BILL ANALYSIS Ó
AB 2467
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Date of Hearing: April 19, 2016
ASSEMBLY COMMITTEE ON HEALTH
Jim Wood, Chair
AB 2467
(Gomez) - As Amended April 5, 2016
SUBJECT: Health facilities: executive compensation.
SUMMARY: Establishes the Hospital Executive Compensation
Transparency Act of 2016 which requires covered hospitals or
medical entities, as defined, to submit an annual hospital
executive compensation report to the Office of Statewide Health
Planning and Development (OSHPD) which provides specified
information regarding executives earning over $250,000 per year;
and, for covered hospitals or medical entities with 100 or more
employees, requires the report to also include information
regarding the pay bands of various employee classifications, as
well as voluntarily self-reported information regarding
employees' gender, ethnicity, race, sexual orientation, and
gender identity, by job categories. Specifically, this bill:
1)Requires, on and after October 1, 2017, each covered hospital
or medical entity to submit an annual hospital executive
compensation report (annual report) to OSHPD for every
hospital executive whose total annual compensation met or
exceeded the executive compensation reporting threshold
(EXCRT).
2)Requires the annual report to include all of the following
information for the prior fiscal year:
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a) The names, positions, or titles of each hospital
executive and the aggregate total annual compensation for
each hospital executive at or exceeding the EXCRT, with a
description of each entity that has contributed to the
total annual compensation of each hospital executive, in
any form, and the amount of such compensation;
b) A detailed breakdown of all wage and nonwage
compensation;
c) Identification of any benefit or remuneration excluded
from the definition of total annual compensation; and,
d) A detailed breakdown of board compensation, which shall
include all of the following:
i) The name of the publicly traded company, privately
held company, or nonprofit organization that provided the
board compensation; and,
ii) The number of hours the hospital executive spent on
matters related to their duties as a director of the
publicly traded company, privately held company, or
nonprofit organization for which the board compensation
was received.
3)Requires, consistent with the federal annual equal employment
opportunity and compensation report on employees' ethnicity,
race, and sex by job category and compensation, on or after
October 1, 2017, and annually thereafter each covered hospital
or medical entity with 100 or more employees to submit to
OSHPD all of the following information for the prior fiscal
year:
a) The number of employees earning annual total
compensation in 12 pay bands, as proposed by the federal
Equal Employment Opportunity Commission (EEOC) in the
Federal Register, Volume 81 Number 20, on February 1, 2016,
on pages 5113 to 5121, inclusive, for each of the eight
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employee classifications defined in OSHPD's hospital annual
financial data and by self-reported gender, ethnicity, and
race, and voluntarily self-reported sexual orientation and
gender identity; and,
b) The total number of hours worked by the employees
included in each pay band.
4)Requires OSHPD, on and after January 1, 2018, to post the
annual hospital executive compensation report for each covered
hospital or medical entity on OSHPD's Internet Website.
Requires the report to be submitted on the form or in the
format required by OSHPD.
5)Requires the board of directors (BOD) of any nonprofit or
for-profit corporation that owns, operates, or controls, in
whole or in part, a covered hospital or medical entity to
approve the annual report before it is submitted to OSHPD, and
requires each director to act in good faith and with
reasonable care and inquiry in approving the annual report and
in ensuring the corporation complies with the requirements of
this bill.
6)Requires the annual report for each covered hospital or
medical entity governed, owned, or controlled by a BOD, to
state that it was approved by the BOD, the date it was
approved, and contain an attestation under penalty of perjury
by an authorized representative of the covered hospital or
medical entity BOD, as specified.
7)Specifies that any scheme or artifice that has the purpose of
avoiding the reporting requirements of this bill is a
violation of this bill.
8)Specifies that payments, compensation, or remuneration by a
separate entity that is purported not to be for work performed
or services provided at or for a covered hospital or medical
entity, but that is disproportionate to its purported purpose
so as to evade the annual hospital executive compensation
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reporting requirements is a violation of this bill.
