BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 389
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 389 (Williams)
          As Amended  July 11, 2013
          Majority vote
           
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          |ASSEMBLY:  |76-0 |(April 18,      |SENATE: |39-0 |(August 26,    |
          |           |     |2013)           |        |     |2013)          |
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           Original Committee Reference:    ED.  

           SUMMARY  :  Requires private schools to fingerprint all employees  
          who will have contact with minors; specifies that as part of  
          certification, the Superintendent of Public Instruction (SPI)  
          may verify that a nonpublic, nonsectarian school or agency has  
          received a successful criminal background check clearance and  
          has enrolled in subsequent arrest notice service, for each  
          owner, operator, and employee of the school or agency; requires  
          a nonpublic, nonsectarian school or agency to, upon demand, make  
          available to the SPI evidence of a successful criminal  
          background check clearance and enrollment in subsequent arrest  
          notice service, for each owner, operator, and employee of the  
          school or agency; and, specifies a nonpublic, nonsectarian  
          school or agency shall retain the evidence and store it in a  
          locked file separate from other files.

           FISCAL EFFECT  :   According to the Senate Appropriations  
          Committee, the costs to the Department of Justice (DOJ) to  
          process fingerprints and obtain criminal background information,  
          as required by this bill, will be fully reimbursed by fees paid  
          to the Fingerprint Fees Account by the applicants or employers  
          (private, nonpublic schools).  To the extent that the SPI elects  
          to verify successful criminal background check clearance for  
          private schools during certification, there would likely be a  
          minor workload increase to the California Department of  
          Education (CDE). 

           COMMENTS  :   According to the author, this bill establishes  
          uniformity between public and private, nonpublic schools  
          regarding employee background check requirements.  Nonpublic  
          schools are private schools funded with public dollars to serve  
          students with exceptional needs. According to the CDE, there are  
          293 certified nonpublic schools.  Approximately 12,635  
          California students are educated each year in nonpublic schools  








                                                                  AB 389
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          located both in California and in other states.  
           
          This bill requires all private schools, including nonpublic  
          schools, to fingerprint their employees who have contact with  
          pupils; and, the bill further clarifies that during the  
          certification process for nonpublic schools, the SPI shall have  
          access to evidence that demonstrates these schools are  
          completing the necessary background checks on their employees.

          Nonpublic schools often serve the most vulnerable students. When  
          a child has needs that cannot be met in a public school setting,  
          that child may be educated in a nonpublic school at public  
          expense. Students qualified for placement in nonpublic schools  
          have exceptional learning, behavioral, or physical handicapping  
          conditions that negatively impact their educational progress.  
          Typical handicapping conditions of nonpublic school students  
          include: learning disabled, seriously emotionally disturbed,  
          developmentally disabled, autistic, speech and language  
          impaired, or other health impairments. These students, like all  
          California students, deserve to be protected but are potentially  
          most at risk of not being able to communicate abuse.

           Fingerprinting at Private Schools and Nonpublic Schools  :   
          Current law requires districts and charter schools to conduct a  
          background check on any certificated employee whose employment  
          status is temporary, substitute, or probationary or on any  
          non-certificated person who will be employed by the district.   
          Because districts and charter schools are required to establish  
          a relationship regarding employees with the DOJ through the  
          background check process, public school districts and charter  
          schools are notified of subsequent arrests.  This mechanism  
          enables them to take immediate action including conducting their  
          own internal investigation of an arrest.  If necessary, a  
          district or charter school can then immediately remove an  
          employee from a classroom to ensure student safety.

          Existing law exempts certificated or licensed employees at  
          private schools, including nonpublic schools, from the  
          background check requirements if these individuals possess a  
          valid California state teaching credential or are currently  
          licensed by another state agency that requires a criminal record  
          summary.  Although the Commission on Teacher Credentialing (CTC)  
          and other licensing agencies require background checks, the law  
          prohibits interagency sharing of records thereby preventing the  
          CTC from providing to districts information it receives from the  








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          DOJ. Consequently, private schools, including nonpublic schools,  
          would not receive notification of any arrest of a certificated  
          employee if one occurred after they are hired. 

          Because public school districts or charter schools are required  
          to have a relationship established with the DOJ, the district or  
          charter school is quickly notified of an arrest and has the  
          ability to take immediate action and investigate the arrest.   
          However, since there is no existing requirement that a private  
          school, including a nonpublic school, establish a relationship  
          with the DOJ through background checks, a private school,  
          including a nonpublic school, would not be notified if an  
          employee is arrested, and under the current process, would not  
          be able to immediately undertake an investigation to ensure the  
          safety of students who interact with that employee. 

           Certification for Nonpublic Schools  :  The SPI certifies  
          nonpublic schools and part of the certification process requires  
          the SPI to confirm that the school is doing the proper  
          background checks on its employees.  Due to privacy laws, the  
          SPI is not able to obtain the appropriate evidence that the  
          background checks are taking place when the employees are hired  
          and that proper steps are taken when someone is arrested after  
          they are hired.  This bill requires nonpublic, nonsectarian  
          schools to provide the SPI evidence of a criminal background  
          check and clearance on each operator and employee.  The Assembly  
          should consider what evidence the SPI will have access to as  
          part of this requirement and whether this evidence will be  
          sufficient to certify the process is being handled  
          appropriately.  The Assembly should also consider whether the  
          evidence obtained by the SPI will violate any privacy laws.  
           

          Analysis Prepared by  :    Chelsea Kelley / ED. / (916) 319-2087 


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