BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 455
                                                                  Page  1

          Date of Hearing:  July 2, 2013

                            ASSEMBLY COMMITTEE ON HEALTH
                                 Richard Pan, Chair
                  SB 455 (Ed Hernandez) - As Amended:  June 25, 2013

           SENATE VOTE  :  Not relevant.
           
          SUBJECT  :  General acute care hospitals: patient classification  
          system.

           SUMMARY  :  Requires a committee for each general acute care  
          hospital to review, at least annually, the reliability of its  
          patient classification system.  Requires at least 50% of the  
          committee members to be registered nurses (RNs) who provide  
          direct patient care, and requires that these RNs be appointed by  
          their bargaining agent, if any.  Specifically,  this bill :  

          1)Requires a committee, currently established through  
            regulation, for each general acute care hospital to review, at  
            least annually, the patient classification system with respect  
            to the reliability of this system for validating staffing  
            requirements to determine whether or not the system accurately  
            measures patient care needs.

          2)Requires at least 50% of the committee members to be RNs who  
            provide direct patient care and appointed by the bargaining  
            agent, if any.  In the absence of a bargaining agent, requires  
            that these RNs be appointed by the nursing administrator.   
            Requires the remaining members of the committee to be  
            appointed by the nursing administrator.

          3)Clarifies that it is the intent of the Legislature to  
            supersede specified subdivisions of the California Code of  
            Regulations, which relate to the committee reviewing the  
            effectiveness of the patient classification system for  
            validating staffing requirements, and not to affect any other  
            provision of law. 

           EXISTING LAW  :  

          1)Licenses and regulates health facilities by the Department of  
            Public Health (DPH).

          2)Requires DPH to adopt regulations that establish minimum,  








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            specific, and numerical licensed nurse-to-patient ratios by  
            licensed nurse classification and by hospital unit for all  
            general acute care hospitals.

          3)Requires DPH to consider flexibility for rural general acute  
            care hospitals in response to their special needs.

          4)Defines "hospital units" as critical care units, burn units,  
            labor and delivery rooms, postanesthesia service areas,  
            emergency departments, operating rooms, pediatric units,  
            step-down/intermediate care units, specialty care units,  
            telemetry units, general medical care units, subacute care  
            units and transitional inpatient care units.

          5)Requires the ratios adopted by regulation pursuant to 2)  
            above, to constitute the minimum number of RNs and licensed  
            nurses (LNs) that must be allocated to a unit.  Requires  
            additional staff to be assigned in accordance with a  
            documented patient classification system for determining  
            nursing care requirements, including the severity of the  
            illness, the need for specialized equipment and technology,  
            the complexity of clinical judgment needed to design,  
            implement, and evaluate the patient care plan and the ability  
            for self-care, and the licensure of the personnel required for  
            care.

           EXISTING REGULATIONS  :

          1)Define "patient classification system," in part, as a method  
            for establishing hospital RN staffing requirements by unit,  
            patient, and shift.

          2)Define "direct patient care" to mean the provision of health  
            care services directly to individuals being treated for, or  
            suspected of having, physical or mental illnesses.  Direct  
            patient care includes preventive care.  The first line  
            supervision of direct patient care are required to also be  
            considered "direct patient care."

          3)Require a hospital's administrator of nursing service to  
            develop a written staffing plan based on patient care needs  
            determined by the patient classification system.

          4)Require the reliability of the patient classification system  
            for validating staffing requirements to be reviewed at least  








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            annually by a committee appointed by the nursing administrator  
            to determine whether or not the system accurately measures  
            patient care needs, and requires at least half of the members  
            of the review committee to be RNs who provide direct patient  
            care.
           
          FISCAL EFFECT  :  This bill, as amended, has not been analyzed by  
          a fiscal committee.

           COMMENTS  :

           1)PURPOSE OF THIS BILL  .  According to the author, by placing the  
            patient classification committee requirement in statute, this  
            bill will help ensure hospitals are complying with the law.   
            Additionally, selecting representatives for workplace  
            committees is a fundamental tenet of collective bargaining.

           2)BACKGROUND  .  According to the California Department of Health  
            Care Services (DHCS), regulations implementing  
            nurse-to-patient ratios in California hospitals pursuant to AB  
            394 (Kuehl), Chapter 945, Statutes of 1999, went into effect  
            on January 1, 2004.  However, before California had specific  
            nurse-to-patient ratios, hospitals were required by regulation  
            to establish a patient classification system.  According to  
            DHCS these regulation became effective on January 1, 1997.   
            This patient classification system is a method by which  
            hospitals establish staffing requirements by unit, patient,  
            and shift, and includes a method by which the amount of  
            nursing care needed for each category of patient is validated  
            for each unit.

