BILL ANALYSIS
SENATE HUMAN
SERVICES COMMITTEE
Senator Carol Liu, Chair
BILL NO: AB 435
A
AUTHOR: Comm. on Accountability and Administrative
Review B
VERSION: August 3, 2010
HEARING DATE: August 10, 2010
4
REFERRAL: Rules and Appropriations; Urgency 2/3 vote
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5
CONSULTANT:
Park
SUBJECT
Regional centers: whistleblower protection
SUMMARY
Requires each state contract with a regional center to
include steps the regional center will take to ensure that
a regional center's staff, board members, consumers and
their representatives, and providers are notified of their
right to make confidential reports of improper regional
center activity to the Department of Developmental
Services. Provides for penalties, civil liability, and
imprisonment for specified acts against a regional center
employee for having made a protected disclosure, as
specified. Makes other changes related to these
activities.
ABSTRACT
Existing law:
1.Establishes the Lanterman Developmental Disabilities
Services Act (Lanterman Act), under which the Department
of Developmental Services (DDS) contracts with 21 private
non-profit regional centers to provide case management
Continued---
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services and arrange for, or purchase, services that meet
the needs of individuals with developmental disabilities,
as defined.
2.Requires the state to enter into five-year contracts with
regional centers, subject to the annual appropriation of
funds by the Legislature. Requires contracts to include
a provision requiring each regional center to render
services in accordance with applicable provision of state
laws and regulations; requires contracts to include
annual performance objectives, and meet other specified
criteria.
3.Requires each contract with a regional center to specify
steps to be taken to ensure contract compliance,
including, but not limited to: incentives that encourage
regional centers to meet or exceed performance standards;
and levels of probationary status and corrective action,
as specified. Requires DDS to evaluate a regional
center's compliance with its contract performance
objectives and legal obligations related to those
objectives, as specified.
4.Requires DDS to make reasonable efforts to resolve
problems with a regional center that is not fulfilling
its contractual obligations, and requires letters of
noncompliance to be issued and corrective action plans to
be developed and implemented if there is no successful
resolution. Requires DDS to terminate the contract of
any regional center that continues to fail in fulfilling
its contractual obligations, if specified findings are
made, and authorizes such findings to be the basis of
non-renewal.
5.Provides in the Lanterman Act and the
Lanterman-Petris-Short (LPS) Act that, except for
specifically delineated exceptions, all information and
records obtained in the course of providing services to
people with developmental disabilities or recipients of
voluntary or involuntary mental health services shall be
confidential.
6.Under the California Whistleblower Protection Act (WPA),
establishes circumstances and procedures under which
persons, as defined, may report confidentially improper
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governmental activities, as defined, to the State
Auditor. Provides for fines, imprisonment, and civil
liability for specified violations, such as retaliation
or reprisal against a state employee or applicant for
making protected disclosures, as defined, to the State
Auditor.
7.Prohibits employers, both public and private, from
preventing employees from disclosing information, or
retaliating against employees for disclosing information,
to a government or law enforcement agency where the
employee has reasonable cause to believe that the
information discloses a violation of state or federal
statute, or a violation of or noncompliance with a state
or federal rule or regulation. Requires the Attorney
General (AG) to maintain a whistleblower hotline to
receive calls regarding such violations, and requires the
AG to refer calls to the appropriate government agency
for review and possible investigation. Requires the AG
and appropriate government agency to hold in confidence,
during the initial review of the call, information
disclosed through the whistleblower hotline, including
the identity of the caller and the employer identified by
the caller. Establishes fines and criminal penalties for
violations of these provisions, and burden of proof
pertaining to civil actions and administrative
proceedings related to such violations.
8.Prohibits employers from making, adopting, or enforcing
any rule, regulation, or policy preventing an employee
from disclosing information to a government or law
enforcement agency or from acting in furtherance of a
false claims action, and prohibits an employer from
discharging, demoting, suspending, threatening,
harassing, denying promotion to, or in any other manner
discriminating against, an employee in the terms and
conditions of employment because of lawful acts done by
the employee on behalf of the employee or others in
disclosing information to a government or law enforcement
agency or in furthering a false claims action. Provides
for relief measures, including reinstatement, back pay,
damages, litigation costs, and attorney's fees, in
addition to other remedies.