9)Requires OSHPD to establish and assess reasonable fees, to be
submitted with each annual report to cover only the reasonable
costs of implementing and ensuring compliance with this bill.
10)Defines board compensation as the total annual compensation
provided to each hospital executive by any publicly traded
company, privately held company, or nonprofit organization on
whose BOD hospital executive sits and from which the hospital
executive received total annual compensation of more than one
thousand dollars ($1,000).
11)Defines covered hospital or medical entity as any of the
following:
a) A private nonprofit general acute care hospital;
b) An acute psychiatric hospital;
c) Any private for-profit general acute care hospital;
d) A hospital group, or any person, corporation,
partnership, limited liability company, trust, or other
entity that owns, operates or controls, in whole or in
part, any such group;
e) A hospital-affiliated medical foundation that is
directly or indirectly, including through one or more
intermediaries, controlled or owned by, or controlled or
owned by the same person or entity as, a hospital, hospital
group, hospital-affiliated physicians group, or nonprofit
corporation that owned, operates, or controls, in whole or
in part, a hospital, hospital group, or hospital-affiliated
physicians group. Specifies that a medical foundation will
be deemed a hospital-affiliated medical foundation if
either or both of the following are true:
i) The medical foundation is a disregarded entity of,
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or would be required to be designated as a related
organization on the Internal Revenue Service (IRS) form
900 (or its accompanying schedules or the successor of
such forms or schedule) of, a hospital, hospital group,
hospital-affiliated physicians group, or a nonprofit
corporation that owns, operates, or controls, in whole or
in part, a hospital, hospital group, or
hospital-affiliated physicians group; and/or;
ii) A majority of the medical foundation's assets are
owned by a hospital, hospital group, or
hospital-affiliated physicians group or by a nonprofit
corporation that owns, operates, or controls, in whole or
in part, a hospital, hospital group, or
hospital-affiliated physicians group or of a nonprofit
corporation that owns, operates, or controls, in whole or
in part, a hospital, hospital group, or
hospital-affiliated physicians group;
f) A hospital-affiliated physicians group, is any
physicians group or medical group that is directly or
indirectly, including through one or more intermediaries,
controlled or owned by, or controlled or owned by the same
person or entity as, a hospital, hospital group,
hospital-affiliated medical foundation, or a nonprofit
corporation that owns, operates, or controls, in whole or
in part, a hospital, hospital group, or hospital-affiliated
medical foundation. A physicians group shall be deemed a
hospital-affiliated physicians group if either or both of
the following are true:
i) The physicians group is a disregarded entity of, or
would be required to be designated as a related
organization on IRS form 990 (or its accompanying
schedules or the successor of such forms or schedules)
of, a hospital, hospital group, or hospital-affiliated
medical foundation or a nonprofit corporation that owns,
operates, or controls, in whole or in part, a hospital,
hospital group, or hospital-affiliated medical
foundation; and/or,
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ii) A majority of the physicians group's assets are
owned by a hospital, hospital group, or
hospital-affiliated medical foundation or a nonprofit
corporation that owns, operates, or controls, in whole or
in part, a hospital, hospital group, or
hospital-affiliated medical foundation.
g) A health care district.
12)Exempts the following from the definition of a covered
hospital or medical entity:
a) Hospitals operated or licensed by the United States
Department of Veterans Affairs or public hospitals, with
the exception of hospitals owned or operated by a health
care district; and,
b) Designated public hospitals, as defined.
13)Specifies that EXCRT means the total annual compensation from
any source for work performed or services provided at or for
the covered hospital or medical entity that is greater than
two hundred fifty thousand dollars ($250,000) in a year.
14)Specifies that hospital executive means all persons whose
primary duties are executive, managerial, or administrative at
or for the covered hospital or medical entity, even if that
person also performs or performed other duties.
15)Specifies that hospital executive includes, but is not
limited to, chief executive officers, chief executive
managers, chief executives, executive officers, executive
directors, chief financial officers, presidents, executive
presidents, vice presidents, executive vice presidents, and
other comparable positions.
