BILL ANALYSIS Ó
SB 911
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Date of Hearing: June 17, 2014
ASSEMBLY COMMITTEE ON HUMAN SERVICES
Mark Stone, Chair
SB 911 (Block) - As Amended: May 27, 2014
SENATE VOTE : 25-11
SUBJECT : Residential Care Facilities for the Elderly: Training
requirements
SUMMARY : Increases training requirements for licensees and
staff of Residential Care Facilities for the Elderly (RCFE).
Specifically, this bill :
1)Increases the number of hours of instruction for RCFE licensee
certification training from 40 hours to 100 hours, which
includes a doubling of the number of hours of classroom
instruction from 40 to 80 hours, and adds nonpharmacologic,
person-centered approaches to dementia care; resident
admission, retention and assessment procedures; and resident
rights to the list of items covered in the RCFE licensee
certification training program.
2)Increases the initial certification training for
administrators from 40 hours to at least 100 hours and the
continuing education requirement for administrators from 20
hours to at least 60 hours during each two-year certification
period.
3)Increases the number of hours of instruction for RCFE staff
certification training from 10 hours to 40 hours, which
includes a requirement that 24 hours be conducted in a
classroom setting, and adds the use, misuse, and interaction
of drugs commonly used by the elderly, the adverse effects of
psychotropic drugs for use in controlling the behavior of
persons with dementia, and instruction related to the special
needs of persons with Alzheimer's disease and dementia,
including nonpharmacologic person-centered approaches to
dementia care, to staff training requirements.
4)Increases continuing education requirements for RCFE staff
from four hours annually to 20 hours annually.
5)Requires the Department of Social Services (DSS) to develop a
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uniform resident assessment tool to be used by all RCFEs to
help identify resident needs for service and assistance with
activities of daily living, and to develop a mandatory
training program on the utilization of the assessment tool to
be given to administrators and their designated substitutes.
6)Provides that no RCFE licensee, or officer or employee of the
licensee, may discriminate or retaliate against any person on
the basis, or for the reason that, the person dialed or called
911, and provides that any violation of this prohibition shall
result in a civil penalty, as specified.
7)Requires a RCFE that accepts or retains a resident with a
prohibited health condition, as specified, shall ensure that
the resident receives home health or hospice services
sufficient in scope and hours to ensure that the resident
receives medical care as prescribed by the resident's
physician and contained in the resident's service plan. Makes
RCFEs violating this provision subject to a civil penalty, as
specified.
8)Requires a RCFE that accepts or retains a resident with a
restricted health condition, as specified, to ensure that the
resident receives medical care as prescribed by the resident's
physician and contained in the resident's service plan by
appropriately skilled professionals acting within their scope
of practice. Makes RCFEs violating this provision subject to
a civil penalty, as specified.
9)Defines an "appropriately skilled professional" as an
individual who has training and is licensed to perform the
necessary medical procedures prescribed by a physician, which
includes but is not limited to a registered nurse, licensed
vocational nurse, physical therapist, occupational therapist,
or respiratory therapist who may be employed by a home health
agency (HHA), the resident, or a facility, and who are
currently licensed in this state.
10)Requires DSS to develop jointly with the California
Department of Aging requirements for a uniform core of
knowledge for the required initial certification and
continuing education for administrators, and their designated
substitutes, and for recertification of administrators of
RCFEs, as specified. Requires this training to be developed
in consultation with individuals or organizations with
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specific expertise in RCFEs or assisted living services, or by
an outside source with expertise in residential care
facilities for the elderly or assisted living services.
11)States legislative findings that the quality of services
provided to residents of RCFEs is dependent upon the training
and skills of staff and that the current training requirements
for staff of RCFEs are insufficient to meet the range of care
needs of the residents of those facilities.
12)Requires DSS to adopt regulations to require staff members of
residential care facilities for the elderly who assist
residents with personal activities of daily living to receive
appropriate training, as specified.
13)Increases dementia training requirements for RCFE staff from
six hours to 15 hours for initial training and from eight
hours to 12 hours for annual in-service training.
14)Requires staff who assist residents with prescription
medication management in a RCFE with more than 16 persons to
complete 32 hours, instead of 16 hours, of initial training
related to medication management, as specified. For RCFEs
providing care to 15 or fewer persons, requires staff to
complete 16 hours, instead of six hours, of initial training.
