BILL ANALYSIS                                                                                                                                                                                                    Ó






                                  SENATE HUMAN
                               SERVICES COMMITTEE
                            Senator Carol Liu, Chair


          BILL NO:       SB 909                                       
          S
          AUTHOR:        Pavley                                       
          B
          VERSION:       March 20, 2014                              
          HEARING DATE:  April 8, 2014                                
          9
          FISCAL:        No                                           
          0
                                                                      
          9
          CONSULTANT:    Sara Rogers                                 

                                        

                                    SUBJECT
                                         
                     Dependent children: health screenings

                                     SUMMARY  

          Permits a social worker to authorize an initial medical,  
          dental, and mental health screening of a child taken into  
          temporary custody, prior to a detention hearing, for  
          specified purposes. Additionally, adds mental health care  
          to the list of health care services that may be authorized  
          by the court or a social worker under various situations  
          and adds mental health providers to the list of health  
          professionals who may recommend such care.

                                     ABSTRACT  

           Existing Law:


           1)Establishes the criteria by which a child who has  
            suffered, or is at risk of suffering, significant abuse  
            or harm shall be within the jurisdiction of the juvenile  
            court which may adjudge that person to be a dependent  
            child of the court. (WIC 300)  

                                                         Continued---




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           2)Permits the juvenile court to direct all such orders to  
            the parent, parents, or guardian of a minor who is  
            subject to any juvenile court proceeding as the court  
            deems necessary and proper for the best interests of the  
            minor. Provides that these orders may concern the care,  
            supervision, custody, conduct, maintenance, and support  
            of the minor, including education and medical treatment.  
            (WIC 245.5)


          3)Through case law, provides that proceedings in juvenile  
            court must conform to the constitutional guarantee of due  
            process. (152 Cal. App. 2d 458, 313 P.2d 182)


          4)Permits the court to limit parental control over an  
            adjudged dependent child and requires the court to  
            clearly and specifically set forth those limitations.  
            Provides that such limitations may not exceed those  
            necessary to protect the child. (WIC 361)


          5)Permits the court to make any and all reasonable orders  
            for the care, supervision, custody, conduct, maintenance,  
            and support of an adjudged dependent child, including  
            medical treatment, subject to further order of the court.  
            (WIC 362)


          6)Permits a social worker to authorize the performance of  
            the medical, surgical, dental, or other remedial care for  
            a child in temporary custody upon the recommendation of  
            the attending physician or surgeon. Requires the social  
            worker, before the care is provided, to notify the parent  
            or guardian, and if the parent or guardian objects,  
            provides that care shall be given only upon order of the  
            court. (WIC 369(a))


          7)Permits the court, upon the recommendation of a licensed  
            physician or surgeon, to authorize remedial care or  
            treatment for a child for whom a petition has been filed  
            but there is no parent, guardian or person standing in  





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            loco parentis capable of or willing to authorize the  
            treatment. ((WIC 369 (b))


          8)Permits the court to order that a social worker may  
            authorize the medical, surgical, dental or other remedial  
            care for a dependent child that has been placed by the  
            court under the custody or supervision of a social worker  
            if it appears there is no parent or guardian capable of  
            authorizing or willing to authorize medical, surgical,  
            dental or other remedial care. (WIC 369 (c)) 


          9)Permits a social worker to authorize emergency medical,  
            surgical, or other remedial care, as defined, for a child  
            in temporary custody, a dependent child, or a child for  
            whom a petition has been filed, in an emergency  
            situation. Requires the social worker to make reasonable  
            efforts to obtain the consent of, or to notify, the  
            parent or guardian. (WIC 369 (d))


          10)Permits a minor who is 12 years of age or older to  
            consent to mental health treatment or counseling services  
            if, in the opinion of the attending professional person,  
            the minor is mature enough to participate intelligently  
            in the mental health treatment or counseling services.  
            (HSC 124260) 


           This bill:


           1)Makes various uncodified findings and declarations  
            stating that the state has a compelling interest in  
            ensuring the physical and mental health of children in  
            the child welfare system and referencing American Academy  
            of Pediatrics recommendations for initial health  
            screenings for foster children.  