            The regulations implementing the AB 394 nurse-to-patient  
            ratios law set the minimum ratio of nurses to patient by unit,  
            including one-to-one in operating rooms, one-to-two in  
            intensive care units, and one-to-five in general  
            medical-surgical units.  These regulations also incorporated  
            the patient classification system requirement.  In essence,  
            the specific nurse-to-patient ratios establish the minimum  
            number of nurses by unit, while the patient classification  
            system determines whether there needs to be a higher level of  
            staffing beyond the minimum ratio after taking into  
            consideration factors such as the severity of the illness, the  
            need for specialized equipment and technology, and the  
            complexity of clinical judgment needed to evaluate the patient  
            care plan, among other factors.  The nurse-to-patient ratio  








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            regulations require that the minimum ratios must be met at all  
            times.

            Finally, the regulations require the reliability of the  
            patient classification system for validating staffing  
            requirements to be reviewed at least annually by a committee  
            appointed by the nursing administrator to determine whether  
            the system accurately measures patient care needs.  At least  
            half of the members of this committee are required to be RNs  
            who provide direct patient care.

           3)SUPPORT  .  The United Nurses Associations of California/Union  
            of Health Care professionals (UNAC/UHP) is the sponsor of this  
            bill and says that many laws incorporate protections that  
            could be subject to collective bargaining.  Examples include  
            the minimum wage, the eight hour day, and indeed nurse ratios  
            in hospitals.  California law provides minimum standards for  
            the minimum wage, the eight hour day, and nurse ratios: these  
            standards were supported by the labor movement.  Appointment  
            of nurses to the patient classification review committee by a  
            collective bargaining agent, if any, should be another such  
            instance.
             
             The American Federation of State, County and Municipal  
            Employees, AFL-CIO (AFSCME) writes that they are the cosponsor  
            of this bill because hospitals need to respect the right of  
            the collective bargaining agent to appoint direct care nurses  
            to the patient classification committee and because of the  
            importance of pending regulations on hospital fines.

           4)OPPOSITION  .  The California Hospital Association writes in  
            opposition to this bill that the hospital has the ultimate  
            responsibility for ensuring quality patient care, including  
            ensuring appropriate staffing levels.  Given this  
            responsibility, it is inappropriate to require the hospital to  
            delegate a major component of its assessment tool to a third  
            party.  Requiring a hospital to delegate this authority is  
            particularly problematic given that the hospital's interests  
            and the union's interests may not always align.  For example,  
            the hospital may want to have particular units or individuals  
            represented on the committee.  On the other hand, the union  
            may appoint individuals based on their own priorities such as  
            leadership development or other factors.  Further, the  
            hospital must maintain the prerogative to appoint staff in  
            good standing who are eligible and qualified to perform the  








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            duties vested in the patient classification committee.  The  
            bargaining unit agent is not a hospital representative and  
            cannot determine performance eligibility requirements.
             
             The California Nurses Association opposes this bill and states  
            that it would undermine existing Title 22 licensing and  
            certification regulations that have been carefully vetted  
            through the Administrative Procedure Act for clarity,  
            authority, reference and necessity, and that have been refined  
            through public comments during the exceptionally long and  
            detailed rulemaking that accompanied AB 394 and should not be  
            replaced by confusing legislative language.  In their zeal for  
            control over the appointment process to the patient  
            classification review committee, a goal that is more  
            appropriately reached through contract negotiation, the  
            sponsors of this legislation weaken staffing protections for  
            RNs in unorganized facilities.
             


           5)PREVIOUS LEGISLATION  .  

             a)   SB 1246 (Ed Hernandez) of 2012, would have required  
               periodic inspections by DPH to include a review of  
               compliance with nurse staffing ratios and patient  
               classification systems, and eliminated a requirement that  
               DPH promulgate regulations further defining the criteria  
               for assessing administrative penalties, thereby allowing  
               existing fine authority to go into effect.  SB 1246 would  
               have also codified patient classification regulations, as  
               does this bill.  SB 1246 was vetoed by Governor Brown.  In  
               his veto message he states, "This bill seeks to grant the  
               Department of Public Health greater authority to enforce  
               hospital nurse staffing ratios and patient classification  
               system requirements.  Everything is already on track to get  
               this job done. The department will soon release proposed  
               regulations on administrative penalties that will apply to  
               a broad range of violations. The rulemaking process should  
               be completed next year."

             b)   AB 394 requires DPH to adopt regulations specifying  
               nurse-to-patient ratios, by unit, for general acute care  
               hospitals, acute psychiatric hospitals, and special  
               hospitals.  Additionally, requires hospitals to adopt  
               written policies and procedures for nursing staff training.  








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                Provides that the ratios are to constitute the minimum  
               number of RNs and LNs that must be provided; requires  
               hospitals to assign additional staff in accordance with a  
               documented patient classification system.
           
          REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          American Federation of State, County and Municipal Employees,  
          AFL-CIO (cosponsor)
            United Nurses Associations of California/Union of Health Care  
          Professionals (cosponsor)
          SEIU California

           Opposition 
           
          Association of California Healthcare Districts
          California Hospital Association
          California Nurses Association 

           Analysis Prepared by  :    Lara Flynn / HEALTH / (916) 319-2097