BILL ANALYSIS                                                                                                                                                                                                    �



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        SENATE THIRD READING
        SB 534 (Ed Hernandez)
        As Amended September 4, 2013
        Majority vote

         SENATE VOTE  :Vote not relevant  
         
         HEALTH              17-0                                        
         
         -------------------------------- 
        |Ayes:|Pan, Logue, Ammiano,      |
        |     |Atkins, Bonilla, Bonta,   |
        |     |Gomez,                    |
        |     |Roger Hern�ndez,          |
        |     |Lowenthal, Maienschein,   |
        |     |Mitchell, Nazarian,       |
        |     |Nestande, V. Manuel       |
        |     |P�rez, Wagner,            |
        |     |Wieckowski, Wilk          |
        |     |                          |
         -------------------------------- 
         SUMMARY  :  Requires, until the California Departments of Public  
        Health (DPH) and Developmental Services (DDS) adopt regulations for  
        licensure for Intermediate Care Facilities for the Developmentally  
        Disabled - Nursing (ICF/DD-N), these facilities comply with  
        applicable federal certification standards.  Requires chronic  
        dialysis clinics, surgical clinics, and rehabilitation clinics to  
        comply with federal certification standards until DPH has adopted  
        regulations for those facilities.  Creates a specific exemption to  
        current law, which requires congregate living health facilities  
        (CLHFs) to be freestanding, that allows for multiple CLHFs to exist  
        in one multifloor building if certain requirements are met.   
        Specifically,  this bill  :  

        1)Requires, until DPH adopts regulations relating to the provision  
          of services by a chronic dialysis clinic, a surgical clinic, or  
          rehabilitation clinic, the following facilities licensed or  
          seeking licensure to comply with the following federal  
          certification standards in effect immediately preceding January 1,  
          2013:

           a)   Requires a chronic dialysis clinic to comply with applicable  
             federal certification standards for an end stage renal disease  
             clinic;








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           b)   Requires a surgical clinic to comply with applicable federal  
             certification standards for an ambulatory surgical clinic  
             (ASC); and,

           c)   Requires a rehabilitation clinic to comply with applicable  
             federal certification standards for a comprehensive outpatient  
             rehabilitation facility.

        1)Requires until the DPH and DDS adopt regulations pursuant to  
          existing law, relating to services by ICF/DD-N, licensed  
          facilities to comply with applicable federal certification  
          standards in effect immediately preceding January 1, 2013.

        2)Creates a specific exemption to current law, which requires CLHFs  
          to be freestanding, that allows for multiple CLHFs to exist in one  
          multifloor building if all of the following requirements are met:

           a)   Each facility meets other applicable building standards not  
             related to multiple floors;

           b)   Each facility is separated by a wall, floor, or other  
             permanent partition but may share an elevator, stairs, or  
             stairwell, and need not be freestanding;

           c)   The proposal to develop proximate CLHFs is supported by the  
             county health department and the board of supervisors in the  
             county in which the facilities are proposed for one of the  
             following locations:

             i)     McClellan Air Force Base Building No. 522, located at  
               3201 James Way, McClellan, California;

             ii)    McClellan Air Force Base Building No. 523, located at  
               3207 James Way, McClellan, California;

             iii)   McClellan Air Force Base Building No. 524, located at  
               5621 Dudley Blvd, McClellan California; and,

             iv)    McClellan Air Force Base Building No. 525, located at  
               5327 Dudley Blvd, McClellan, California.

        4)Adds finding and declarations that this is a special law and is  
          necessary and a general law cannot be made applicable within the  








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          meaning of the California Constitution because of the unique  
          circumstances relating to the need for CLHFs in and around  
          Sacramento County.

         FISCAL EFFECT  :  According to the Assembly Appropriations Committee,  
        one-time costs for analysis of standards, development of  
        recommendations, report to the Legislature, and a public hearing in  
        the range of $200,000 (Licensing and Certification Fund).   
        Currently, DPH has the authority to cite facilities under federal  
        law.  If the authority to cite facilities under state law is used  
        instead, revenue may accrue to the State Facilities Citation Penalty  
        Account instead of the Federal Facilities Citation Penalty Account.   
        These are both special fund accounts that are used for purposes of  
        the DPH Licensing and Certification program and related activities.   
        The State account is available for funding of long-term care  
        ombudsman programs and for quality improvement activities, while the  
        Federal account is used for temporary management costs of facilities  
        whose certification or licensure is revoked.  It should be noted  
        that the September 4th amendments were not included in the fiscal  
        analysis.  