           2)Permits a social worker to authorize an initial medical,  
            dental, and mental health screening of a child taken into  
            temporary custody, prior to a detention hearing, for the  
            following purposes:





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                     To determine whether the child has an urgent  
                 medical, dental or mental health need that requires  
                 immediate attention.
                     To determine whether the child poses a health  
                 risk to other persons.
                     To determine an appropriate placement to meet  
                 the child's medical and mental health care needs  
                 identified in the initial health screening.


          1)Adds mental health care to the list of health care  
            services that may be authorized by the court or a social  
            worker under various situations pursuant to WIC 369 and  
            adds mental health providers to the health professionals  
            who may recommend such care as follows:


                     Permits a social worker to authorize the  
                 performance of mental health care for a child in  
                 temporary custody upon the recommendation of the  
                 attending mental health provider and following  
                 notification of the parent or guardian, or if  
                 objected to, only upon order of the court.
                     Permits the court, upon the recommendation of a  
                 mental health provider to authorize mental health  
                 care for a child for whom a petition has been filed  
                 but there is no parent, guardian or person standing  
                 in loco parentis capable of or willing to authorize  
                 the treatment.
                     Permits the court to order that a social worker  
                 may authorize mental health care for a dependent  
                 child that has been placed by the court under the  
                 custody or supervision of a social worker if it  
                 appears there is no parent or guardian capable of  
                 authorizing or willing to authorize the care. 
                     Permits a social worker to authorize, in an  
                 emergency situation, as defined, mental health care  
                 for a child in temporary custody, a dependent child,  
                 or a child for whom a petition has been filed.  
                 Requires the social worker to make reasonable  
                 efforts to obtain the consent of, or to notify, the  
                 parent or guardian.






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          1)Replaces the term "person" with "child" throughout the  
            statute.


          2)Provides that this section shall not affect the  
            application of communicable disease prevention and  
            control duties of the California Department of Health  
            Care Services and local public health officers pursuant  
            to HSC 120100.


          3)Defines "mental health provider" to have the same meaning  
            as Business and Professions Code Section 865 which  
            defines this as a physician and surgeon specializing in  
            the practice of psychiatry, a psychologist, a  
            psychological assistant, intern, or trainee, a licensed  
            marriage and family therapist, a registered marriage and  
            family therapist, intern, or trainee, a licensed  
            educational psychologist, a credentialed school  
            psychologist, a licensed clinical social worker, an  
            associate clinical social worker, a licensed professional  
            clinical counselor, a registered clinical counselor,  
            intern, or trainee, or any other person designated as a  
            mental health professional under California law or  
            regulation.


                                  FISCAL IMPACT  

          This bill has not been identified as a fiscal bill, however  
          the Appropriations committee has requested to hear it. 

                            BACKGROUND AND DISCUSSION  

          According to the author, existing law does not provide  
          clear authority for a social worker to provide consent for  
          a health care provider to conduct initial medical, dental  
          and mental health assessments during the 72 hours prior to  
          a detention hearing. The author states that without clear  
          authority for conducting these initial assessments and  
          screenings for newly detained children, many counties have  
          relied on a variety of local rules and blanket orders from  
          the juvenile court to provide authority for the  
          assessments. According to the author, each local rule or  





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          blanket order uses its own criteria for what the screening  
          includes which has resulted in a great deal of  
          inconsistency statewide. The author states that this bill  
          would provide county social workers with clear authority to  
          consent to initial health assessments and screenings for  
          detained children which are needed prior to the initial  
          petition hearings.


          Juvenile Dependency Process - Limitations on Parental  
          Rights


          The juvenile dependency process is designed to strike a  
          balance between the responsibility to provide maximum  
          safety and protection for abused and neglected children and  
          those at risk, while at the same time maintaining a focus  
          on the preservation and due-process rights of the family.  
          In this regard, the court has broad authority to direct  
          "all such orders to the parent, parents, or guardian of a  
          minor who is subject to any proceeding under this chapter  
          as the court deems necessary and proper for the best  
          interests of?the minor. These orders may concern the care,  
          supervision, custody, conduct, maintenance, and support of  
          the minor, including education and medical treatment."  
          Existing law permits a social worker to take a minor into  
          "temporary custody" if it is suspected that a child is  
          being, or is at risk of being, abused or neglected.  
          However, in such cases, abuse has not yet been validated,  
          the child has not yet been adjudged to be a dependent of  
          the court, and parental rights have not been formally  
          limited. The authority for the juvenile dependency system  
          to limit parental authority over children is subject to a  
          series of rigorous and lengthy hearings and extensive court  
          oversight designed to ensure that parental rights are only  
          limited to the extent necessary to protect the child.<1> 


          After taking a minor into custody, existing law requires a  
          social worker to immediately file a petition with the  
          juvenile court, if the social worker has determined that  
          the minor shall be retained in custody, or else to release  
          -------------------------


          <1> WIC 300 et seq.






