BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2570
                                                                  Page  1

          Date of Hearing:   April 21, 2010

                     ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
                                Sandre Swanson, Chair
                   AB 2570 (Ma) - As Introduced:  February 19, 2010
           
          SUBJECT  :   Professional employer organizations: regulation.

           SUMMARY  :   Establishes specified regulatory requirements for  
          professional employer organizations (PEOs).  Specifically,  this  
          bill  :

          1 Provides that a person or entity shall not provide, advertise  
            or otherwise hold itself out as providing professional  
            employer services unless that entity or person is registered  
            as a PEO with the Employment Development Department (EDD).

          2)Requires the Director of EDD to prescribe rules establishing  
            the method for PEOs to report quarterly wages and  
            contributions for worksite employees and states the following:

             a)   The rules shall recognize the PEO as the employing unit  
               of its worksite employees for reporting purposes but may  
               require that each worksite employee of a single client by  
               reported under a separate and unique EDD subaccount of the  
               PEO to reflect the experience f the worksite employees for  
               a client.

             b)   Any EDD subaccount shall be used solely to determine  
               experience rates for that individual subaccount on an  
               annual basis.

             c)   Any rule promulgated shall also include administrative  
               requirements that permit a PEO to transmit the reporting  
               and payment date required collectively as a single  
               electronic filing with EDD.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   This bill represents the latest in a series of bills  
          sponsored by the PEO industry seeking to amend California law to  
          adequately reflect and regulate the PEO industry.

          According to the industry, PEOs are companies that allow their  
          small business clients to cost-effectively outsource the  








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          management of human resources, employee benefits and health  
          insurance.  In a PEO arrangement, the employer's (or client's)  
          responsibilities for its worksite employees are expressly  
          allocated or shared pursuant to a written agreement between the  
          client and the PEO.  In such arrangements, the PEO typically  
          assumes responsibility for such things as payroll, payment of  
          payroll-related taxes, workers' compensation, unemployment  
          insurance, healthcare coverage and similar employment benefits.

          According to the industry, such arrangements allow the business  
          owner to concentrate on managing their business, while  
          contracting out their human resources department.  They also  
          contend that PEOs implement efficiencies to lower employment  
          costs.  In many arrangements, economies of scale allowing the  
          PEO to act as a large purchaser can provide employees with an  
          expanded benefits package including life insurance, 401(k)  
          plans, disability insurance, discount plans, flexible spending  
          plans and more.
          However, for several years the industry has argued that a  
          regulatory vacuum exists in California law with respect to PEOs.  
           Under existing law, Unemployment Insurance Code section 606.5  
          defines a "temporary services employer" and a "leasing employer"  
          as an employing unit that contracts with clients or customers to  
          supply workers and performs all of the following functions:

             (1)   Negotiates with clients or customers for such matters  
               as time, place, type of work, working conditions, quality,  
               and price of the services.

             (2)   Determines assignments or reassignments of workers,  
               even though workers retain the right to refuse specific  
               assignments.

             (3)   Retains the authority to assign or reassign a worker to  
               other clients or customers when a worker is determined  
               unacceptable by a specific client or customer.

             (4)   Assigns or reassigns the worker to perform services for  
               a client or customer.

             (5)   Sets the rate of pay of the worker, whether or not  
               through negotiation.

             (6)   Pays the worker from its own account or accounts.









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             (7)   Retains the right to hire and terminate workers.

          According to the industry, PEOs have historically been  
          recognized by EDD as a "leasing employer" as defined under  
          Unemployment Insurance Code section 606.5.  However, they  
          contend that both the PEO industry and EDD have recognized for  
          some time that the statutory definition of a PEO as a leasing  
          employer does not accurately reflect the business model of the  
          industry or the exposure to the state under the Unemployment  
          Insurance Code.  The industry states that it has been working  
          with EDD for several years to discuss ways to better clarify  
          PEOs under the current unemployment insurance statutory model to  
          address both of these issues.  These discussions have focused on  
          ensuring that the code evolves in a positive way to adequately  
          protect workers in the state and strengthen the integrity and  
          solvency of the unemployment insurance system.

          In recent years, the industry has also discussed these issues  
          with representatives of organized labor, who have expressed a  
          number of concerns about the business model.  However, those  
          discussions have not yet resulted in a legislative agreement.

          Most recently, the industry has approached EDD and had  
          discussions about developing a process for PEOs to report  
          unemployment insurance contributions on a subaccount level.  The  
          industry contends that this approach would address concerns  
          raised in the past about employers entering PEO arrangements in  
          order to reduce or "wash" their unemployment insurance  
          experience rating.

          The industry indicates that they would like for this bill to  
          move forward as those discussions continue with EDD and as they  
          engage in further discussions with other interested  
          stakeholders, including organized labor.



           PRIOR LEGISLATION  :

          AB 1560 (Committee on Labor and Employment) from last year  
          provided that an entity providing or advertising professional  
          employer services be registered with EDD.  The bill was moved  
          forward as a vehicle for discussion but was held in the Assembly  
          Appropriations Committee.









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          AB 2975 (Keene) from 2008 stated the intent of the Legislature  
          that professional employer organizations (PEOs) be regulated  
          with respect to unemployment insurance obligations, as  
          specified.  The bill was moved forward as a vehicle for  
          discussion but was held in the Assembly Appropriations  
          Committee.

          AB 2891 (Frommer) from 2004 stated the intent of the Legislature  
          that professional employer organizations (PEOs) be properly  
          recognized and regulated.  The bill was moved forward as a  
          vehicle for discussions to take place with representatives of  
          organized labor and the Department of Industrial Relations, but  
          these provisions were subsequently amended out of the bill.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          National Association of Professional Employer Organizations

           Opposition 
           
          None on file.

           
          Analysis Prepared by  :    Ben Ebbink / L. & E. / (916) 319-2091