BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



           ------------------------------------------------------------ 
          |SENATE RULES COMMITTEE            |                   AB 549|
          |Office of Senate Floor Analyses   |                         |
          |1020 N Street, Suite 524          |                         |
          |(916) 651-1520         Fax: (916) |                         |
          |327-4478                          |                         |
           ------------------------------------------------------------ 
           
                                         
                                 THIRD READING


          Bill No:  AB 549
          Author:   Furutani (D)
          Amended:  8/20/10 in Senate
          Vote:     21

           
           SENATE BUSINESS, PROF & ECON DEVELOP COMM  :  5-2, 6/28/10
          AYES:  Negrete McLeod, Calderon, Corbett, Florez, Yee
          NOES:  Aanestad, Correa
          NO VOTE RECORDED:  Wyland, Walters

           SENATE APPROPRIATIONS COMMITTEE  :  7-4, 8/12/10
          AYES:  Kehoe, Alquist, Corbett, Leno, Price, Wolk, Yee
          NOES:  Ashburn, Emmerson, Walters, Wyland

           ASSEMBLY FLOOR  :  68-4, 1/27/10 - See last page for vote


           SUBJECT  :    Licensure:  clinical laboratory personnel

           SOURCE  :     City of Hope


           DIGEST  :    This bill includes clinical biochemical  
          geneticist in the list of clinical laboratory personnel  
          that are eligible for licensure by the Department of Public  
          Health (DPH).  This bill requires DPH to issue a temporary  
          license to a histocompatibility laboratory director, and  
          other specified clinical laboratory personnel within 30  
          days of receiving a completed application.  This bill also  
          requires DPH to adopt emergency regulations creating a  
          trainee license category, as specified.

                                                           CONTINUED





                                                                AB 549
                                                                Page  
          2

           Senate Floor Amendments  of 8/20/10 delete certain  
          requirements for the Department of Public Health in issuing  
          licenses for specified clinical laboratory personnel, and  
          make technical, and other clarifying changes.

           ANALYSIS  :    Existing law:

          1. Establishes in federal law, the Clinical Laboratory  
             Improvement Amendments of 1988 (CLIA), which regulates  
             laboratories when performing testing on human specimens  
             and includes laboratory standards for proficiency  
             testing, facility administration, personnel  
             qualifications, and quality control.  Applies standards  
             to all settings, including commercial, hospital, or  
             physician office laboratories.

          2. Establishes within DPH the Laboratory Field Services  
             (LFS) which provides for licensing and registration  
             services for clinical laboratories, and laboratory  
             personnel, as specified.

          3. Defines a clinical laboratory as any establishment or  
             institution operated for the performance of clinical  
             laboratory tests or examinations, or the practical  
             application of clinical laboratory sciences.  

          4. Defines a clinical laboratory test or examination as the  
             detection, identification, measurement, evaluation,  
             correlation, monitoring, and reporting of any particular  
             analyte, entity, or substance within a biological  
             specimen for the purpose of obtaining scientific data  
             which may be used as an aid to ascertain the presence,  
             progress, and source of a disease or physiological  
             condition in a human being, or used as an aid in the  
             prevention, prognosis, monitoring, or treatment of a  
             physiological or pathological condition in a human  
             being, or for the performance of nondiagnostic tests for  
             assessing the health of an individual.

          5. Provides that a clinical chemist, microbiologist,  
             toxicologist, genetic molecular biologist,  
             cytogeneticist or oral and maxillofacial pathologist is  
             any person licensed by DPH to engage in, or supervise  
             others engaged in, clinical laboratory practice limited  







                                                                AB 549
                                                                Page  
          3

             to his or her area of specialization or to direct a  
             clinical laboratory, or portion thereof, limited to his  
             or her area of specialization.  Specifies requirements  
             for licensure of these clinical laboratory personnel,  
             including requirements in training, education and  
             experience.  States that the application and renewal  
             fees for these laboratory personnel are $63 commencing  
             on July 1, 1983.

          6. States that a histocompatibility laboratory director  
             means a physician and surgeon licensed to practice  
             medicine or a licensed bioanalyst, and qualified to  
             serve as a laboratory director, as specified; or a  
             person who has earned a doctoral degree in a biological  
             science, who has completed, subsequent to graduation,  
             four years of experience in immunology, two of which  
             have been in histocompatibility testing.