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          the minor within 48 hours.<2> The law then requires the  
          court to hold a "detention hearing" before the expiration  
          of the next judicial day after such a petition has been  
          filed to determine whether the minor shall continue to be  
          detained.<3> Following the detention hearing, the court is  
          required to hold a "jurisdictional hearing" to determine  
          whether the minor is a person described by WIC Section 300  
          and, if a minor is detained in custody, to hold that  
          hearing within 15 days after the detention hearing.<4>  
          After finding that a minor is a person described by Section  
          300, the court is then required to hold a "disposition  
          hearing" within 60 days after the detention hearing to  
          determine whether the child is a dependent child of the  
          court, to potentially limit parental rights, establish a  
          guardian, determine an appropriate placement, or to order  
          the provision of services to the child or family.<5> 


          Generally, in cases where children are in temporary  
          custody, parental notification of any medical treatment  
          that may be authorized is required since parental rights  
          have not been terminated or limited, or even yet heard by  
          the court. If it is determined by a physician that medical  
          care is needed, but the parent or guardian is unavailable  
          or unwilling to consent to the treatment, a social worker  
          is generally required to seek written consent from the  
          court to provide such care or to receive authorization from  
          the court for the social worker to provide the consent.<6> 


          -------------------------
          <2> WIC 311 and WIC 313


          <3> WIC 315


          <4> WIC 334 and WIC 355


          <5> WIC 360 and WIC 361


          <6> WIC 369






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          Existing law provides no specific permission for social  
          workers to authorize initial medical screens. This bill  
          would permit social workers to authorize an initial medical  
          screening for children who have not had a court hearing  
          without the need to seek any consent from a parent or  
          guardian, and regardless of whether the parent or guardian  
          may object. Under current law, only in cases of emergency  
          where it appears the child requires immediate emergency  
          treatment, is a social worker permitted to provide  
          unilateral consent after making reasonable efforts to  
          obtain consent from the parent or guardian. In this case,  
          "emergency situation" is defined as when:


               [A] child requires immediate treatment for the  
               alleviation of severe pain or an immediate diagnosis  
               and treatment of an unforeseeable medical, surgical,  
               dental, or other remedial condition or contagious  
               diseases which if not immediately diagnosed and  
               treated would lead to serious disability or death. <7>


          Additionally, in numerous instances a minor dependent may  
          themselves consent to medical treatment depending on the  
          type of treatment and the age of the child. For example, a  
          minor who is 12 years of age or older may consent to mental  
          health treatment or counseling services if, in the opinion  
          of the attending professional person, the minor is mature  
          enough to participate intelligently in the mental health  
          treatment or counseling services (HSC 124260). Family Code  
          provides that a minor over the age of 15 living outside a  
          parent's home may consent to medical and dental care and a  
          youth who is 12 years or older may consent to medical,  
          hospital and surgical care related to the diagnosis or  
          treatment of infectious, contagious, communicable and  
          sexually transmitted diseases, as specified. Additionally,  
          a child of any age that has been a victim of a sexual  
          assault may consent to the diagnosis, treatment, collection  
          of medical evidence and care related to the assault  
          following attempts to contact the parent of guardian  
          (unless the perpetrator). 

          -------------------------
          <7> WIC 369 (d)






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          Once a child has been placed by order of the court within  
          the care and custody or under the supervision of a social  
          worker, that social worker may consent to remedial medical  
          care if there is no parent, guardian or person standing in  
          loco parentis capable or willing to authorize the care  
          after due notice. California regulations require a medical  
          examination for children to be conducted following  
          detention. This exam is required to be conducted within 10  
          days of initial placement following detention for high risk  
          children and children 0 to 3 years of age. Medical exams  
          for all other children must occur within the first 30 days  
          of initial placement. 


          Standing or Blanket Court Orders regarding Medical Consent


          In order to facilitate the timely approval of medical  
          consent requests, many courts have established blanket or  
          standing orders permitting social workers to authorize  
          medical treatment for youth in certain circumstances. 


