BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                   SB 744|
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                              UNFINISHED BUSINESS


          Bill No:  SB 744
          Author:   Strickland (R)
          Amended:  7/14/09
          Vote:     27 - Urgency

           
           SENATE HEALTH COMMITTEE  :  11-0, 4/15/09
          AYES: Alquist, Strickland, Aanestad, Cedillo, Cox,  
            DeSaulnier, Leno, Maldonado, Negrete McLeod, Pavley, Wolk

           SENATE BUSINESS, PROF. & ECON. DEVELOP. COMM.  :  6-1,  
            4/27/09
          AYES:  Wyland, Aanestad, Oropeza, Romero, Walters, Yee
          NOES:  Correa
          NO VOTE RECORDED:  Negrete McLeod, Corbett, Florez

           SENATE APPROPRIATIONS COMMITTEE  :  13-0, 5/26/09
          AYES:  Kehoe, Cox, Corbett, Denham, DeSaulnier, Hancock,  
            Leno, Oropeza, Runner, Walters, Wolk, Wyland, Yee

           SENATE FLOOR  :  39-0, 6/1/09
          AYES:  Aanestad, Alquist, Ashburn, Benoit, Calderon,  
            Cedillo, Cogdill, Corbett, Correa, Cox, Denham,  
            DeSaulnier, Ducheny, Dutton, Florez, Hancock, Harman,  
            Hollingsworth, Huff, Kehoe, Leno, Liu, Lowenthal,  
            Maldonado, Negrete McLeod, Oropeza, Padilla, Pavley,  
            Romero, Runner, Simitian, Steinberg, Strickland, Walters,  
            Wiggins, Wolk, Wright, Wyland, Yee

           ASSEMBLY FLOOR  :  70-3, 9/2/09 - See last page for vote


           SUBJECT  :    Clinical laboratories:  public health  
                                                           CONTINUED





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          laboratories

           SOURCE  :     Department of Public Health


           DIGEST  :    This bill revises licensing and certification  
          requirements for clinical laboratories by recognizing  
          accreditation of clinical laboratories by private,  
          nonprofit organizations (PNOs), as specified, revises  
          license fees according to the number of tests performed,  
          and makes other administrative changes

           Assembly Amendments delete the requirement for PNOs provide  
          the Department of Health Services (DHS) procedures for  
          making proficiency testing information available upon  
          request of any person, delete the requirement for PNOs to  
          agrees to permit the Department to conduct random  
          inspections of clinical laboratories accredited by it in  
          order to validate compliance with California law, and  
          require DHS to begin accepting applications for  
          certificates of deemed status, in a form and manner  
          prescribed by DHS, by January 1, 2011.

           ANALYSIS  :    

          Existing law:

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

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

          3. Requires a clinical laboratory that performs tests that  
             are of moderate or high complexity to be licensed by  
             DPH.  Requires a clinical laboratory that performs tests  







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             that are of low complexity, also referred to as "waived  
             tests," or that perform provider-performed microscopy  
             (PPM), which is microscopic analysis of a specimen by a  
             health care provider such as a physician, to be  
             registered, rather than licensed, by DPH, and requires a  
             laboratory that operates multiple locations, to obtain a  
             separate license or registration for each laboratory  
             location.

          4. 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.

          5. Allows the DPH to certify a clinical laboratory that is  
             accredited by a private, nonprofit organization as  
             having met state licensure or registration requirements,  
             provided that the accrediting organization is federally  
             approved under CLIA, has accreditation standards that  
             are equal to, or more stringent than, state licensure  
             and registration requirements, and allows DPH to  
             randomly inspect its accredited clinical laboratories  
             for compliance with state law.  Specifies certification  
             requirements for accredited laboratories, including  
             allowing the accrediting organization to provide any  
             records or other information about the laboratory  
             required by DPH.  

          6. Requires clinical laboratories to pay fees, as  
             specified, to DPH for the purposes of initial and  
             renewal licensure, registration, or certification.

          7. Establishes the Clinical Laboratory Improvement Fund  
             (CLIF), 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.

          8. Requires the services of a public health laboratory to  
             be available to city or county local public health  
             departments for the purpose of examining suspected cases  
             of infectious and environmental diseases, and to assist  
             in community disease surveillance.  Requires any city or  







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             county public health laboratory, and specified personnel  
             to be approved by DPH, and to comply with all applicable  
             CLIA requirements.  Under existing law, public health  
             laboratories are exempt from licensure and certification  
             fees.