16)Specifies that the definition of hospital executive applies
irrespective of whether the person exercising executive,
managerial, or administrative authority is or was an employee
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of a covered hospital or medical entity or a nonprofit
corporation that owns, operates, or controls, in whole or in
part, a covered hospital or medical entity. The definition
shall also apply to any person who exercises or exercised such
authority even if the arrangements for such authority or for
compensation or both are pursuant to a contract or
subcontract.
17)Specifies that the definition of hospital executive includes
any person who held the duties described in these provisions
during the period covered by the annual report, even if the
person is postemployment or post-service.
18)Specifies that the definition of a hospital executive does
not apply to medical or health care professionals whose
primary duties are or were the provision of medical services,
research, direct patient care, or other non-managerial,
nonexecutive, and non-administrative services.
19)Specifies that total annual compensation means all
remuneration paid, earned, or accrued in the course of a
fiscal year for work performed or services provided, including
the cash value of all remuneration (including benefits) in any
medium other than cash, and including, but not limited to, all
of the following:
a) Wages; salary; paid time off; bonuses; incentive
payments; lump-sum cash payments; the fair market value of
below-market-rate loans or loan forgiveness; housing
payments; payments for transportation, travel, meals, or
other expenses in excess of actual documented expenses
incurred in the performance of duties; payments or
reimbursement for entertainment or social club memberships;
the cash value of housing, automobiles, parking, or similar
benefits; scholarships or fellowships; the cash value of
dependent care or adoption assistance or personal legal or
financial services; the cash value of stock options or
awards; payments or contributions for insurance, except as
exempted in 20) below, to a Section 125 cafeteria plan or
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equivalent arrangement, to a health savings account, or for
severance or its equivalent; and deferred compensation
earned or accrued, even if not yet vested nor paid;
b) The total value in the aggregate of the compensation or
payments authorized or paid under a severance or similar
post-service or post-employment arrangement, to include the
fair market value of all cash remuneration as well as the
fair market value of all remuneration (including benefits)
paid in any medium other than cash;
c) Payments, compensation, or remuneration for work
performed or services provided at or for a covered hospital
or medical entity even if made by a separate person or
entity, including, but not limited to, any of the
following:
i) A for-profit or unincorporated entity;
ii) A corporation, partnership, or limited liability
company;
iii) A trust or other entity that is controlled by the
same person or persons who govern a covered hospital or
medical entity;
iv) A supporting or supported organization within the
meaning of Sections 509(a)(3) and 509(f)(3) of the
Internal Revenue Code; or,
v) A disregarded entity of, or related organization as
set forth within, the IRS form 990 of a covered hospital
or medical entity or a nonprofit corporation that owns,
operates, or controls, in whole or in part, a covered
hospital or medical entity.
d) Payment of compensation or remuneration by any person,
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corporation, partnership, limited liability company, trust,
or other entity that a covered hospital or medical entity,
or a nonprofit corporation that owns, operates, or
controls, in whole or in part, a covered hospital or
medical entity, participates in, belongs to, is a member
of, or pays into shall be presumed compensation for work
performed or services provided at or for the covered
hospital or medical entity.
20)Specifies that total annual compensation does not include the
cost of health insurance or disability insurance or payments
or contributions to a health reimbursement account.
EXISTING FEDERAL LAW:
1)Requires non-profit organizations with gross receipts of
$200,000 or more or total assets of $500,000 or more to file
financial information, including regarding salaries, with the
IRS. The IRS form 990, officially, the "Return of
Organization Exempt from Income Tax" is an IRS form that
provides the public with financial information about a
nonprofit organization. It is often the only source of such
information. It is also used by government agencies to prevent
organizations from abusing their tax-exempt status. Certain
nonprofits have more comprehensive reporting requirements,
such as hospitals and other health care organizations.