         COMMENTS  :  According to the author, this bill would require four  
        health facility categories currently regulated by DPH to comply with  
        facility-specific federal certification requirements to meet state  
        licensing requirements until DPH adopts state regulations.  These  
        facilities are already required to meet federal requirements in  
        order to receive Medicare and Medicaid funding; this bill gives  
        authority to state regulators to enforce these standards until such  
        time that DPH adopts regulations specific to these facilities.   
        According to the author, McClellan Business Park wishes to establish  
        CLHFs within the former McClellan Air Force Base in North Highlands  
        in Sacramento County.  The health care facilities would be housed  
        initially in two three-story buildings that were formerly used to  
        house military personnel.  There are two more buildings in close  
        proximity that could be used for CLHFs at a later date.  Each floor  
        would be separately licensed, there would be no co-mingling of  
        patients between floors, and all facilities would provide a  
        home-like environment for residents.  However, current law requires  
        CLHFs to be "freestanding."  According to the author McClellan  
        Business Park believes that it can comply with all CLHF requirements  
        except for the requirement to be "freestanding" as interpreted by  
        DPH and this legislation is needed to grant such authority in this  
        very limited situation. This bill only grants the authority for the  
        four specific buildings described by their addresses.   








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        According to DPH, as of April 2, 2013, there are 173 designated  
        health care facilities that have been issued a state license.  This  
        includes 98 chronic dialysis clinics, 57 ICF/DD-N's, 16 surgical  
        clinics, and two rehabilitation clinics.  Among these four facility  
        types, 166 facilities (96%) had an active license while the rest,  
        seven (4%) did not.  To date, DPH has not adopted state regulations  
        for these facilities, but relies on the federal certification  
        standards to determine licensure.  DPH is currently in the process  
        of drafting regulations for the ICF/DD facilities, however, the  
        Assembly Health Committee staff is not aware of any regulations in  
        process for the surgical clinics, chronic dialysis clinics, and  
        rehabilitation clinics.
         
         With regard to CLHFs, California Health and Safety Code (Section  
        1267.15) states that CLHFs shall be freestanding, but this does not  
        preclude their location on the premises of a hospital.  Congregate  
        living health facilities shall be separately licensed.  According to  
        DPH, because neither code nor regulation defines "freestanding" DPH  
        defers to the common dictionary definition of freestanding which is  
        "standing alone, on its own foundation, free of support or  
        attachment."

        The federal regulatory standards for chronic dialysis clinics  
        (referred to as End Stage Renal Centers in federal regulations),  
        surgical clinics (referred to as ASC in federal regulations), and  
        rehabilitation clinics, among other things, set forth the various  
        standards required at each facility in order to qualify for Medicare  
        and Medicaid participation by the Centers for Medicare and Medicaid  
        Services (CMS).  Depending on the facility in question, the  
        regulations set requirements for the facilities management and  
        governing body, what services may be offered and safety and  
        cleanliness standards.  Standards also include, but are not limited  
        to, requirements covering patient rights, the administration of  
        anesthesia, if applicable, medical records, privacy, and infection  
        control.  

        DPH, in support of the prior version of this bill, states that this  
        bill will enable it to adopt existing federal regulatory standards  
        as the state licensing standards for chronic dialysis clinics,  
        rehabilitation clinics, surgical clinics, and ICF/DD-Ns.  DPH states  
        that it does not have state licensing standards in place for chronic  
        dialysis clinics, rehabilitation clinics, surgical clinics, and  
        ICF/DD-Ns.  Federal standards for these facilities exist, but DPH  








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        lacks the statutory authority to enforce the standards.  In the  
        absence of such authority, DPH states that it may only recommend  
        action by CMS to stop Medicare and Medicaid program funding if the  
        health care facility is out of compliance.  
           
         McClellan Business Park supports the recent amendment which would  
        help to establish CLHFs within the former McClellan Air Force Base  
        in North Highlands (Sacramento County), stating, current law  
        requires CLHFs to be "freestanding" but does not define whether this  
        means having separate foundations or, as is used more commonly,  
        independently standing relative to a hospital.  By defining the term  
        "freestanding" for McClellan Business Park only, this bill will help  
        DPH to determine whether this project should go forward based on its  
        merits.  The Sacramento County Public Health Officer, Olivia  
        Kasirye, MD, MS, writes in support of this bill that with the  
        implementation of the Patient Protection and Affordable Care Act and  
        changes to requirements for hospitals to take measures to prevent  
        readmission of patients, the CLHFs will provide much needed services  
        for those patients that still require skilled nursing care, while at  
        the same time help free up hospital beds and prevent readmissions.  

         Analysis Prepared by  :    Lara Flynn / HEALTH / (916) 319-2097 
                                                                  FN: 0002752