          7. States that on and after January 1, 2007, to be eligible  
             for licensure as a histocompatibility laboratory  
             director, an applicant who is not a licensed physician  
             and surgeon or bioanalyst must provide evidence of  
             satisfactory performance on a written examination in  
             histocompatibility, as specified.

          8. States that a person who is licensed as a  
             histocompatibility laboratory director and qualified  
             under CLIA may perform clinical laboratory tests or  
             examinations classified as of high complexity under  
             CLIA, and any clinical laboratory test or examination  
             classified as waived or of moderate complexity under  
             CLIA.

          9. Establishes the Clinical Laboratory Improvement Fund  
             into which fees collected by DPH from clinical  
             laboratories are deposited and used for the purpose of  
             licensing, registration, certification, inspection, or  
             other activities relating to the regulation of clinical  
             laboratories.

          This bill:

          1. Requires DPH, within 30 days of determining that an  
             application is complete, to issue a temporary license to  







                                                                AB 549
                                                                Page  
          4

             any applicant seeking licensure as a histocompatibility  
             laboratory director, clinical chemist, microbiologist,  
             toxicologist, molecular biologist, cytogeneticist, or  
             biochemical geneticist, when the applicant meets the  
             following requirements:

             A.   The applicant has earned a doctoral degree in a  
               biological science and has completed, subsequent to  
               graduation, four years of training and experience in  
               immunology, of which two years shall have been in  
               histocompatibility testing in a laboratory in any  
               state of the United States or in Canada.

             B.   Provides evidence of satisfactory performance on a  
               written examination in histocompatibility administered  
               by the American Board of Histocompatibility and  
               Immunogenetics.

          1. Provides that applicant issued a temporary license shall  
             work only under the supervision of a licensed laboratory  
             director.

          2. States that a temporary license issued pursuant to item  
             # 3) above, shall remain valid until the applicant has  
             taken the oral examination offered by DPH, the applicant  
             has taken the oral examination offered by DPH, DPH  
             completes evaluating and processing of the applicant's  
             results and licensure, and DPH has issued a permanent  
             license.  Provides that if the applicant fails to pass  
             the required examinations, DPH may revoke the temporary  
             license upon notice to the applicant sent by first-class  
             mail.  Allows DPH to set and charge an application and  
             renewal fee sufficient to recover the costs of issuing  
             the temporary license.

          3. States that the trainee license for the personnel  
             specified in item # 3) above, applies to: 

             A.   Applicants holding an earned doctoral degree in a  
               biological science or field related to genetics from  
               an accredited university; and,

             B.   Who provide evidence of satisfactory performance on  
               a written examination in the area of specialty that is  







                                                                AB 549
                                                                Page  
          5

               administered by the American Board of Medical  
               Genetics, the Canadian Council of Medical Genetics, or  
               the appropriate accrediting body for the area of  
               specialty for which the applicant is seeking  
               licensure.  

          1. Provides that a formal letter, or other written  
             documentation issued by an accredited training program  
             indicating that the applicant has completed the program,  
             and from a clinical laboratory confirming the  
             applicant's employment experience, shall constitute  
             sufficient evidence for the following licensed  
             categories: clinical chemistry, clinical microbiology,  
             clinical toxicology, clinical molecular biology,  
             clinical biochemical genetics, and clinical  
             cytogenetics.  

          2. Requires these applicants to provide evidence of  
             satisfactory performance on a written examination in the  
             applicant's specialty or subspecialty administered by an  
             appropriate accrediting body recognized by DPH.  States  
             that to constitute sufficient evidence, formal letters  
             or other documentation must be provided directly by the  
             examining agency or appropriate accrediting body to DPH.

          3. Requires DPH to maintain an expeditious process for  
             licensing applicants for licensure in clinical  
             laboratory practice.  States that application forms and  
             instructions for each category of licensure shall be  
             posted on DPH's Internet Website.

          4. Requires DPH, after receiving an application for  
             licensure in clinical laboratory practice, including a  
             resubmission of an application, to notify the applicant  
             in writing, or by electronic mail that the application  
             is complete and shall be processed by DPH or that the  
             application is incomplete.  States that if the  
             application is incomplete, DPH shall specify in the  
             notification the transcripts, board certification,  
             verification of training, or other documents required to  
             complete the application for licensure that have not  
             been received by the department.