2)Requires publicly traded companies to file reports with the
Securities and Exchange Commission (SEC). The SEC is one of
the regulatory watchdogs of the U.S. government, created in
the 1930s to protect investors, maintain fair and efficient
markets, and facilitate capital formation. This is
accomplished by collecting and disseminating documents that
disclose financial and other company information so the public
can make sound investment decisions. To fulfill this
responsibility, the SEC has the authority to require
publicly-traded companies to file disclosure documents, which
are then made available to the investing public via the
Electronic Data Gathering, Analysis, and Retrieval system
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(EDGAR), the SEC's online database of public company filings.
All companies (including foreign entities) that publicly sell
securities in the U.S. must be registered with the SEC and
comply with its filing requirements.
EDGAR performs automated collection, validation, indexing,
acceptance, and forwarding of submissions by companies and
others who are required by law to file forms with the SEC.
Its primary purpose is to increase the efficiency and fairness
of the securities market for the benefit of investors,
corporations, and the economy by accelerating the receipt,
acceptance, dissemination, and analysis of time-sensitive
corporate information filed with the SEC.
EXISTING STATE LAW:
1)Requires local agency financial transaction reports to include
information about the annual compensation of the local
agency's elected officials, officers, and employees, requires
local agencies to post this information on their Internet
Websites, and requires the State Controller to compile,
publish, and make this information publicly available on the
Controller's Website.
2)Establishes OSHPD, and designates OSHPD as the single state
agency to collect specified health facility or clinic data for
use by all state agencies.
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3)Requires private non-profit hospitals to complete a community
needs assessment and adopt a community benefits plan, and to
annually submit the community benefit plan to OSHPD, along
with a report of the economic value of community benefits
provided in furtherance of the plan.
FISCAL EFFECT: This bill has not been analyzed by a fiscal
committee.
COMMENTS:
1)PURPOSE OF THIS BILL. According to the author, currently
there is little transparency over whether for-profit or
non-profit hospitals use taxpayer dollars to provide
high-quality, affordable medical care, or if funds are being
diverted to exorbitant executive compensation packages. The
author states that this bill ensures more accountability and
transparency in an otherwise opaque environment.
2)BACKGROUND.
a) Rising healthcare costs. The U.S. Census Bureau has
published new estimates of health spending based on their
Quarterly Services Survey, published on March 10, 2016.
Analysis of the survey data shows that health spending was
7.3% higher in the first quarter of 2015 than in the first
quarter of last year. Hospital spending increased 9.2%. A
Kaiser Family Foundation analysis of the data concludes
that greater use of health services, as well as more people
covered by the Patient Protection and Affordable Care Act
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appear to be responsible for most of the increase, noting
that people are beginning to use more physician and
outpatient services again as the economy improves and that
the number of days people spent in hospitals also rose.
b) Executive compensation. According to the proponents of
this bill, little is known about what factors drive health
care costs, however they point to the fact that hospital
executive compensation has spiked in recent years.
According to the healthcare industry publication "Payers &
Providers," 66 executives at the state's three largest
hospital systems (Sutter Health, Dignity Health, and Kaiser
Permanente) earned more than $1 million each in 2013, up
from 52 executives just two years before.
c) Publicly available information.
i) Non-profit entities. The IRS 990, officially, the
"Return of Organization Exempt from Income Tax" is an IRS
form that provides the public with financial information
about a non-profit organization. It is often the only
source of such information. Non-profit hospitals are
required to file the form 990 in order to maintain their
non-profit/tax-exempt status. However, only the top 20
wage earners over $150,000 have to be identified on the
forms, and due to differing corporate structures of
hospitals and hospital systems, the data is not easily
comparable. For example, Kaiser is one corporate entity
with two branches, North and South. Their 990 covers
their hospitals and health plan, however their medical
group (the doctors) are a for profit entity, so their
salaries are not included on the 990. Conversely,
Dignity Health (Dignity) files a single 990 for the
entire system. The top 20 wage earners on Dignity's form
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are system-wide employees, so their 990 excludes many
CEO's.