15)Adds new training requirements for RCFE staff at facilities
serving residents with postural supports, restricted health
conditions or who receive hospice services to include 15 hours
of training prior to providing direct care to residents on the
care, supervision, and special needs of those residents, and
12 hours annually thereafter of in-service training on the
subject of serving those residents.
16)Delays implementation of the bill until January 1, 2016.
EXISTING LAW
1)Establishes the California RCFE Act, which requires facilities
that provide personal care and supervision, protective
supervision or health related services for persons 60 years of
age or older who voluntarily choose to reside in that facility
to be licensed by the California Department of Social
Services' (DSS) Community Care Licensing Division (CCLD).
(H&S Code 1569 and 1569.1)
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2)Requires RCFE licensee applicants to attend an orientation
given by the department which outlines the applicable rules
and regulations, and the scope and responsibility for
operation of a RCFE. (H&S Code 1569.235)
3)Requires a RCFE administrator to be at least 21 years of age,
have a valid RCFE administrator certificate, as specified, and
hold a high school diploma or pass a general educational
development (GED) test, as specified. (H&S Code 1569.613).
4)Requires RCFE licensee applicants to successfully complete a
certification program approved by DSS, consisting of a minimum
of 40 hours of classroom instruction, as specified, and
passage of a written test. (H&S Code 1569.23)
5)Requires DSS to authorize organizations, as specified, to
provide certificate and continuing education courses for RCFE
administrators. (H&S Code 1596.616(i))
6)Requires RCFE licensees, administrators, facility managers and
staff to undergo a criminal background check and clearance
prior to operation or employment. (H&S Code 1569.17)
7)Requires RCFE administrator certification to consist of 40
hours of classroom instruction, to be renewed every two
years, and makes issuance of the renewal conditional upon the
administrator to submit documentation of completion of 40
hours of continuing education, which shall include eight hours
of training on providing care to residents with dementia, as
specified. (H&S Code 1596.616(f))
8)Requires an RCFE administrator who holds a valid license as a
nursing home administrator, as specified, to comply with
required administrator training requirements, but exempts him
or her from having to take the written administrator test.
(H&S Code 1596.616)
9)Permits a RCFE administrator to designate a "facility
manager;" defined as a person on the premises with the
authority and responsibility necessary to manage and control
the day-to-day operation of a RCFE and supervise residents.
(H&S Code 1596.618)
10)Requires RCFE staff to undergo ten hours of training within
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the first four weeks of employment and four hours annually
thereafter, as specified. (H&S Code 1569.625)
11)Requires RCFE staff to undergo an additional six hours of
training on providing care to residents with dementia within
the first four weeks of employment and eight hours of
in-service training on dementia care annually thereafter.
(H&S Code 1569.626)
12)Requires DSS to provide appropriate training to CCLD
licensing personnel, which includes 40 hours of pre-service
training, as specified, and 36 hours of annual training, as
specified. (H&S Code 1569.652)
FISCAL EFFECT : According to the Senate Appropriations
Committee:
1)Significant one-time costs potentially in excess of $500,000
(General Fund) for DSS to revise regulations and consult with
specified groups to update the uniform core of knowledge for
RCFE administrators and training for direct care staff.
2)No new costs to the Department of Aging to continue existing
efforts of collaboration with the DSS in development of
training curriculum and a resident assessment tool.
3)Significant ongoing increase in training costs to employees
and/or facilities to meet the enhanced initial and continuing
education training requirements imposed.
4)Potential minor non-reimbursable local enforcement costs for
violations of any of the provisions of this bill.
COMMENTS :
Background : It is the intent of the Legislature, in
establishing the RCFE Act, to help provide a system of
residential care to allow older persons be able to voluntarily
live independently in a homelike environment as opposed to being
forced to live in an institutionalized facility, such as a
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nursing home, or having to move between medical and nonmedical
environments. RCFEs, commonly referred to as assisted living
facilities, are licensed retirement residential homes and board
and care homes that accommodate and provide services to meet the
varying, and at times, fluctuating health care needs of
individuals who are 60 years of age and over, and persons under
the age of 60 with compatible needs. Licensed by DSS' Community
Care Licensing Division (CCLD), they can range in size from
residential homes with six or less beds to more formal
residential facilities with 100 beds or more.
There is also no uniform common care model; rather the types of
assistive services can vary widely, which can include differing
levels of personal care and protective supervision, based upon
the needs of the resident.