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This bill:
1.Requires, not later than July 1, 2011, that each contract
with a regional center include steps the regional center
will take to provide notice to its staff, board members,
consumers and their representatives, and providers that
confidential reports of improper regional center
activity, as defined, can be made directly to DDS.
Requires all regional center contracts to be amended by
July 1, 2011, to include these provisions.
2.Requires notices to include all appropriate methods for
contacting DDS and requires regional centers to post
notices for regional center staff where other mandatory
employee notices are posted.
3.Defines "improper regional center activity" to mean an
activity by a regional center or its employee, officer,
or board member that is undertaken in performance of his
or her official duties, whether or not within the scope
of his or her employment, and that violates a state or
federal law or regulation, including, but not limited to,
corruption, malfeasance, bribery, theft or misuse of
government property, fraudulent claims, coercion,
conversion, malicious prosecution, or willful omission to
perform duty; or involves gross misconduct or
incompetency.
4.Defines "protected disclosure" to mean a good faith
communication that discloses or demonstrates an intention
to disclose to DDS or the Legislature information that
may evidence an improper regional center activity, or a
condition that may significantly threaten the health or
safety of employees or the public if the disclosure or
intention to disclose was made in order to remedy that
condition.
5.Allows a [regional center] employee, who files a written
complaint with the regional center pertaining to certain
acts prohibited by law, to file a copy of the complaint,
signed under penalty of perjury, with DDS, within 12
months of the most recent act of reprisal.
6.Provides that a person who intentionally engages in acts
of reprisal, retaliation, threats, coercion, or similar
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acts against a regional center employee for having made a
protected disclosure, as defined, shall be guilty of a
misdemeanor punishable by a fine not to exceed $10,000,
imprisonment in a county jail not to exceed one year, or
both.
7.Establishes, in addition to all other penalties provided
by law, civil liability for intentional acts of reprisal,
retaliation, threats, coercion, or similar acts against
regional center employees for having made a protected
disclosure, and authorizes recovery of punitive damages
for malicious conduct, and for reasonable attorney's
fees. Conditions an action for damages on the prior
filing of a complaint with DDS.
8.Provides that these provisions shall not prevent a
regional center, manager, or supervisor from taking,
directing others to take, recommending, or approving a
personnel action or failing to take a personnel action,
with respect to an employee if the governing board of the
regional center determines that the action or inaction is
justified on the basis of evidence separate and apart
from the individual's protected disclosure.
9.Provides that these provisions shall not diminish the
rights, privileges or remedies of an employee under any
other federal or state law, employment contract, or
collective bargaining agreement.
10.Allows information and records related to persons with
developmental disabilities to be disclosed to DDS for the
purpose of conducting their investigations above.
11.Provides that employees, office holders, board members
of regional centers shall not be subject to reprisal or
harassment, or threatened with any action that would
prevent him or her from assisting a consumer or consumer
representative from pursuing a complaint.
12.Makes change related to the Department of Public Health
and Department of Health Care Services duties. [NOTE:
technical error.]
13.Declares that, in order to provide timely protections to
regional center employees and improve services to persons
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with developmental disabilities and their families, at
the earliest possible time, it is necessary that this act
go into effect immediately as an urgency statute.
FISCAL IMPACT
Unknown.
BACKGROUND AND DISCUSSION
Authors' statement
The authors (the members of Assembly Accountability and
Administrative Review Committee) state that, although the
private, non-profit system of 21 regional centers are
funded with close to $4 billion in federal and state funds
per year, the public does not have access to the level of
information about their operations or financial
transactions that it would have if these were public
agencies.
The authors note that, on June 10, 2009, the Assembly
Accountability and Administrative Review Committee (AAARC)
heard testimony illustrating the need to increase
transparency in regional center operations, information
pertaining to conflicts of interest, and threats and acts
of retaliation against employees, among other issues. The
authors note that, "most of the comments-received
confidentially by AAARC staff-centered on individuals' fear
of retaliation from DDS or their local regional center for
reporting wrongdoing."
The authors note that employees of public agencies in
California can make confidential reports of improper
activities to the Whistleblower Protection Hotline,
operated by the Bureau of State Audits, and, in many
agencies, employees can also make confidential reports to
an inspector general or ombudsman. The authors highlight
that current law does not provide an avenue for regional
center employees to make confidential complaints to any
investigative body. The authors note that, in the year
since its hearing, the AAARC has continued to receive an
escalating number of reports alleging intimidation and
retaliation against regional center employees-among others-
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who report wrongdoing.
