BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 961
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          Date of Hearing:  April 16, 2013

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                Bob Wieckowski, Chair
                 AB 961 (Levine) - As Introduced:  February 22, 2013

                                  PROPOSED CONSENT
           
          SUBJECT  :  HEALTH FACILITIES: INVESTIGATIONS: PUBLIC DISCLOSURE

           KEY ISSUE  :  SHOULD THE PUBLIC HAVE GREATER AND MORE TIMELY  
          ACCESS TO CITATION REPORTS ISSUED BY THE DEPARTMENT OF PUBLIC  
          HEALTH TO LONG-TERM CARE FACILITIES THAT DOCUMENT HEALTH OR  
          SAFETY VIOLATIONS INVOLVING RESIDENTS WITH DEVELOPMENTAL OR  
          PSYCHIATRIC DISABILIITES?

           FISCAL EFFECT  :  As currently in print this bill is keyed fiscal.

                                      SYNOPSIS
          
          This non-controversial bill, sponsored by Disability Rights  
          California, seeks to improve public access to meaningful  
          information regarding complaints or health and safety violations  
          in long-term care facilities, particularly with respect to  
          incidents involving persons with developmental or psychiatric  
          disabilities.  First, the bill seeks to require the Department  
          of Public Health (DPH) to complete an investigation and issue  
          any citation within specified time periods, depending on the  
          nature of the violation, and allows for an extension of up to 30  
          days if DPH is unable to complete its investigation due to  
          extenuating circumstances.  In addition, this bill seeks to  
          authorize public notice of survey or licensing reports, or all  
          citations issued by the Department of Social Services (DSS) or  
          DPH, if the information related to a facility with a license  
          capacity of 16 beds or more, and does not include the name or  
          personally identifiable information of any resident or person  
          with a developmental or psychiatric disability.  This bill  
          previously was approved by the Assembly Health Committee by a  
          17-0 vote, and has no known opposition.

           SUMMARY  :  Requires the Department of Public Health to complete  
          an investigation of a complaint against a long-term care  
          facility and issue any citation within a certain timeframe, and  
          allows public access to citation reports and other DSS or DPH  
          records that meet specified confidentiality protections.   








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          Specifically,  this bill  :   

          1)Requires DPH to complete its investigation of a LTC facility  
            and issue a citation, if any, within the following time  
            periods:

             a)   Within 90 days if the violation was likely the direct  
               proximate cause of death of a patient or resident;
             b)   Within 120 days if the violation presented an imminent  
               danger of death or serious harm to a patient or resident,  
               or a substantial probability of death or serious harm to a  
               patient or resident; and,
             c)   Within 180 days if the violation has a direct or  
               immediate relationship to the health, safety, or security  
               of a patient or resident.
             d)   Within an additional 30 days of all these time periods  
               if DPH is unable to complete its investigation due to  
               extenuating circumstances beyond its control, so long as  
               the extenuating circumstances are documented by DPH in its  
               final determination.

          2)Authorizes public notice of the following information, if the  
            information relates to a facility with a license capacity of  
            16 beds or more and does not include the name or personally  
            identifiable information of any patient:

             a)   Survey and licensing reports, and all class "AA," "A,"  
               or "B" violations issued by DPH.
             b)   Facility evaluation, deficiency, and complaint  
               investigation reports issued by DSS.

          3)Provides that confidential information in the possession of  
            DPH and DSS shall not contain the name of a person with a  
            developmental or psychiatric disability or other personally  
            identifiable information.

           EXISTING LAW  :  

          1)Provides for the inspection and licensure of LTC facilities by  
            DPH.  (Health and Safety Code Section 1254.  Unless stated  
            otherwise, all further statutory references are to this code.)

          2)Establishes the Long-term Care, Health, Safety, and Security  
            Act of 1973 (LTC Safety Act), which allows DPH to assess  
            penalties against LTC facilities for violation of state laws  








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            and regulations and applicable federal law and regulations  
            pertaining to patient care.  (Chapter 2.4 of Division 2,  
            commencing with Section 1417.)

          3)Requires DPH upon receipt of a written or oral complaint  
            against a long-term health care facility, to notify the  
            complainant of the name of the assigned inspector within two  
            working days of receipt of the complaint and to make an onsite  
            inspection or investigation of the complaint within ten  
            working days of receipt of the complaint.  If a complaint  
            involves the threat of imminent danger of death or serious  
            bodily harm, DPH is required to make an onsite inspection or  
            investigation of the facility within 24 hours of receipt of  
            the complaint.  (Section 1420(a)(1).)

          4)Requires DPH to notify the complainant and the facility  
            licensee, in writing, of its determinations within 10 days of  
            the completion of the inspection or investigation.  (Section  
            1420(a)(3).)