          In Santa Clara County Superior Court, the court has issued  
          a standing order which finds that "children and youth [in  
          out-of-home placement] would benefit from prompt provision  
          of routine medical, mental health, and dental treatment to  
          maintain and enhance their physical and mental health and  
          well-being, and delay in treatment would be detrimental or  
          even life-threatening." The order authorizes the Santa  
          Clara Valley Health and Hospital System and any other  
          licensed health care facility or provider to provide  
          specified services to these children.<8>


          Alameda County Superior Court uses a standard two-page form  
          for child welfare workers or probation officers to request  
          -------------------------


          <8> Santa Clara County Superior Court of California.  
          Standing Order re: Ordinary Medical, Mental Health, and  
          Dental Treatment for Juvenile Justice and Dependent  
          Children and Youth in Temporary Custody and Out of Home  
          Placement. Filed May 3, 2013. 






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          the court grant an order for provision of remedial medical  
          care. Los Angeles County Superior Court had a blanket order  
          regarding medical consent until very recently. Currently,  
          the blanket order has been rescinded and it is not clear if  
          the court intends to issue another.


          Medical literature


          The sponsor, Los Angeles County, cites an article published  
          in the Journal of the American Academy of Pediatrics (AAP)  
          authored by the Committee on Early Childhood, Adoption and  
          Dependent Care, which notes the erratic contact that many  
          children have had with health care providers prior to  
          placement. The article makes a distinction between an  
          initial health screening, which is recommended to occur  
          before or shortly after placement, and a comprehensive  
          medical assessment, which is recommended to occur within  
          one month of placement. The stated purpose of the initial  
          health screen is to identify any immediate medical, urgent  
          mental health or dental needs the child may have and of  
          which the caseworker and foster parents should be aware.<9>


          Additionally, the sponsor cites a manual published by the  
          AAP and authored by the Task Force on Health Care for  
          Children in Foster Care which defines the medical "practice  
          parameters" recommended in the initial screen in further  
          detail including:


                 A review of available medical, developmental and  
               mental health history
                 Review of symptoms
                 Vital signs, height, weight, body mass index
                 If indicated, a physical examination by a physician  
               or nurse practitioner
                 An unclothed external body inspection for signs of  
               acute illness, signs of abuse, or rash suggestive of  
             -----------------------
          <9> Health Care of Young Children in Foster Care. Committee  
          on Early Childhood, Adoption, and Dependent Care.  
          Pediatrics 2002; 109;536






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               contagious or infectious disease, range of motion  
               joint inspection
                 External genitalia inspection
                 Assessment of chronic conditions
                 Developmental and mental health screen for  
               significant delay, major depression, suicidal thoughts  
               or violent behavior


          These recommended practice parameters for an initial  
          medical screen are significantly more intrusive than would  
          be permitted under existing law without parental consent.  
          Although the sponsor states it is not their intent for the  
          AAP screen to guide the medical screen authorized under  
          this bill, this bill provides no alternative clear  
          definition of "medical screen" yet it references the AAP  
          guidelines in the uncodified findings and declarations.


          The AAP manual states that developmental, educational and  
          emotional problems affect more than 80 percent of children  
          and adolescents placed in foster care and that successful  
          permanency planning requires developmental and mental  
          health treatment plans that are comprehensive,  
          well-coordinated and ongoing.  


          Additional Medical Screenings for Abused or Neglected  
          Children


          Protocol for child abuse examinations are delineated under  
          Penal Code 11171 and 13823.5, and have been established in  
          conjunction with the Office of Emergency Services, the  
          California Department of Public Health and the state  
          Department of Justice. Forensic examinations are authorized  
          to be provided to a child who has been placed into  
          protective custody if the child has been detained due to  
          allegations of physical or sexual abuse and the medical  
          providers who are consulting or performing the examination  
          have specialized training in detecting and treating child  
          abuse injuries. The forensic examination must be performed  
          within 72 hours of the time the allegations were made or,  
          if possible, within 72 hours of the detention (WIC 324.5).  
          Federal appellate courts have additionally determined that  





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          such examinations may only be provided with parental or  
          court approval unless there are exigent circumstances  
          requiring an immediate exam.<10>


          In the case of probation youth, county probation officers  
          may authorize medical treatment for a juvenile prior to the  
          detention hearing when either the parent or guardian are  
          unable to be located or do not respond to requests for  
          consent following reasonable efforts.<11> County probation  
          departments are required to provide a routine medical exam  
          to juveniles within the first 96 hours of their detainment,  
          and the specific practice parameters for this medical care  
          are defined in Title 15 CCR Section 1432.