If a resident needs medical care in his or her residence in
order to maintain an independent lifestyle, incidental medical
services are permitted to be provided by a licensed or otherwise
approved external provider, such as a home healthcare agency
(HHA), which is licensed by the California Department of Public.
Additionally, some RCFEs, upon approval of DSS and after having
met specified orientation and training requirements, may provide
assistive memory care services to individuals with dementia or
Alzheimer's disease.
Existing regulations also lay out the circumstances under which
an individual may be allowed to reside in RCFEs. Specifically,
they include persons:<1>
1)Capable of administering their own medications;
2)Receiving medical care and treatment outside the facility or
who are receiving needed medical care from a visiting nurse;
3)Who because of forgetfulness or physical limitations need only
be reminded or to be assisted to take medication usually
prescribed for self-administration;
4)With problems including, but not limited to, forgetfulness,
wandering, confusion, irritability, and inability to manage
money;
5)With mild temporary emotional disturbance resulting from
---------------------------
<1> Section 87455(b) of Title 22, California Code of
Regulations.
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personal loss or change in living arrangement;
6)Who are temporarily bedridden, as specified; and
7)Who are under 60 years of age whose needs are compatible with
other residents in care, if they require the same amount of
care and supervision as the other residents in the facility.
Regulations also provide specific prohibitions on individuals
who are allowed to reside in a RCFE, which includes whether the
resident has active communicable tuberculosis, requires 24-hour
skilled nursing or intermediate care, has an ongoing behavioral
or mental disorder, or has dementia, unless he or she is
otherwise permitted to be cared for in a RCFE by CCLD.<2>
Growing demand : Over the past thirty years, the demand for
RCFEs has grown substantially. Although RCFEs have been
generally available, they experienced explosive growth in the
1990s, more than doubling the number of beds between 1990 and
2002,<3> and continued to grow 16 percent between 2001 and
2010.<4> Nationwide, states reported 1.2 million beds in
licensed RCFEs in 2010.<5> In 2010, the national Centers for
Disease Control reported that 40% of RCFE residents needed help
with three or more activities of daily living and three-fourths
of residents had at least two of the 10 most common chronic
conditions.<6>
According to DSS, as of June 2, 2014 there are 7,587 licensed
RCFEs in California with a capacity to serve 176,891 residents.
RCFE licensee and administrator requirements : California
---------------------------
<2> Section 87455(c) of Title 22, California Code of
Regulations.
<3> Flores and Newcomer, "Monitoring Quality of Care in
Residential Care for the Elderly: The Information Challenge".
Journal of Aging and Social Policy, 21:225-242, 2009.
<4> SCAN Foundation. "Long Term Care Fundamentals: Residential
Care Facilities for the Elderly." March 2011.
http://thescanfoundation.org/sites/thescanfoundation.org/files/LT
C_Fundamental_7_0.pdf
<5> "Assisted Living and Residential Care in the States in
2010," Mollica, Robert, AARP Public Policy Institute
<6> "Residents Living in Residential Care Facilities: United
States, 2010, Caffrey, Christine, et al., US Centers for
Disease Control, April 2012
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statute differentiates between administrators and facility
licensees, who often are the business owners and may be property
owners and administrators charged with overseeing the quality of
the day-to-day operations and are generally required to be
present at the facility during normal working hours. However,
initial training and certification requirements for licensees
and administrators are similar.
At minimum, in order to be eligible to apply for a RCFE license,
a person must be at least 21 years of age, pass a criminal
background check and have a high school diploma or pass a GED
test. A prospective licensee must then provide evidence that he
or she is of "reputable and responsible character," which
includes providing an employment history and character
references. A prospective licensee must also document that he
or she has sufficient financial resources to maintain the
standard of care required by law and must disclose any prior
role as an administrator or licensee of another community care
facility, including whether any disciplinary action was taken
against him or her.
Regarding training, a licensee and an administrator are both
required to undergo 40 hours of classroom instruction in order
to be certified. This training covers relevant laws and
regulations and core competencies as follows:
1)Laws, regulations, and policies and procedural standards that
impact the operations of residential care facilities for the
elderly;
2)Business operations;
3)Management and supervision of staff;
4)Psychosocial needs of the elderly;
5)Community and support services;
6)Physical needs for elderly persons;
7)Use, misuse, and interaction of medication commonly used by
the elderly;
8)Resident admission, retention, and assessment procedures;
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9)Training focused specifically on serving clients with
dementia; and
10)Cultural competency and sensitivity in issues relating to the
underserved aging lesbian, gay, bisexual, and transgender
community.
