               schools. 

             i)   School parenting program or adult education child care 
               program, as specified.

             j)   Child day care programs that operates only one day a 
               week for no more than four hours.

             aa)  Child day care programs that offers temporary child care 
               services, as specified.

             bb)  Instructional programs provided in a classroom-like 
               setting, as specified.







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             cc)  Programs administered by the Department of Corrections, 
               as specified.

             dd)  A crisis nursery, as defined, until January 1, 2014. 

          8)Defines a juvenile delinquent, under Section 601 of the 
            Welfare and Institutions Code, as any person under the age of 
            18 who:

             a)   Persistently or habitually refused to obey the 
               reasonable and proper orders or directions of his or her 
               parents, guardian, or custodian.

             b)   Is beyond the control of that parent, guardian or 
               custodian.

             c)   Violates any ordinance of any city or county 
               establishing a curfew based solely on age.

             d)   Has four or more truancies within one school year, as 
               defined, or a school attendance review board or a probation 
               officer determines that the available public and private 
               services are insufficient or inappropriate to correct the 
               habitual truancy of the minor, or to correct the minor's 
               persistent or habitual refusal to obey the reasonable and 
               proper orders or directions of school authorities, or fails 
               to respond to directives of a school attendance review 
               board or probation officer or to services provided.

           FISCAL EFFECT  :  Unknown

           COMMENTS  :   

           Need for this bill:
           According to the author, this measure is needed to "ensure boot 
          camps, ranch camps, or forestry camps, are not excluded from the 
          child care licensing process."  These programs are often 
          intended to provide less restrictive treatment options for 
          children with significant mental health or behavioral issues.  
          However, there have been only two known non-residential youth 
          boot camps in California, specifically in Pasadena. 

          In one particular instance, a camp owner was arrested and 
          charged with child abuse, kidnapping, false imprisonment, 







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          extortion, and the unlawful use of a badge.  Upon further 
          inspection it was found that this camp did not have a DSS-issued 
          child care license, which would have required the camp to comply 
          with child safety laws, ensure that all staff undergoes a 
          criminal background check and provides for the protection of 
          children under their care, and be subject to the DSS complaints 
          process and operational accountability requirements.  

           Background
           These types of programs often use military-style boot camp 
          training regimens and significant physical exertion strategies 
          with the intent of building self-discipline, confidence and 
          organizational skills in troubled youth with severe behavioral 
          issues.  Children are typically housed in a dormitory or 
          barracks-like setting, where deprivation of everyday amenities, 
          like showers, regular meals, and access to media, i.e. 
          television, internet, etc. is common.

          Unlike residential youth boot camps, which are licensed and most 
          often overseen by the Department of Corrections and 
          Rehabilitation or local law enforcement agencies, such as a 
          County Sheriff or Probation Office, nonresidential youth boot 
          camps are not used as an out of home placement. According to the 
          Youth Law Center, children in privately operated nonresidential 
          youth boot camps are typically placed there by their parents, 
          who are seeking an alternative services option to help address 
          their child's serious behavioral issues.

          Although not previously uncommon, residential youth boot camps 
          became popular in the 1990s. Seen as an alternative to existing 
          service methodologies for difficult to serve youth with 
          significant behavioral problems, residential youth boot camps 
          were found to produce positive behavioral outcomes through the 
          use of intense physical activities.  However, due to their 
          extreme use of aggressive tactics, many have been accused of 
          child abuse and neglect, which has resulted in serious injury 
          and death. 

          In October, 2007 the United States Government Accountability 
          Office (GAO) released a report on "Concerns Regarding Abuse and 
          Death in Certain Programs for Troubled Youth."  The GAO 
          primarily looked at specific allegations of child abuse, some of 
          which resulted in death, at residential treatment programs 
          throughout the country.  The term 'residential treatment 
          program' was used by the GAO to encapsulate private entities 







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          "that call themselves wilderness therapy programs, therapeutic 
          boarding schools, academics, behavioral modification facilities, 
          ranches, and boot camps, among other names." 