Regional centers
Community-based services to developmentally disabled
persons, as defined, are provided through 21 nonprofit
corporations known as regional centers. Regional centers
are obligated by statute and contract to provide certain
services, including eligibility determinations, individual
assessment, case management, and individual program plan
(IPP) development. The regional center develops the IPP in
collaboration with the individual with the development
disability, and where appropriate, the authorized
representative. The IPP includes a statement of goals,
based on the needs, preferences and life choices of the
individual and a schedule of the type and amount of
services and supports to be purchased by the regional
center or obtained from generic agencies or other resources
to achieve the IPP goals and objectives. Regional centers
purchase services such as transportation, health care, day
programs and residential care provided by community care
facilities, and generally pay for services if an
individual's private insurance does not cover, or the
individual has no private coverage, or where "generic"
services provided through other programs, entities, or
agencies are not available.
Collectively, regional centers employ almost 7,000
individuals statewide, serve 240,000 individuals, and
purchase services from about 40,000 vendors or providers.
DDS' oversight of regional centers
DDS has performance contracts with regional centers,
whereby DDS monitors progress, and follows-up when the
regional center fails to maintain an acceptable level of
compliance with performance objectives or make progress
toward meeting them. DDS may impose corrective actions on
a regional center, additional contract provisions, and
levels of probation. DDS also performs biennial (or
annual, if warranted) fiscal audits on regional centers.
Additionally, for the purpose of ensuring the center is
meeting federal requirements pursuant to the DDS' approved
federal waiver, DDS visits each center every other year,
whereby DDS staff reviews records, interviews consumers and
staff, and visits program sites. DDS must also review
regional center purchase of service policies to prevent a
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center from utilizing a policy that violates the Lanterman
Act.
DDS' handling of complaints
DDS indicates that it has a variety of complaint and appeal
processes available to vendors/contractors, agencies,
facilities, parents, and consumers. These include consumer
rights complaints; complaints related to the Early Start
program, due process requests, and mediation conference
requests; Lanterman Act fair hearing requests; Title 17
complaints; citizen complaints and comments. DDS notes
that each of these complaint and appeal processes has
separate and distinct procedures for resolution.
On July 28, 2010, DDS issued a letter to all regional
center executive directors regarding its whistleblower
complaint process. The DDS whistleblower notice defines
both improper regional center activity and improper
vendor/contractor activity and indicates that DDS will need
a clear and concise statement of the improper activity and
any evidence to support the allegation. The notice states
that, "If you do not provide a name or other information
(witnesses or documents) that clearly identifies the person
you are alleging has acted improperly, and the regional
center or vendor/contractor where that person works, we may
not have sufficient information to investigate. ? Although
complaints may be filed anonymously, if insufficient
information is provided and we have no means to contact
you, we may not be able to investigate your allegations."
The notice also states that DDS "?will do everything
possible to maintain the confidentiality of a complainant
making a whistleblower complaint if the complainant
requests confidentiality. However, in the rare
circumstances where DDS is unable to maintain
confidentiality due to its statutory responsibilities
(including ensuring the health and safety of consumers and
regional center contract compliance), the Department will
attempt to inform the complainant of its need to disclose
certain information prior to releasing identifying
information. Additionally, the identity of the complainant
may be revealed to appropriate law enforcement agencies
conducting a criminal investigation."
In the notice, DDS stated that it had posted on its website
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information regarding the whistleblower complaint process
and requested all regional centers to also post on their
Web sites, in addition to utilizing other communication
mechanism to provide notification to employees, board
members, consumers and their families, and the vendor
community of the complaint process and their right to make
reports of improper activity to DDS.
Whistleblower statutes and protection against retaliation
The California Whistleblower Protection Act (WPA)
establishes procedures and protections with respect to
confidential complaints made against state agencies by
state employees and other "persons" to the State Auditor
for possible investigation. WPA specifically provides for
fines, imprisonment, and civil liability for specified
violations, such as retaliation or reprisal against a state
employee or applicant for making protected disclosures, as
defined, to the State Auditor.
Regional centers, like other non-governmental employers,
are subject to the Labor Code prohibitions on retaliation
against employees for disclosures of violations of state or
federal statute, or a violation of or noncompliance with a
state or federal rule or regulation. These provisions
include fines and criminal penalties for violations of the
provisions. Additionally, Health and Safety Code provides
for whistleblower type protections relating to the
reporting of care, services, and conditions of a health
facility and applies certain civil and criminal penalties.