          5)Requires DPH to notify any complainant who is dissatisfied  
            with DPH's determinations of the right to an informal  
            conference, and provides the complainant five business days to  
            request such a conference.  (Section 1420(b).)

          6)Defines three classifications of citations, as follows:

             a)   Class "AA" violations are violations that meet the  
               criteria for a class "A" violation and that DPH determines  
               to have been a direct proximate cause of death of a patient  
               or resident of a LTC facility.
             b)   Class "A" violations are violations which DPH determines  
               present either (1) imminent danger that death or serious  
               harm to the patients or residents of the LTC facility would  
               result therefrom, or (2) substantial probability that death  
               or serious physical harm to patients or residents of the  
               LTC facility would result therefrom.
             c)   Class "B" violations are violations that the state  
               department determines have a direct or immediate  
               relationship to the health, safety, or security of  
               long-term health care facility patients or residents, other  
               than class "AA" or "A" violations.  (Section 1424.)

           COMMENTS  :  This non-controversial bill, sponsored by Disability  
          Rights California, seeks to improve public access to meaningful  








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          information regarding complaints or health and safety violations  
          in long-term care facilities, particularly with respect to  
          incidents involving persons with developmental or psychiatric  
          disabilities. 

           Background on LTC oversight.   California long-term care  
          facilities are subject to an extensive body of state and federal  
          requirements.  DPH has over 965 Licensing and Certification  
          Division (L&C) field survey staff, an additional 112 L&C  
          headquarters management staff, and over a $55 million  
          fee-supported budget dedicated to monitoring facility compliance  
          with applicable laws, regulations, and policies.  The L&C staff  
          conducts federal recertification surveys, extended annual  
          facility surveys, and detailed complaint investigations to  
          ensure continuous compliance throughout the State.  Of the total  
          L&C division workload, 71% are dedicated to LTC facility  
          oversight.  

           This bill establishes time-certain timelines for investigations  
          to be completed.   DPH issues citations to LTC facilities when a  
          facility's failure to meet state regulations results in actual  
          harm to a resident or jeopardizes a resident's health, safety,  
          or security.  According to the author, on average, a year or  
          more elapses between when an alleged incident occurred and when  
          DPH issues a citation because, problematically, there is no  
          deadline by which DPH must complete complaint investigations and  
          issue citations.  During the interim, however, the deficient  
          facility is not required to take any corrective action to ensure  
          the incident will not recur, thereby endangering other  
          residents.  

          To address this safety issue, this bill would require DPH to  
          complete an investigation and issue a citation within different  
          specified time periods, allowing for an extension of up to 30  
          days if DPH is unable to complete its investigation due to  
          extenuating circumstances.  By imposing a reasonable deadline  
          for completing investigations, this bill furthers the laudable  
          public policy of identifying and correcting problems as soon as  
          possible to protect the safety of all residents.

           This bill balances public right of access to information with  
          the privacy rights of disabled persons.   Existing law provides  
          heightened confidentiality protections for information and  
          records associated with individuals receiving services who have  
          developmental or psychiatric disabilities.  Citation reports do  








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          not include names of residents or staff, typically employing  
          pseudonyms such as "Resident X" or "Staff Y" instead.  However,  
          according to the author, DPH has taken the position that  all   
          information it obtains during the course of a complaint  
          investigation is protected under the law.  Consequently, DPH  
          entirely redacts citations pertaining to people with a  
          developmental or psychiatric disability, including basic  
          information about the nature of the violation and the events  
          preceding or contributing.  This is problematic, however,  
          because many facilities, such as state  developmental centers,  
          state psychiatric hospitals, and intermediate care facilities,  
          serve only people with psychiatric or developmental  
          disabilities.  By completely redacting citations issued to these  
          facilities, contends the author, family members and the public  
          at large are essentially precluded from obtaining meaningful  
          information about a facility's track records of regulatory  
          violations, and have no other means to access information  
          contained in this nominally public record.  
           
          This bill seeks to balance the public right of access with  
          important confidentiality protections that people with  
          disabilities deserve.  First, this bill would expressly  
          authorize public notice of specified DPH and DSS records,  
          including citations, survey licensing reports, complaint  
          investigation reports, and others, as long as personally  
          identifiable information of any patient is redacted, in addition  
          to the individual's name.  The bill also authorizes such public  
          notice only to information relating to a facility with a license  
          capacity of 16 beds or more.  This limitation is intended to  
          ensure the confidentiality of residents in small facilities of  
          less than 16 beds, because simple descriptive characteristics of  
          a person that would not otherwise be identifying may effectively  
          reveal that person's identity in a facility where there are less  
          than 16 residents.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Disability Rights California (sponsor)
          The Evans Law Firm

           Opposition 
           
          None on file








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          Analysis Prepared by  :   Anthony Lew / JUD. / (916) 319-2334