Once completed, licensees and administrators must pass a written
exam administered by CCLD, and once they are certified,
licensees and administrators must renew their certification
every two years. However, for administrators, in order to have
their certification renewed, they must have participated in at
least 40 hours of continuing education. The continuing
education hours are required to include at least eight hours of
education on providing dementia care, and no more than half of
the hours of continuing education can be completed through
online courses.
RCFE staff requirements : Licensees employ a wide range of staff
to provide day-to-day support and care for residents of RCFEs.
Although many employ individuals with specific expertise and
certifications, such as Licensed Vocational Nurses and Certified
Nursing Assistants, at minimum staff "who assist residents with
personal activities of daily living" are required to be at least
18 years of age and undergo 10 hours of training within four
weeks of being employed by the RCFE and four hours of training
each year thereafter. The training is somewhat similar to that
required of licensees and administrators, but is limited to
covering the physical limitations and needs of the elderly, the
importance and techniques for personal care services, residents'
rights, policies and procedures regarding medications and the
psychosocial needs of the elderly.
There are also additional training requirements for staff who
work in RCFEs that "provide" dementia care or who assist
residents with managing their medication. Staff who work in a
RCFE that advertises or promotes special care, special
programming, or a special environment for persons with dementia
are required to undergo an additional six hours of training on
providing care to persons with dementia. Staff also must
annually complete eight hours of continuing training on dementia
care. Training for staff who assist residents in the management
and self-administration of medication depends on the size of the
facility in which they work. For facilities with 16 or more
residents, staff must undergo 16 hours of training, and for
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facilities with 15 or fewer residents, staff must complete six
hours of training on medication management. Both training
requirements must be completed within the first two weeks of
employment and conclude with an examination. Four hours of
annual continuing medication management training is required, as
well.
All personnel, including the licensee, administrator and staff,
are required to undergo and receive a criminal background
clearance, and must demonstrate they are of good health, which
means they must be physically and mentally capable of performing
assigned tasks. In order to ensure that all personnel are of
good health, they are required to undergo a health screening not
more than six months prior or seven days after employment or
licensure.<7>
Adequacy and relevance of existing training and certification
requirements : Nearly 25 years have passed since existing RCFE
licensing and certification requirements have been changed. The
last noted change was in AB 1615 (Hannigan), Chapter 848,
Statutes of 1991, which required prospective licensees to
undergo an orientation training prior to commencing the licensee
certification process. Additionally, there are no requirements
that licensees or administrators have a college degree or
professional license, and staff are only required to be 18 years
of age regardless of whether they have a high school diploma.
The staff training requirements pale in comparison to those of
many service related positions that do not provide direct care
to the infirm, elderly or disabled. In its 2013 special report,
"Residential Care in California: Unsafe, Unregulated, and
Unaccountable," California Advocates for Nursing Home Reform
wrote that even a manicurist "must have 400 hours of training
and pass a state exam."
The existing training requirements and methods by which RCFE
personnel access and meet their ongoing training needs is also
antiquated. Currently, RCFE licensees and administrators are
required to undergo 40 hours of training and complete a written
exam. However, as noted by DSS, "currently, no proctoring
protocol exists, resulting in no statewide uniformity on how the
exams are administered. This lack of consistency and guidance
results in errors and can ultimately result in candidates
getting certified who may not meet the minimum
---------------------------
<7> Section 87411(f) of Title 22, California Code of
Regulations.
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qualifications."<8>
Staff comments : This measure is part of a package of
legislative measures that seek to establish the RCFE Reform Act
of 2014. In response to a number of recent unfortunate
incidences at RCFEs throughout the state; due to neglect, lack
of oversight, and intentional acts of negligence, legislative
efforts are being pursue to increase the frequency of licensing
inspections, increase licensing fees and civil penalties,
require RCFEs carry liability insurance and increase training
requirement for licensee, administrators and staff. However,
this measure is in conflict with AB 1570 (Chesbro), which, like
this bill, proposes to increase training requirements for
licensees and staff, and dementia care. In order to avoid this
conflict and to address increased training requirement for RCFE
administrators, a compromise proposal has been agreed to by the
authors of this bill and AB 1570 and the Senate and Assembly
Human Services Committees.