          Use of psychotropic medications 


          Psychotropic medication or psychotropic drugs are defined  
          in statute as "those medications administered for the  
                   purpose of affecting the central nervous system to treat  
          psychiatric disorders or illnesses. These medications  
          include, but are not limited to, anxiolytic agents,  
          antidepressants, mood stabilizers, antipsychotic  
          medications, anti-Parkinson agents, hypnotics, medications  
          for dementia, and psychostimulants."


          California is one of a handful of states that requires  
          court authority to approve the use of psychotropic  
          medications for children in foster care. Welfare and  
          Institutions Code 369.5 provides that only a juvenile court  
          judicial officer shall have authority to make orders to  
          administer psychotropic medications to a child and that  
          such authorization shall be based on a request from a  
          physician. 


          -------------------------
          <10> Los Angeles County Procedural Guide 0600-500.00


          <11> SB 913, Chapter 256, Statutes of 2011






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          As of 2013, according to CDSS child welfare indicators  
          data, the state average for use of psychotropic medications  
          among children in foster care is 12.5%, however there is  
          wide variation among counties, even in counties with  
          relatively similar numbers of children in care. For example  
          20.1% of foster children in San Joaquin County are  
          prescribed psychotropic medication, while in Sacramento  
          County, the number is 13.1%.


          Currently CDSS is engaged in a Quality Improvement Project:  
          Improving the Use of Psychotropic Medication among Children  
          and Youth in Foster Care which is intended to improve  
          oversight and monitoring of psychotropic medication use and  
          to develop data tools to identify "quality concerns"  
          described as overutilization of medication, inappropriate  
          prescribing, gaps of service including insufficient  
          monitoring or not basing decisions on evidence based care.


          Opposition Concerns


          The National Center for Youth Law writes that this bill as  
          currently drafted would give social workers unreviewable  
          authority to agree to any psychiatric interventions for  
          dependent children and youth in temporary custody while  
          under current law, such interventions require consent of  
          the parent or the court. The American Family Rights  
          Association (AFRA) cites similar concerns stating that any  
          emergency need for mental health assessment would be  
          covered under the current 5150 codes and that there would  
          be no other need for a mental health screening during  
          temporary custody.  


          Additionally, AFRA states that this bill would allow a  
          social worker to adjudicate medical, dental and mental  
          health screenings which could violate Federal and State law  
          by allowing controls and treatments of the juvenile during  
          the period of temporary custody and before a judge  
          determines official custody. AFRA writes that "[w]e feel  
          that a judge as a licensed and credentialed professional in  
          jurisprudence should have the opportunity to determine that  
          federal and state laws have been followed. Our position is  





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          that until a judge has had the opportunity of review, the  
          rights of the parents and the rights of the juvenile have  
          to be respected and followed. A social worker, in any or  
          all circumstances will not have this training or experience  
          in American Jurisprudence."


          Staff Comments:


          1.The fundamental question raised by this bill is: Should  
            the state grant county social workers the right to  
            consent to medical screenings of children who have not  
            yet been legally detained by the court? Existing law,  
            both state and federal, reflect a balance between the  
            constitutional rights of families and the potential harm  
            to children. In general the law is clear that short of  
            emergency circumstances, only the parents or the court  
            may authorize medical treatment in temporary custody. The  
            sponsor states that non-invasive medical screens are  
            essential to be performed on children in temporary  
            custody prior to the detention hearing even in cases  
            where the potential health need is not an emergency, and  
            without seeking parental consent. 


            The scope of a medical screen provided for under this  
            bill is undefined. The sponsor offers adding the term  
            "non-invasive" to describe the medical screen which  
            simply means non-penetrating of skin or orifices. A  
            "non-invasive medical screen" could still involve a child  
            being unclothed, and is not well defined with regard to  
            mental health care. Because this bill does not provide  
            parents with the authority to consent or object to such a  
            screen it is potentially a very substantial expansion of  
            a social workers authority to authorize medical care. The  
            sponsor, Los Angeles County, has stated that it does not  
            currently support a more clear delineation of the scope  
            of a medical screen. 