According a June 30, 2015 article published in the
Chronicle of Philanthropy, the IRS is working on a
technology that should allow it to release electronic
version of the form 990 by early this year, which would
make it much easier for the public to search for
information about non-profit finances and operations.
ii) For-profit entities. Publicly traded companies
report significant amounts of financial data to
shareholders and the government in their annual U.S. SEC
filings. Several documents that companies are required
to file include information about the company's executive
compensation policies and practices including; the
company's annual proxy statement; the company's annual
report; and, registration statements filed by the company
to register securities for sale to the public. The
information is available on the SEC's searchable
database, EDGAR.
iii) Private for-profit entities. Privately owned
for-profit hospitals are not required to report on their
executive's salaries. Of the 105 for-profit hospitals in
the state, approximately 50 are not publicly traded, and
do not report salary information.
d) Federal annual equal employment opportunity and
compensation report (EEO-1 Report). The EEO-1 Report is a
compliance survey mandated by federal statute and
regulations. The survey requires company employment data
to be categorized by race/ethnicity, gender and job
category. On January 29, 2016, the EEOC announced proposed
changes to its EEO-1 report, which requires employers to
submit employee W-2 earnings and hours worked. Under the
proposal, all employers with at least 100 employees (not
just federal contractors) would be required to comply. In
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addition, the proposed changes will require the submission
of payroll data broken down by race/ethnicity, in addition
to gender. The data would be made available to the EEOC
and the Office of Federal Contract Compliance Programs for
enforcement purposes. The proposed rule was published on
February 1, 2016 and interested parties have 60 days to
submit comments.
The EEOC proposing to change the reporting requirements to
include the data on employees' earnings and hours worked,
beginning in 2017. The EEOC's proposed pay bands (which
are included in the reporting provisions of this bill) are
as follows:
i) $19, 239 and under:
ii) $19,240 - $24, 439;
iii) $24,440 - $30,679;
iv) $30,680 - $38,999;
v) $39,000 - $49,919;
vi) $49,920 - $62,919;
vii) $62,920 - $80,079;
viii) $80,080 - $101,919
ix) $128,960 - $163,799;
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x) $163,800 - $207,999; and,
xi) $208,000 and over.
The EEOC is prohibited from making public the employment
data derived from any of its compliance surveys. The EEOC
uses EEO-1 data to support civil rights enforcement and to
analyze employment patterns, such as the representation of
female and minority workers within companies, industries or
regions. The EEOC is not proposing to require an employer
to begin collecting additional data on actual hours worked
for salaried workers, to the extent that the employer does
not currently maintain such information.
e) Self-reported employee information. According to the
Human Rights Campaign (HRC) unlike other diversity
categories, such as race and gender, employers are not
required to collect statistics on the number of lesbian,
gay, bisexual, and transgender (LGBT) people they employ.
Employers have sought to determine the number of their
employees who identify as LGBT while balancing privacy
concerns. Some employers use LGBT employee group
membership numbers to generate estimates, but this method
is limited by the scope of such voluntary groups over a
highly dispersed workforce. More recently, employers have
gathered statistics through anonymous employee engagement
or satisfaction surveys, which can include upward of 100
questions, and through confidential and secure employee
records. In both cases, whether an employee discloses
their gender identity or sexual orientation is optional and
voluntary and any reporting or direct access to the data is
designed to ensure confidentiality of the employee. In the
HRC Corporate Equality Index 2015 survey of 781 employers,
46% allow employees to voluntarily disclose their sexual
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orientation and gender identity on anonymous surveys or
confidential Human Resource records, compared with 141 of
the 519 employers (27%) in the 2008 survey and just 17% in
the 2006 survey.
3)SUPPORT. The California State Council of the Service
Employees International Union (SEIU California) supports this
bill, stating, while California public hospitals (city,
county, or University of California) are already required to
provide complete salary information for all employees through
the Controller, which publicly reports these data, significant
gaps and inconsistencies exist for our understanding of
not-for-profit and for-profit hospitals.