AB 1570 will continue to address increased licensee, staff and
dementia care training requirements, but will be amended to
resolve the policy differences in these training requirements
between the two bills. Conversely, this bill will be amended to
include increased administrator training requirements, which
neither bill currently addresses. RCFE administrators are an
integral component of any RCFE management structure and are
essential to a facility's ability to operate. Their omission
from current legislative efforts to increase training
requirements for all RCFE personnel would be a significant
oversight. this bill will also retain provisions relating to
health care services assurances, increased postural support and
medication management training requirements.
Through these amendments, the two bills will become mutually
beneficial of each other; companion measure that provides for a
holistic and comprehensive reform of RCFE training requirements.
Lastly, it has been agreed that amendments would be made to this
bill in the Assembly Human Services Committee and amendments
would be made to AB 1570 in the Senate Human Services Committee.
---------------------------
<8> 2014-15 Budget Change Proposal #CCLD-2; Department of Social
Services; Social Services and Licensing. 2014-15 Budget. Page
12.
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RECOMMENDED AMENDMENTS
Amendment #1
In order to align this bill with AB 1570 so that they do not
conflict with each other, committee staff recommends that this
bill be amended to delete Sections 1 and 2 and Sections 7
through 10 of the bill. It should also be amended to include
correlating training requirements for RCFE administrators and to
modify the current training requirements in the bill to align
with the intent of both bills.
Specifically, committee staff recommends the following
amendments:
1. Delete Sections one and two and Sections seven through
ten of the bill.
2. Amend Section 1569.616 of the Health and Safety Code to
increase training requirements for RCFE administrators.
Amendment #2
Section four of the bill proposes to require RCFEs to ensure
that residents receive home health or hospice services for the
purpose of receiving medical care as prescribed by their
physician. This is laudable, however, it is beyond the scope of
responsibility for a RCFE to assure that a resident is receiving
medical services by a licensed health care provider. Rather,
RCFEs should be required to assist residents with accessing
health care services that are being provided by an agency or
provider, such as a home health agency that is not associated or
affiliated with the RCFE. Requiring RCFEs to ensure the receipt
of health care services from an unaffiliated health care
provider would place RCFEs in the position of having to
understand and possible provide medical care to a resident under
this requirement, which is beyond their statutory authority.
Specifically, committee staff recommends deleting "ensure that
residents receive" on page eight of the bill and replace with
" assist residents with accessing ".
Amendment #3
Section 12 of the bill proposes to double the number of hours of
training for personnel who are responsible for the medication
management in a RCFE. This is a substantial increase, which
would be difficult to implement, especially for smaller bed
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facilities. In order to reflect the intent of the author and
sponsor, but also the practical impact of the requirement,
committee staff recommends reducing the proposed increases in
the following ways:
1)For RCFEs with 16 or more residents, 24 hours of initial
training, which shall include 16 hours of hands-on shadowing
training and eight hours of other training, as specified.
2)For RCFEs with 15 or fewer residents, ten hours of initial
training, which shall include six hours of hands-on shadowing
training and four hours of other training, as specified.
Amendment #4
Section 13 of the bill requires RCFE staff to undergo postural
support training if the facility is serving residents with
postural supports, who have restricted health conditions or
health services, or are receiving hospice services. When taken
in totality with all the other RCFE measures increasing training
and other requirements, this would likely pose a significant
burden on RCFEs to comply, especially smaller facilities. DSS
has noted that as proposed, this would make it difficult for
them to enforce this requirement as they would not know whether
a RCFE has residents that would trigger this requirement unless
they were conducting an onsite inspection. In order to ensure
that this provision is properly enforced, DSS has recommended an
amendment to allow information regarding residents with these
specified conditions be shared at its request in order to
enforce these additional training requirements.
Specifically, committee staff recommends reducing the number of
hours required for postural support training from 15 hours to
four hours of initial training and from 12 hours of ongoing
training to two-hour trainings every six months.
Staff also recommends deleting references to sections of Title
22 of the California Code of Regulations, as they are
unnecessary, and recommends adding language on page 27, line 24
after (c) to read:
At the request of the department, and immediately if the
request is made during an inspection, licensees are
required to provide the department with a confidential list
of residents and their conditions specified in subdivision
(a), to be kept confidential to the extent permitted by
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law. This list shall be maintained in an accurate and
current status at all times.
(d)
DOUBLE REFERRAL . This bill has been double-referred. Should
this bill pass out of this committee, it will be referred to the
Assembly Committee on Aging and Long-Term Care.