AAARC June 10, 2009, hearing on regional centers
The background briefing paper prepared by AAARC staff for
its June 10, 2009, informational hearing notes that the
regional center system "differs from other state services
because the point of service for consumers is a private,
non-profit organization, as opposed to a state or local
public agency." As a result, AAARC staff notes, "many
transparency and accountability provisions in the law which
apply to public agencies, do not apply to [RCs]." AAARC
staff state that "much of the information that [RCs] are
required to provide to DDS or to make available to the
public, is available only upon request" and that AAARC
staff "has heard widespread allegations about the
burdensome process of requesting information from or about
[RCs], and the related fear of retribution." According to
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AAARC staff, several regional centers were reputed to be
well-run; however, "other [RCs] were fraught with
allegations of conflict of interest, over billing, refusals
to provide information, and retaliation towards those who
raised concerns about the way their local [RC] operates."
AAARC staff state that "[t]here is currently no way to make
. . . reports or complaints to the [RC], DDS, the Attorney
General, or any other oversight agency in an anonymous
manner because Whistleblower protections are not
applicable."
Allegations of wrongdoing
In response to a request from committee staff for
additional information uncovered by AAARC staff in its
review of regional centers, which began in Feb/March 2009,
AAARC staff responded with the following:
Examples of wrongdoing reported confidentially to the
Assembly Committee on Accountability and
Administrative Review include:
Regional center staff being reprimanded or
threatened with dismissal for presenting options
or choices to consumers and their families at IPP
meetings instead of directing them to providers
preferred by regional center management.
Generally with this type of complaint, that
preference is based on familial or social
relationships as opposed to objective criteria
such as assessments of provider quality;
Regional center staff being threatened with
dismissal if they disobey an order to lie to
consumers about the availability of services with
a provider that has raised concerns about
regional center operations;
Regional center staff being dismissed for raising
questions about preferential treatment of vendors
based on familial relationships with regional
center management.
These activities violate the right of consumers to
make informed decisions and to access the services
that may best meet their needs. According to the
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Lanterman Act:
"The right of individuals with developmental
disabilities to make choices in their own lives
requires that all public or private agencies receiving
state funds for the purpose of serving persons with
developmental disabilities, including, but not limited
to, regional centers, shall respect the choices made
by consumers or, where appropriate, their parents,
legal guardian, or conservator. Those public or
private agencies shall provide consumers with
opportunities to exercise decision-making skills in
any aspect of day-to-day living and shall provide
consumers with relevant information in an
understandable form to aid the consumer in making his
or her choice." (WIC 4502.1)
"It is the intent of the Legislature to ensure that
the individual program plan and provision of services
and supports by the regional center system is centered
on the individual and the family of the individual
with developmental disabilities and takes into account
the needs and preferences of the individual and the
family, where appropriate, as well as promoting
community integration, independent, productive, and
normal lives, and stable and healthy environments. It
is the further intent of the Legislature to ensure
that the provision of services to consumers and their
families be effective in meeting the goals stated in
the individual program plan, reflect the preferences
and choices of the consumer, and reflect the
cost-effective use of public resources." (WIC
4646(a))
AAARC staff also provided that since it began its review of
regional centers and since its June 2009 hearing, AAARC has
received an average of one complaint per week related to
regional center activities, the majority of which have
dealt with improper regional center activities, identified
above. AAARC staff indicate that the majority of the calls
are from providers and family members of consumers, with
the next group represented being regional center employees;
and that providers, advocates, and family members of
consumers routinely reference instances of regional center
staff withholding reports of improper activities out of
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fear of retaliation. (AAARC staff notes that it has
pursued other parallel efforts to improve transparency and
accountability in the regional center system, and has
received calls pertaining to those efforts as well.)
AAARC staff state that the concerns raised by AAARC pertain
to "the ability of regional center staff to provide, and
the right of consumers and their families to receive, the
best service that they can without fear of retaliation."
AAARC staff state that "a consumer cannot know and
therefore cannot make use of the fair hearing process to
address instances where a case manager withholds
information at an IPP meeting out of fear of retaliation."