          5. Makes other technical, non-substantive changes.







                                                                AB 549
                                                                Page  
          6


           Background
           
           Biochemical Genetics  .  According to the American Board of  
          Medical Genetics (ABMG), an organization that certifies  
          individuals and accredits training programs in the field of  
          human genetics, a clinical biochemical geneticist is an  
          individual with a U.S. or Canadian earned, or the  
          equivalent of an earned doctoral degree (M.D., D.O., Ph.D.)  
          who can correctly perform and interpret biochemical  
          analyses relevant to the diagnosis and management of human  
          genetic diseases, and who acts as a consultant regarding  
          laboratory diagnosis of a broad range of biochemical  
          genetic disorders.  ABMG points out that these requirements  
          imply that the individual possesses the following: the  
          ability to supervise and direct the operations of a  
          clinical biochemical genetics diagnostic laboratory,  
          including technical expertise and knowledge in quality  
          control and quality assessment procedures; broad knowledge  
          of (1) basic biochemistry and genetics, (2) the application  
          of biochemical techniques to the diagnosis and management  
          of genetic diseases, and (3) the etiology, pathogenesis,  
          clinical manifestations, and management of human inherited  
          biochemical disorders; an understanding of the  
          heterogeneity, variability, and natural history of  
          biochemical genetic disorders; diagnostic and interpretive  
          skills in a wide range of biochemical genetic problems; and  
          the ability to communicate biochemical laboratory results  
          in the capacity of consultant to medical genetics  
          professionals and other clinicians, and directly to  
          patients in concert with other professional staff.

           Clinical Laboratories  .  According to DPH, there are  
          approximately 19,000 clinical laboratories in California,  
          3,000 of which are licensed laboratories performing  
          moderate and/or high complexity testing.  The remaining  
          12,000 are registered labs performing waived tests and/or  
          provider-performed microscopy.  California's clinical  
          laboratories are subject to both federal and state  
          oversight.  LFS within DPH provides licensing,  
          registration, and certification services to various  
          facilities including clinical laboratories, and the  
          personnel who perform professional pre-analytical,  
          analytical, and post-analytical testing services for these  







                                                                AB 549
                                                                Page  
          7

          facilities.  Additionally, there are certain requirements,  
          including education, training and examination for specified  
          clinical laboratory personnel, including a clinical  
          laboratory scientist, clinical histocompatibility scientist  
          or clinical laboratory directors.

          Federal CLIA requirements establish standards for  
          laboratories to ensure the accuracy, reliability, and  
          timeliness of patient test results, and specify numerous  
          quality standards, including those for facility  
          administration, personnel qualifications, quality control,  
          and proficiency testing, a process used by laboratories to  
          verify the accuracy and reliability of their test results.   
          CLIA standards apply to laboratory testing in all states,  
          and in all settings, including commercial, hospital, or  
          physician office laboratories.  CLIA standards are based on  
          the complexity of the testing (waived, moderate, or high  
          complexity).  To become certified under CLIA, a clinical  
          laboratory must pay applicable fees, meet all applicable  
          standards, and be surveyed biennially.  In California, DPH  
          is contracted by CMS to conduct the biennial CLIA survey on  
          behalf of the federal government.  CLIA fees are based on  
          the type of certification sought by a laboratory, and the  
          annual volume and types of testing performed.  

           State Auditor's Report  .  In 2008, the Bureau of State  
          Audits (BSA) published a report concluding that LFS had not  
          provided the clinical laboratory oversight mandated by  
          state law and regulations.  Major findings of the BSA  
          revealed that LFS was not inspecting laboratories every two  
          years, as required, inconsistently monitored laboratory  
          proficiency testing, closed many complaints without taking  
          action, sporadically imposed sanctions against laboratories  
          for violations, and, in three instances since fiscal year  
          2003-04, incorrectly adjusted licensing fees resulting in  
          more than $1,000,000 in lost revenue.  In light of these  
          findings, the Auditor proposed a number of recommendations  
          to leverage existing resources to improve oversight of  
          clinical laboratories, including a recommendation for DPH  
          to approve accrediting organizations to conduct clinical  
          laboratory inspections.  The Auditor stated in the report  
          that DPH had not approved any accreditation organizations  
          to perform such activities, and reported that LFS had  
          expressed concern over the quality of the inspections  







                                                                AB 549
                                                                Page  
          8

          conducted by accrediting organizations.  The Auditor  
          pointed out that LFS would need to approve accrediting  
          organizations and monitor their compliance, so LFS would  
          have the tools to address these concerns.  