          The GAO worked to identify a common or universal definition of a 
          youth boot camp but found it "difficult to obtain an overall 
          picture of the extent of the residential treatment program 
          industry." According to the GAO, in the context of the report, 
          the phrase "residential treatment program" can refer to 
          organizations throughout the country that call themselves 
          "wilderness therapy programs, boarding schools, academies, 
          behavioral modification facilities, and boot camps, among other 
          names." 

          In a follow up report issued in April, 2008, the GAO examined 
          selected cases of death, abuse and deceptive marketing by 
          residential treatment programs.  In its review of ten closed 
          civil or criminal cases, ineffective management was found to be 
          a common occurrence in a private "residential treatment program" 
          where inexperienced staff and inadequate equipment and 
          facilities led to unmet needs and resulted in increased 
          instances of child abuse, neglect and death.  

          Like residential youth boot camps, nonresidential youth boot 
          camps face similar concerns of neglect, abuse and death.  
          However, whereas some residential youth boot camps operate at a 
          regular "bricks and mortar" facility or series of facilities, 
          nonresidential youth boot camps that operate by day can use 
          multiple sites, which may or may not include regular facilities. 
           This makes it difficult to determine whether nonresidential 
          youth boot camps that operate at various physical locations that 
          may or may not have or utilize a facility should be licensed. 

           Licensing
           Under the CCDCFA, the Legislature declares its intent to provide 
          a comprehensive, quality system for licensing child care 
          facilities to ensure a quality day care environment and states 
          that good quality child care services are essential services for 
          working parents.  It also sets licensing requirements and 
          provides authority to DSS to develop and adopt regulations to 
          administer the act, including the authority to set licensing 
          standards for facilities that provide nonmedical care to 
          children under the age of 18.

          The CCDCFA defines a "child day care facility" as a facility 







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          that provides nonmedical care to children under 18 years of age 
          in need of personal services, supervision, or assistance 
          essential for sustaining the activities of daily living or for 
          the protection of the individual on less than a 24-hour basis.  
          Child day care facility includes day care centers, 
          employer-sponsored child care centers, and family day care 
          homes.  (Health and Safety Code 1596.750)  It also establishes a 
          separate definition for a "day care facility," which is defined 
          as any child day care facility other than a family day care 
          home, and includes infant centers, preschools, extended day care 
          facilities, and schoolage child care centers.  (Health and 
          Safety Code 1596.76)

          Further, Section 101158 of Title 22 of the California Code of 
          Regulations requires that "no adult, general partners of a 
          partnership, controlling partners in a limited liability 
          corporation, county, city, public agency or other governmental 
          entity from operating, establishing, managing, conducting, or 
          providing care and supervision" that meets facility capacity 
          authorizations to operate without a valid license issued by DSS.

          The CCDCFA is intended primarily for child development 
          facilities that provide educational and supervision services for 
          children ages zero to 12.  Adding nonresidential youth boot 
          camps as facilities that fall under the jurisdiction of this act 
          may not be appropriate as they provide more intensive and 
          aggressive behavioral treatment and intervention services for 
          youth typically over the age of 12 who have serious behavioral 
          issues. 

          It would more appropriate to place nonresidential youth boot 
          camps under the jurisdiction of the California Community Care 
          Facilities Act (CCCFA). Under the CCCFA, the Legislature 
          declares it the intent of the state to establish a coordinated 
          and comprehensive statewide service system of quality community 
          care for mentally ill, developmentally and physically disabled, 
          and children and adults who require care or services by a 
          facility or organization issued a license or special permit.  
          This includes the intent to assure that all people who require 
          these services are provided with the appropriate range of social 
          rehabilitative, habilitative and treatment services, including 
          residential and nonresidential programs tailed to their needs.  
          (Health and Safety Code Section 1501)

          According to the DSS, some residentially based boot camps are 







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          required to be licensed under the CCCFA as they provide 24-hour 
          care and supervision in a group home-like setting.  However, DSS 
          acknowledges that some residential boot camps, such as a 
          "wilderness boot camp" or an "outdoor therapy camp," which 
          provide "boot camp" type services do not fall under current 
          licensing requirements because they do not operate out of a 
          specific facility. 