Bureau of State Audits (BSA) audit of DDS regional centers
BSA's audit of DDS and regional centers is expected to be
released on August 31, 2010. According to BSA, this audit
will provide independently developed and verified
information related to DDS and a sample of regional centers
and would include, but not be limited to, the following: an
examination of DDS's oversight responsibilities for its
regional centers; a review of a sample of paid invoices for
the past two fiscal years at each regional center
(selected) and a determination if the activities for
payment were reasonable and/or allowable under the law; a
review a sample of service provider contracts for the past
two fiscal years at each regional center (selected) and an
evaluation of the regional centers' policies and practices
for awarding contracts to service providers, including how
the regional centers determine that the service providers
can satisfy the needs of the consumers, whether past
performance by a service provider was considered, and the
potential for conflict of interest did not exist; a survey
of a sample of current and past service providers to obtain
information on whether the providers are reluctant to file
complaints for fear of retaliation or believe they
experienced retaliation from the regional centers and the
reason for their perceptions; a determination if the
regional centers' procedures for allowing public access to
information on operations complies with law.
Arguments in support
Some of the following support letters were submitted in
relation to the prior version of the bill, as amended on
June 22, 2010.
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The California Disability Services Association (CDSA)
writes that the duties of regional centers make them
quasi-governmental in nature, in that they expend large
sums of money, enforce various laws and regulations, and
serve as a gateway to services for the population they are
charged with serving.
Modern Support Services, which provides supported and
independent living services to developmentally disabled
individuals, writes that, while the regional center system
provides much needed services to individuals and families,
"there are many situations and decisions made by Regional
Center staff that may possibly compromise the health and
well being of consumers, as well retaliatory acts towards
vendor agencies who do not see 'eye to eye' with a regional
center employee." Modern Support Services states that,
"currently regional center employees are terrified to say
or report anything as they are afraid of being terminated
from employment."
ResCoalition and Service Employees International Union
write that "the [regional center] system has become fraught
with stories of favoritism, inflated contracts, and
blackballing."
One attorney writes on behalf of his client, a former
employee of a regional center for 14 years, who was
terminated. The attorney states that his client had
contacted both DDS and the AG regarding improper billing by
regional centers, after which the regional center began
disciplinary proceedings against him and then terminated
his client for circulating his concerns to other staff, in
alleged violation of the regional center's e-mail policy.
Arguments in opposition
The Association of Regional Center Agencies (ARCA) writes
that existing law provides overlapping protection and
safeguards for regional center employees when making a
protected disclosure, and cites both Government Code
Section 12653 regarding false claims and Labor Code 1102.5
regarding the reporting of violations of state and federal
law and regulation. ARCA also states that the bill places
greater responsibility of approving a personnel action on
the board of directors as the governing body of the
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regional center, at least 25 percent of whom are persons
with developmental disabilities, and at least 50 percent of
whom are persons with disabilities or their
parents/guardians. ARCA believes that this greater
authority to terminate an employee, which traditionally
falls under the executive director, exposes individual
board members to criminal and civil liability. ARCA also
believes that the penalties afforded by the bill, as well
as the existing penalties of Labor Code create an overly
harsh punishment standard.
ARCA also states that the provisions of the bill should
also protect the 100,000 people employed by 40,000
community-based regional center vendors, who provide the
services and are the true final recipients of state
purchase-of-service funds.
Finally, ARCA raises procedural concerns in pointing out
that AB 1589 of 2009 was held under submission by the
Assembly Appropriations Committee due to its fiscal impact
during the state's fiscal crisis, and this measure has been
gutted and amended late in the session.
Related/prior legislation
AB 1589 (Committee on Accountability and Administrative
Review) of 2009 requires regional centers (RCs) to disclose
information on "related-persons transactions" and
establishes whistleblower protections for RC employees who
report improper RC activities. Held under submission by
the Assembly Appropriations Committee.
AB 1749 (Lowenthal and Strickland) of 2010 would extend to
judicial branch employees certain additional rights under
the Whistleblower Protection Act to complain about improper
governmental activities and protections against retaliation
for making those complaints and other protected
disclosures. On Senate Floor, Special Consent Calendar.
PRIOR VOTES
Not relevant. This is a gut and amend.
COMMENTS
1.Recent amendments and bill's history. As heard by this
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committee on June 30th, this bill, a gut and amend, was
substantially similar to another bill, AB 1589 (Committee
on Accountability and Administrative Review) of 2009,
which was held by the Assembly Appropriations Committee.