2013-14 RELATED LEGISLATION:
SB 895 (Corbett) Would require CDSS to conduct annual
unannounced comprehensive inspections for all facilities,
requires CDSS to verify compliance following deficiencies within
10 days, and requires results of inspections to be available on
the CDSS website.
SB 1153 (Leno) Would permit CDSS to order a suspension of new
admissions for an RCFE when the facility has violated applicable
laws and regulations that present a direct risk to the health
and safety or residents, is not providing adequate care and
supervision, has been cited for subsequent violations of the
same law within 12 months, or has failed to pay existing fines.
SB 911 (Block) Would increase certification training
requirements for RCFE licensees, and staff who care for
residents, increases training requirements for staff providing
dementia care.
SB 1382 (Block) Would increase the annual licensure fees by 30%
and make related findings and declarations.
AB 1571 (Eggman) Would increase disclosure requirements for RCFE
licensee applicants and require applicant information to be
cross-referenced with the State Department of Public Health.
Would require, by 2015, CDSS to create an online inquiry system
posting detailed information about RCFE facilities including
complaints, deficiencies and enforcement actions resulting in
fines. In subsequent years, would require CDSS to post
additional information, as specified.
AB 1572 (Eggman) Would require RCFEs, at the request of two or
more residents, to assist the residents in establishing and
maintaining a single resident council, as specified, and would
require the facility to interact with the council in specified
ways.
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AB 1523 (Atkins and Weber) Would require RCFEs to maintain
liability insurance covering injury to residents and guests in
the amount of $1 million per occurrence and $3 million annually.
AB 1436 (Waldron) Would require the results of all reports of
inspections, evaluations or consultations and lists of
deficiencies to be posted on the department's Internet Web site.
AB 1454 (Calderon) Would require all licensed community care
facilities, RCFEs, and child day care centers to be subject to
an annual unannounced visits visit by CDSS.
AB 1570 (Chesbro) Would increase the certification training
requirements for RCFE administrators, training requirements for
RCFE staff that care for residents, and training requirements
for staff providing dementia care.
AB 1554 (Skinner) Would make various changes to existing RCFE
complaint procedures including requiring the department to make
an onsite inspection within 24 hours of a complaint alleging
abuse, neglect or a threat of imminent danger. Additionally
would require the department to complete its investigation
within 90 days of receiving a complaint. Would permit a
complainant to file an appeal of departmental findings.
AB 1899 (Brown) Would make a person whose license is revoked or
forfeited for abandonment of the facility ineligible for
reinstatement of the license for a period of 10 years following
the revocation or forfeiture. Additionally would require CDSS
to establish and maintain a telephone hotline and an Internet
Web site dedicated to receiving complaints.
AB 2171 (Wieckowski) Would establish specified RCFE resident's
rights and require facilities to inform residents of these
rights as specified.
AB 2044 (Rodriguez) Would require every licensed residential
care facility to be subject to an annual unannounced visit by
the department, as specified. Additionally, would require
complaints to be inspected within three days if the complaint
involves alleged abuse or serious neglect, or within 10 days for
all other complaints and would require investigations to be
completed within 30 days. Would provide a complainant with the
right to request an informal conference and subsequent appeal,
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as specified. Also would require certain staff to be present in
the facility for specified times.
REGISTERED SUPPORT / OPPOSITION :
Support
AARP
Alliance on Aging of Monterey County
Assisted Living Consumer Alliance
California Advocates for Nursing Home Reform (CANHR)
California Association of Public Authorities for (IHSS (CAPA)
California Continuing Care Residents Association CALCRA)
California Long-term Care Ombudsman Association (CLTCOA)
California Senior Legislature CSL)
Consumer Attorneys of California
Consumer Federation of California
Contra Costa Advisory Council on Aging (CCACOA)
County of San Diego
Elder Law & Advocacy
Hazel's Army
Long Term Care Services of Ventura County, Inc.
Long Term Care Ombudsman Services of San Luis Obispo County
National Association of Social Workers, CA Chapter (NASW-CA)
National Consumer Voice
Office of the State Long-Term Care Ombudsman
Ombudsman Services of Contra Costa
Stand Up For Rosie
Stanislaus County Commission on Aging
Stanislaus Long Term Care Ombudsman Program
UCSF, Dept. of Community Health Systems
Valentine La Group, Inc.
Opposition
Angel Care Community Services, Inc.
California Assisted Living Association (CALA)
California Right to Life Committee, Inc.
Analysis Prepared by : Chris Reefe / HUM. S. / (916) 319-2089