Hospitals which are publicly-traded must disclose executive
compensation for their Chief Executive Officer, Chief
Financial Officer, and the next three top paid employees
company-wide to the SEC, which seldom capture their California
executives if the firm is national. SEIU California
continues, with nonprofits, the public makes a significant
investment in the form of over a billion a year in tax
exemptions in California, but nonprofit hospitals must only
disclose their top five highest compensated employees, beyond
their officers and directors, which often obfuscates
individual hospital CEO compensation, particularly at large
multi-facility nonprofit hospital chains. In each of these
examples there has already been established a compelling
policy reason to understand how top executives are being paid
- for the sake of understanding public investments, and
informing private investor decision-making - but the reporting
requirements in each case are different in scope and detail
and ultimately become of little use in very large nonprofit
chains or national companies, especially for national systems
not based in California. SEIU California notes that, at issue
for non-profit operated hospitals is the need to better
understand whether the state's investment through tax breaks
and others subsidies leads hospitals to provide more charity
care and community benefits, or whether it simply serves as a
mechanism to provide hospital executives with more excessive
pay. SEIU California points to a 2015 study published in
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Health Affairs that found that California's nonprofit
hospitals spent the same amount on uncompensated care as
for-profit hospitals, which suggests greater accountability is
warranted. SEIU California concludes this bill will align
hospital executive compensation reporting for all non-profit
and for-profit hospitals, including investor owned hospitals,
and consolidate that reporting within OSHPD, which already
collects and reports a myriad of different hospital financial
data.
The California Labor Federations states that increasing
transparency of CEO compensation at hospitals is a first step
in examining all cost drivers in health care, starting at the
top of the hospital chain, and given that the largest
California hospitals are non-profits, taxpayers should have
access to the compensation and other data about hospitals that
they support with tax breaks.
4)OPPOSITION. The California Hospital Association (CHA) opposes
this bill and states that hospitals and health systems are not
opposed to transparency; many hospitals currently report much
of the information sought and it is available to the public,
however this bill only increases hospital costs and discloses
private compensation information without any justification.
CHA also notes that the bill raises significant privacy
concerns for a broad array of employees, extending to exempt
employees, not just executives, thus nurse managers or
information technology personnel whose total compensation
meets for exceeds $250,000 annually would be reported. CHA
notes that in many organizations, particularly in urban areas,
this reporting threshold would reach deep into the
organization.
The Hospital Corporation of America states it is concerned about
the unintended consequences of public reporting of salaries,
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noting that it could actually drive up labor costs where
employees and applicants use the salary information as
benchmarks for the myriad of hard to fill positions in health
care.
The California Chamber of Commerce (the Chamber) states that
this bill inappropriately assumes that hospital executive
compensation is a major driver of overall health care
spending. The Chamber notes that hospital executives play a
critical role in ensuring that millions of Californians
receive quality health care services, even as cost pressures
and increasing demand for hospital services are making it
harder and harder for many hospitals to keep their doors open.
5)RELATED LEGISLATION. AB 1890 (Dodd) provides that an employer
with 100 or more employees in the state and a contract with
the state of 30 days or more shall submit a description of its
nondiscrimination program to the Department of Fair Employment
and Housing, and shall be required to submit periodic reports
(no more than annually) of its compliance with that program.
AB 1890 is currently pending in the Assembly Appropriations
Committee.
6)PREVIOUS LEGISLATION.
a) AB 2040 (Cristina Garcia), Chapter 894, Statutes of
2014, requires local agency financial transaction reports
to include information about the annual compensation of the
local agency's elected officials, officers, and employees,
requires local agencies to post this information on their
Internet Websites, and requires the Controller to compile,
publish, and make this information publicly available on
the Controller's Website.
b) SB 346 (Wieckowski) of 2015 would have repealed the
existing hospital community benefit law, and established a
new hospital community law to require private non-profit
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hospitals to complete a community needs assessment,
followed by a community benefits plan, and required 90% of
a private non-profit hospital's community benefit moneys to
be allocated to charity care and projects that improve
community health for underserved and vulnerable
populations. SB 346 died in the Senate Health Committee.
c) AB 2180 (Alejo), Chapter 322, Statutes of 2012, requires
a written employment agreement between a health care
district and a hospital administrator to include all
material terms and conditions agreed to between the
district and the hospital administrator regarding
compensation and other benefits, as specified, that differ
from those available to other full-time employees.