This committee held no vote on AB 435. On August 3, the
author submitted substantial amendments, including an
urgency clause, reflected in the current version of the
bill. This version eliminates many parallel provisions
to the California Whistleblower Protection Act (WPA),
pertaining to improper activity by state agencies, and
eliminates the requirement for DDS to investigate all
complaints made confidentially about improper regional
center activity, and associated provisions pertaining to
required notice of personnel actions. The current
version retains the parallel penalty from the WPA (a
misdemeanor punishable by a fine not to exceed $10,000,
imprisonment in a county jail not to exceed one year, or
both) for acts of reprisal, retaliation, threats,
coercion, or similar acts against a regional center
employee for making a protected disclosure. The current
version also retains many of the same civil liability
provisions of WPA.
2.Contract provisions lack specificity and greater
oversight protections. The August 3 version of the bill
requires DDS' contract with regional centers to include
steps the regional center will take to provide notice to
its staff, board members, consumers and their
representatives, and providers that confidential reports
of improper regional center activity, as defined, can be
made directly to DDS. The bill does not provide any
direction to DDS regarding when confidentiality can be
compromised, if at all; what steps should be taken to
protect the regional center employee when confidentiality
is compromised, inadvertently or purposely; or what
improper actions should be subject to corrective action
and probationary status.
3.Recent administrative action by DDS. In its July 28,
2010, notice to regional centers, DDS instructed regional
centers to post notices about the right to make
complaints directly to the department and articulated its
confidentiality policy. It is unclear how the bill's
contract provisions differ from what DDS has already
instructed. It is also unclear how these provisions
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ensure that DDS is providing greater oversight than what
it has been currently doing, which the Assembly Committee
on Accountability and Administrative Review has found
inadequate in its hearings and has been the foundation
for this legislation.
4.Are penalties appropriate? The current version of the
bill retains the parallel penalty from the WPA (a
misdemeanor punishable by a fine not to exceed $10,000,
imprisonment in a county jail not to exceed one year, or
both) for acts of reprisal, retaliation, threats,
coercion, or similar acts against a regional center
employee for making a protected disclosure. This version
also keeps intact many of the same civil liability
provisions of WPA. Any person is subject to these
penalties. The committee may wish to consider the
appropriateness of subjecting consumers who are persons
with developmental disabilities to these penalties.
5.Allegations of wrongdoing. While the AAARC staff report
that its committee received numerous reports of alleged
threats and acts of retaliation, it is unclear whether
all reports were separate incidents, or which reports
were ultimately substantiated. It is also unclear which
complaints were reports of actual threats and
retaliations versus fears of retaliation (although both
are problematic). Additionally, while these reports were
made since early 2009, it is unclear over what time
period such incidents occurred. The AAARC staff have
indicated that it has referred some complaints to the
Bureau of State Audits. The author may wish to clarify
which cases need further resolution.
6.Bureau of State Audits (BSA) audit is in progress.
Currently, BSA is undertaking an audit to, among other
things, examine DDS' oversight responsibilities for its
regional centers. The audit will include a sample of
service provider contracts and evaluate regional center
policies and practices for awarding contracts;
additionally, the audit will include a survey to obtain
information on whether providers are reluctant to file
complaints for fear of retaliation. This audit is
expected to be released in August 31, 2010. The
committee may wish to weigh BSA's findings and
recommendations in this area. As such, this bill may be
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considered premature.
7.Referrals to other committees. Based on the civil
liability and criminal penalties, other policy committees
have requested to hear this urgency measure. A motion to
move the bill out of this committee will take the bill
back to Rules committee for possible referral to other
policy committees.
8.Several technical issues. The bill requires technical
fixes, apart from the larger policy questions, including
changing references from the State Department of Health
Care Services to the State Department of Public Health,
language exempting decisions and actions that are the
subject of the fair hearing procedure, incorrect
references, spelling, and specifying regional center
employees, rather than generally "employees."
9.Additional amendments. On Friday, August 6, the author
circulated additional amendments to various committee
staff related to penalty provisions. Some of these
amendments appear problematic.
POSITIONS
Support:* Arc of Riverside County
California Disability Services Association
Modern Support Services
ResCoalition
Service Employees International Union -
California State Council
3 individuals
*Some support letters were received in relation to the
prior version of the bill, as amended June 22, 2010.
STAFF ANALYSIS OF ASSEMBLY BILL 435 Page
18
(Comm. on Accountability and Administrative Review)
Oppose:Association of Regional Center Agencies
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