          In response to the audit report, DPH generally concurred  
          with the Auditor's findings, and attributed much of its  
          inability to meet its mandated responsibilities to a lack  
          of staffing resources.  DPH stated that LFS would take  
          steps to determine how to maximize the use of existing  
          resources, as well as assess how many additional resources  
          would be needed.  DPH stated that licensing revenues would  
          likely be increased to cover costs associated with state  
          oversight mandates.  DPH also stated that it would explore  
          the use of accrediting organization inspectors to conduct  
          inspections for compliance with state law, and that it  
          would work with the appropriate parties to ensure that  
          clinical laboratory licensing fees are properly adjusted in  
          accordance with the Budget Act.  

          To address the funding shortage, which DPH argued resulted  
          in its inability to conduct inspections, investigate  
          complaints, promptly process licensure applications, and  
          take enforcement action when needed, DPH sponsored SB 744  
          (Strickland), Chapter 201, Statutes of 2009, to among other  
          things, modify the clinical laboratory licensing fee  
          structure, and facilitate the use of private accrediting  
          organizations to inspect clinical laboratories.  At that  
          time, DPH argued that by adjusting and imposing new fees  
          for facility and personnel licensure and certification,  
          charging for re-inspections of laboratories, fining for  
          delinquent laboratory license renewals, and charging fees  
          for licensure of multiple laboratory locations, would  
          provide additional resources for the laboratory oversight  
          program and address many of the problems raised by the BSA  
          audit.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  No

          According to the Senate Appropriations Committee: 

                          Fiscal Impact (in thousands)








                                                                AB 549
                                                                Page  
          9

           Major Provisions                2010-11     2011-12     
           2012-13   Fund  
          CDPH regulations         $110      $220      $155 Special*
            and licensing activities

          * Clinical Laboratory Improvement Fund

           SUPPORT  :   (Verified  8/17/10)

          City of Hope (source) 
          California Healthcare Institute
          Cedars Sinai Health System

           ARGUMENTS IN SUPPORT  :    the City of Hope, states in  
          support that, California faces a shortage of qualified  
          clinical laboratory scientists that could interpret and  
          communicate results to other professionals or to patients  
          in highly complex labs in specialized fields like genetics  
          and histocompatibility.  As a result of this shortage,  
          clinical labs have to outsource to laboratories in  
          neighboring states, which is adding additional cost and  
          delaying the results.  This is detrimental to cancer  
          centers like City of Hope that deal with life threatening  
          diseases and require fast processing and interpretations of  
          laboratory results.  Additionally, the City of Hope has  
          identified several barriers to licensing of highly  
          specialized clinical laboratory personnel, including  
          lengthy delays in the processing of applications by DPH,  
          and the lack of provision for the issuance of a temporary  
          license pending approval by DPH.  The City of Hope points  
          out that the state currently does not have any regulations  
          or licensing program for biochemical geneticists, and  
          although this is a relatively small field, it is a highly  
          complex category that needs regulation.  


           ASSEMBLY FLOOR  :  
          AYES: Adams, Ammiano, Arambula, Beall, Bill Berryhill, Tom  
            Berryhill, Blakeslee, Block, Blumenfield, Bradford,  
            Brownley, Buchanan, Caballero, Charles Calderon, Chesbro,  
            Conway, Cook, Coto, Davis, De La Torre, De Leon,  
            Emmerson, Eng, Evans, Feuer, Fletcher, Fong, Fuentes,  
            Fuller, Furutani, Galgiani, Garrick, Gilmore, Hagman,  
            Hayashi, Hernandez, Hill, Huber, Huffman, Jeffries,  







                                                                AB 549
                                                                Page  
          10

            Jones, Knight, Lieu, Logue, Bonnie Lowenthal, Ma,  
            Mendoza, Monning, Nava, Nestande, Niello, Nielsen, John  
            A. Perez, Portantino, Ruskin, Salas, Saldana, Silva,  
            Skinner, Smyth, Solorio, Audra Strickland, Swanson,  
            Torres, Torrico, Tran, Villines, Yamada
          NOES: Anderson, DeVore, Gaines, Harkey
          NO VOTE RECORDED: Carter, Hall, Miller, V. Manuel Perez,  
            Torlakson, Bass


          JA:nl  8/22/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

                                ****  END  ****