            Should the bill move forward, staff recommends that the  
            author consider directing the California Department of  
            Social Services to provide clear regulatory parameters  
            for the scope of a medical screen for these purposes and  





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            that it should not include an unclothed medical screen  
            for older children absent parental consent, a court order  
            or exigent circumstances. At this time staff recommends  
            amending the bill to add the term "non-invasive" to  
            describe the medical screen. 


          2.Adding mental health to the medical treatment laws for  
            dependent children may be interpreted to expand  
            permission for the authorization of psychotropic  
            medications for children in foster care. Welfare and  
            Institutions Code 369.5 addresses the approval of  
            psychotropic medications for children in out of home  
            placements. Additionally, there are currently numerous  
            federal and state efforts aimed at improving safe and  
            appropriate prescribing and monitoring of psychotropic  
            medication use among children and youth in foster care. 


            Staff recommends amending this bill to clarify that this  
            section shall not permit the authorization of  
            psychotropic medication. 


          The specific recommended amendments are as follows:


          Amendment 1: Page 2 Line 9-13: 


            The Legislature finds and declares all of the following:


            (a) The state has a compelling interest in ensuring the  
            physical and mental health of children in the child  
            welfare system.


            (b) Both the American Academy of Pediatrics and the Child  
            Welfare League of America have found children entering  
            foster care to be in poor health with chronic and acute  
            health, developmental, and psychiatric disorders.


             (c) The American Academy of Pediatrics recommends that  





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            upon entry into foster care every child receive an  
            initial health screening to identify any immediate  
            medical, dental, or mental health care needs.


             (d) The completion of an initial health screening  as  
            recommended by the American Academy of Pediatrics  will  
            improve the health of children entering foster care. 


          Amendment 2: Page 2, line 20:


            (a) Whenever a child is taken into temporary custody  
            under Article 7 (commencing with Section 305), the social  
            worker may authorize a  n   non-invasive  initial medical,  
            dental, and mental health screening of the child, prior  
            to the detention hearing held pursuant to Section 319,  
            for any of the following purposes:


          Amendment 3: Page 5 after line 10:


             (l) "Mental health care" means the provision of mental  
            health services, including
            assessment, treatment, or counseling, on an outpatient  
            basis. This section does not authorize a child to receive  
            psychotropic medication without consent either from the  
            child's parent or guardian or from the court as provided  
            for in section 369.5. Nothing in this section shall be  
            construed as superseding sections 319.1, 357, 369.5, or  
            6550 et seq. regarding authorization for mental health  
            services.  


             (m) Nothing in this section shall be construed to limit  
            or expand the laws pertaining to confidentiality and/or  
            the physician-patient privilege and/or  
            psychotherapist-patient privilege provisions contained in  
            state or federal  law for medical records.


           3. As drafted adding "mental health care" to the provisions  
          of WIC 369 dealing with emergency situations may conflict  





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          with existing law pertaining to Health and Safety Code  
          5150, the Lanterman-Petris-Short Act (LPS), which addresses  
          circumstances where an individual may a danger to self of  
          other and permits the individual to be transported to a  
          designated psychiatric inpatient facility for evaluation  
          and treatment for up to 72-hours against their will. Should  
          the bill move forward, staff recommends the author work  
          with interested stakeholders to address these concerns.


          Prior Legislation:

          SB 913 (Pavley) Chapter 256, Statutes of 2011 permits a  
          chief probation officer to provide consent to medical  
          examinations and non-emergency medical care for youth  
          detained in county juvenile facilities.

          AB 506 (Mitchell) Chapter 153, Statutes of 2013 authorizes  
          a social worker to provide consent for an HIV test to be  
          performed on an infant who is less than 12 months of age  
          when the infant has been taken into temporary custody or  
          has been, or has a petition filed with the court to be,  
          adjudged a dependent child of the court, as specified.


                                    POSITIONS  

          Support:       California State PTA
                         County Welfare Directors Association of  
                    California
                         Glendale City Employees Association
                         National Center for Youth Law
                         Urban Counties Caucus
                         Ventura County Board of Supervisors

          Oppose:        American Civil Liberties Union of California  
                         (unless amended)
          American Family Rights Association
                         The National Center for Youth Law (unless  
                         amended)

                                   -- END --
          







          STAFF ANALYSIS OF SENATE BILL 909 (Pavley)              
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