BILL ANALYSIS                                                                                                                                                                                                    



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          SENATE THIRD READING
          SB 313 (DeSaulnier)
          As Amended  August 24, 2009
          Majority vote 

           SENATE VOTE  :39-0  
           
           INSURANCE           10-0        APPROPRIATIONS      17-0        
           
           ----------------------------------------------------------------- 
          |Ayes:|Solorio, Garrick,         |Ayes:|De Leon, Conway, Ammiano, |
          |     |Anderson, Charles         |     |                          |
          |     |Calderon, Carter, Feuer,  |     |Charles Calderon, Coto,   |
          |     |Hayashi, Nava, Niello,    |     |Davis, Duvall, Fuentes,   |
          |     |Torres                    |     |Hall, Harkey, Miller,     |
          |     |                          |     |John A. Perez, Skinner,   |
          |     |                          |     |Solorio, Audra            |
          |     |                          |     |Strickland, Torlakson,    |
          |     |                          |     |Hill                      |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :   Restructures the laws governing penalties to be  
          assessed on employers that do not comply with the law mandating  
          that every employer provide, either through insurance or an  
          approved self-insurance program, workers' compensation benefits  
          for its employees.  Specifically,  this bill  :   

          1)Increases from $1,000 to $1,500 per employee the penalty  
            amount that shall be assessed against an employer that is  
            violating the mandate to provide workers' compensation  
            coverage, and clarifies that the penalty formula described in  
            2) below, is alternative to this potential penalty.

          2)Provides that instead of the current formula, the penalty to  
            be imposed on an employer for failing to provide workers'  
            compensation coverage for its employees shall be the product  
            of the employer's payroll for the three years prior to the  
            date the penalty assessment is issued and a rate to be adopted  
            by the Labor Commissioner, or, if no rate is adopted, the  
            manual rate or rates used by the State Compensation Insurance  
            Fund for the employers governing classification as defined by  
            the standard classification system approved by the Insurance  








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            Commissioner (IC).

          3)Specifies that the classification shall be determined by the  
            inspector at the time the assessment is issued based on the  
            information available at the time, and presumes subject to  
            subsequent rebuttal by the employer that the wage level for  
            the uninsured employees was equal to the state average weekly  
            wage.

          4)Specifies that any additional moneys collected from violators  
            as a result of the changes to the penalty structure made by  
            this bill shall be deposited into the Uninsured Employers  
            Benefits Trust Fund (UEBTF) - which is the fund that pays for  
            benefits for employees injured while working for uninsured  
            employers -- and used only for non-administrative expenses  
            upon appropriation by the Legislature.

           



          EXISTING LAW :

          1)Requires every employer, except the state, to secure the  
            payment of workers' compensation for employees for injuries  
            arising out of, or in the course of, employment, either by  
            purchasing insurance from a qualified workers' compensation  
            insurer, or by obtaining a certificate of self-insurance from  
            the Office of Self-Insurance Programs in the Department of  
            Industrial Relations (DIR).

          2)Specifies that the Director of the California Employment  
            Development Department (EDD)  shall  issue and serve a penalty  
            assessment order of $1,000 per employee on an employer that is  
            found to be without workers' compensation coverage and on whom  
            a stop-work order has been imposed due to the lack of  
            coverage.  The penalty moneys are deposited in the UEBFT,  
            which is funded by an employer assessment plus the fines and  
            penalties.

          3)Provides that at any time the Director of EDD determines that  
            an employer has been uninsured for a period in excess of one  
            week during the calendar year preceding the director's  
            determination, the director  may  issue and serve a penalty  








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            assessment order that requires the uninsured employer to pay a  
            penalty that is the greater of:  a) twice the amount the  
            employer would have paid in workers' compensation premiums  
            during the period the employer was uninsured; or, b) the sum  
            of $1,000 per employee employed during the period the employer  
            was uninsured.  This penalty shall be in lieu of, and not in  
            addition to any other penalty imposed under the section of law  
            described in number 2) above.

          4)Provides that if the employer is currently insured, or becomes  
            insured during the period during which the above penalty is  
            being determined, the amount an employer would have paid in  
            workers' compensation premiums shall be calculated by  
            prorating the current premium for the number of weeks the  
            employer was uninsured.

          5)Provides that if the employer is uninsured at the time the  
            above penalty is being determined, the amount an employer  
            would have paid in workers' compensation premiums shall be  
            calculated by applying the rating for that type/class of  
            worker as determined by the Workers' Compensation Insurance  
            Rating Bureau and the IC to the number of weeks the employer  
            was uninsured.

           FISCAL EFFECT  :   According to the Assembly Appropriations  
          Committee :

          1)Under current law $4.5 million in penalty assessments were  
            collected in 2008.  Therefore, this bill increases the  
            collection of these penalties by more than $2.2 million  
            special fund attributable to the 50% increase in the per  
            employee penalty from $1,000 to $1,500. 

          2)This bill results in additional, unknown special fund revenues  
            to the extent the alternative penalty calculation modified in  
            this bill is levied.  A core component of the alternative  
            penalty is twice the amount the employer would have paid to  
            have been insured during the prior three-year period. 


           


          COMMENTS  :   








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           1)Purpose  .  According to the author, modernizing the penalty  
            structure will have a deterrent effect on uninsured employers.  
             Currently, it is very difficult to calculate the proper  
            penalty for an uninsured employer because it is difficult to  
            determine how many, and what kind of, employees were working  
            for the employer over the three-year period.  In addition,  
            there is a conflict between the two provisions detailing  
            penalties that the bill clarifies by making the more detailed  
            penalty formula an alternative to the flat "per employee"  
            penalty.

           2)Support  .  Supporters argue that the current penalty structure  
            often results in penalties that are lower than what the cost  
            of obtaining insurance would have been.  Thus, there is little  
            incentive to comply with the law if the penalties for  
            violations are lower than the cost of compliance.  Supporters  
            further note that depositing penalty moneys into the UEBFT  
            will reduce the burden on law-abiding employers.

           
          Analysis prepared by:   Mark Rakich / INS. / (916) 319-2086


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