           RECOMMENDED AMENDMENTS  
          It is unclear whether the bill's current language would achieve 
          the goal of ensuring that all nonresidential youth boot camps 
          are licensed.  Under its current language, it states that 
          facilities providing "behavioral programming to address conduct 
          described in Section 601 of the Welfare and Institutions 
          Code"--but not those operated by state agencies or counties as 
          specified--are not exempt from licensing requirements. 

          Since a parent can choose to place their child in a 
          nonresidential youth boot camp for any reason, the current 
          proposed language may inadvertently exclude certain 
          nonresidential youth boot camps from licensure requirements as 
          it may be difficult to prove or ascertain whether a parent 
          placed their in this type of program due to their child behaving 
          similar to what is described in Section 601 of the Welfare and 
          Institutions Code. 

          Additionally, because some but not all programs that provide 
          these types of camps do not fall within one licensing category 
          under the CCCFA or the CCDCFA, and because youth boot camps 
          purport to provide substantial and aggressive behavioral 
          intervention tactics that can produce both positive and negative 
          outcomes in a child's development, the bill should be amended to 
          define facilities that provide aggressive non-traditional 
          behavioral treatment services for youth to encompass facilities 
          or programs that operate "youth boot camps."  required to amend 
          their regulations to clarify licensing requirements for youth 
          boot camps.

          Specifically, staff recommends the following amendments: 

             1)   Add Section 1502.2 to the Health and Safety Code to 
               read:

                1502.2. "Private non-traditional alternative treatment 
               facility for youth" means any residential or 







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               non-residential facility or program operated by an 
               organization that provides aggressive non-traditional 
               punitive, retaliatory, aversive, or military style 
               behavioral treatment or intervention services for youth.

               (a) No person, firm, partnership, association organization, 
               or corporation shall operate, establish, manage, conduct, 
               or maintain a "private non-traditional alternative 
               treatment facility for youth" as defined in this section 
               unless applicable licensing requirements are met and all 
               components of the program are accredited by an independent 
               nonprofit accrediting organization approved by the 
               department, including the Commission on Accreditation of 
               Rehabilitation Facilities or the Joint Commission.

               (b) Corporal punishment may not be used in any private 
               non-traditional alternative treatment facility for youth.

               (c) For the purposes of this section "corporal punishment" 
               means willfully causing the infliction of physical pain or 
               injury on a child through physical contact, verbal or 
               emotional harassment, intimidation, humiliation, 
               exploitation, or abuse. 

                (d) Every resolution, bylaw, rule, ordinance, or other act 
               or authority permitting or authorizing the operation of a 
               "private non-traditional alternative treatment facility for 
               youth" that does not comply with this section is void and 
               unenforceable. 

               (e) Private non-traditional alternative treatment 
               facilities for youth do not include programs under the 
               jurisdiction of the Department of Corrections and 
               Rehabilitation, Division of Juvenile Facilities, the State 
               Department of Education, county-operated facilities or 
               programs, or a residential or nonresidential behavior 
               program for youth with developmental disabilities that is 
               under the jurisdiction of the Department of Developmental 
               Services or vendorized by a regional center pursuant to 
               Division 4.5 of the Welfare and Institutions Code.
           
             2)   On page 2, delete lines 28 through 30, pages three 
               through seven, and lines one through 33 on page eight.
                
          REGISTERED SUPPORT / OPPOSITION  :







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           Support 
           
          None on file
           
            Opposition 
           
          None on file

           Analysis Prepared by  :    Chris Reefe / HUM. S. / (916) 319-2089