7)TECHNICAL AMENDMENTS. The definition of a covered hospital or
medical entity incorrectly cross references the wrong section
of current law. The bill should be amended to correct the
drafting error, and to clarify the definition of a
hospital-affiliated physicians group.
8)POLICY COMMENTS.
a) As currently drafted, this bill incorporates
requirements that are based on a federal EEOC policy that
has yet to be adopted. The Committee may wish to consider
whether it is premature to predicate California law on a
pending federal proposal.
b) As currently drafted this bill requires the annual
report to include voluntarily self-reported employee data
on sexual orientation and gender identity. Should the bill
move forward, the author may wish to consider adding
language to clarify that the data is private, and any
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reporting of the data will not directly identify the
employee by name.
REGISTERED SUPPORT / OPPOSITION:
Support
SEIU California (sponsor)
California Labor Federation
California Lesbian, Gay, Bisexual and Transgender Health and
Human Services Network
Equality California
Health Access, California
United Nurses Associations of California/Union of Health Care
Professionals
Opposition
Adventist Health and Loma Linda University Health
Adventist Medical Center-Hanford
Adventist Medical Center-Reedley
Adventist Medical Center-Selma
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Alliance of Catholic Health Care
Antelope Valley Hospital
Association of California Healthcare Districts
Banner Lassen Medical Center
Barstow Community Hospital
California Chamber of Commerce
California Hospital Association
Citrus Valley Health Partners
Coalinga Regional Medical Center
Community Hospital Long Beach
Community Medical Centers
Corona Regional Medical Center
Cottage Health
Delano Regional Medical Center
Desert Valley Hospital
Eisenhower Medical Center
Enloe Medical Center
Fairchild Medical Center
Feather River Hospital
Good Samaritan Hospital
Healdsburg District Hospital
HealthSouth Bakersfield Rehabilitation Hospital
Hemet Valley Medical Center
Hospitals Corporation of America
John Muir Health
Kaiser Permanente
Lodi Memorial Hospital
Long Beach Memorial
Mad River Community Hospital
Madera Community Hospital
Marin General Hospital
MemorialCare Health System
MemorialCare Medical Foundation
Menifee Valley Medical Center
Mercy Hospitals
Methodist Hospital of Southern California
Miller Children's and Women's Hospital Long Beach
Monterey Park Hospital
NorthBay Healthcare
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Orange Coast Memorial
Palo Verde Hospital
Plumas District Hospital
Pomona Valley Hospital Medical Center
Prime Healthcare
Private Essential Access Community Hospitals
Providence Health & Services
Providence Holy Cross medical Center in Mission Hills
Providence Little Company of Mary Medical Center San Pedro
Providence Little Company of Mary Medical Center Torrance
Providence Saint John's Health Center
Providence Saint Joseph Medical Center in Burbank
Providence Tarzana Medical Center
Queen of the Valley Medical Center
Redlands Community Hospital
Ridgecrest Regional Hospital
Riverside Community Hospital
St. Jude Medical Center in Fullerton
San Bernardino Mountains Community Hospital
Santa Rosa Memorial Hospital and Petaluma Valley Hospital
Southwest Healthcare System - Inland Valley and Rancho Springs
Medical Centers
Stanford Health Care
Tahoe Forest Health System
Tenet Healthcare
Ukiah Valley Medical Center
United Hospital Association
Valley Children's Healthcare
Vibra Hospital of Sacramento
Watsonville Community Hospital
White Memorial Medical Center
Analysis Prepared by:Lara Flynn / HEALTH / (916) 319-2097
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