          9. Requires an unlicensed person employed by a clinical  
             laboratory whose job is to withdraw blood from a patient  
             to be certified as a phlebotomy technician.  Existing  
             law requires an individual seeking phlebotomy technician  
             certification to pay a fee of $25 to DPH upon initial  
             application and annual renewal.

          This bill:

           1.   Requires the State Department of Health Services  
               (DHS) to issue a certificate of deemed status to  
               laboratories accredited by PNOs that they deem meet  
               state licensure or registration requirements, provided  
               that the following conditions are met: 

               A.     The PNO meets all of the following  
                 requirements: 

                      (i)              Is approved by the federal  
                           Center for Medicare and Medicaid Services  
                           as an accreditation body under the federal  
                           Clinical Laboratory Improvement Amendments  
                           of 1988 (CLIA) and provides the Department  
                           with the following information: 

                         (1)                 A detailed comparison of  
                           the individual accreditation or approval  
                           requirements, with the comparable  
                           condition-level requirements; 

                         (2)                 A detailed description  
                           of its inspection process, including all  
                           of the following: 

                                 a.                       Frequency  
                                   of inspections; 
                                 b.                       Copies of  
                                   inspection forms; 







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                                 c.                        
                                   Instructions and guidelines; 
                                 d.                       A  
                                   description of the review and decision  
                                   making process of inspections; 
                                 e.                       A statement  
                                   concerning whether inspections are  
                                   announced or unannounced; and, 
                                 f.                       A  
                                   description of the steps taken to monitor  
                                   the correction of deficiencies. 

                         (3)                 A description of the  
                           process for monitoring proficiency testing  
                           performance, including action to be taken  
                           in response to unsuccessful participation;  
                           and, 

                         (4)                 A list of all of its  
                           current California licensed or registered  
                           laboratories and the expiration date of  
                           their accreditation, licensure, or  
                           registration, as applicable. 

                    (ii)           Is approved by DHS as having  
                         accreditation standards that are equal to,  
                         or more stringent than, state requirements  
                         for licensure and registration; 

                    (iii)              Conducts inspections of  
                         clinical laboratories in a manner that will  
                         determine compliance with federal standards  
                         and California laws to the extent that  
                         California laws provide greater protection  
                         to residents, or are more stringent than  
                         federal standards, as determined by DHS.  
                         Permits DHS to, without taking regulatory  
                         action, implement or interpret this section  
                         by means of an All Clinical Laboratories  
                         Letter (ACLL), as specified. 

                    (iv)           Is approved by DHS as meeting the  
                         requirements of this bill. Requires DHS to  
                         begin accepting applications for approval,  







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                         in a form and manner prescribed by DHS, by  
                         January 1, 2011. Requires DHS to make a  
                         determination on an application submitted  
                         pursuant to this subparagraph within 180  
                         days of receiving the application. 

               B.     The laboratory meets all of the following  
                 requirements: 

                    (i)            Meets the accreditation standards  
                         of the PNO; 

                    (ii)           Agrees to permit the PNO to  
                         provide any records or other information to  
                         DHS, its agents, or contractors, as DHS may  
                         require; 

                    (iii)              Pays fees, as specified; 

                    (iv)           Authorizes its proficiency testing  
                         organization to furnish to DHS and the PNO  
                         the results of the laboratory's  
                         participation in an approved proficiency  
                         testing program, as specified, for the  
                         purpose of monitoring the laboratory's  
                         proficiency testing, along with explanatory  
                         information needed to interpret the  
                         proficiency testing results, upon request of  
                         DHS; 

                    (v)            Authorizes the PNO to release to  
                         DHS a notification of every violation of  
                         condition-level requirements, including the  
                         actions taken by the organization as a  
                         result of the violation, within 30 days of  
                         the initiation of the action; and, 

                    (vi)           Authorizes the PNO to give notice  
                         to DHS of any withdrawal of the laboratory's  
                         accreditation. 

           2.   States that if the PNO has withdrawn or revoked its  
               accreditation of a laboratory, the laboratory shall  
               retain its certificate of deemed status for 45 days  







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               after it receives notice of the withdrawal or  
               revocation of the accreditation, or the effective date  
               of any action taken by DHS, whichever is earlier. 

           3.   Requires a certificate of deemed status issued to be  
               renewed annually provided that the conditions for  
               issuance are still met. Except as otherwise  
               authorized, DHS shall not conduct routine inspections  
               of a laboratory issued a certificate of deemed status.  
               Each application for a certificate of deemed status  
               and each request for renewal of that certificate shall  
               be accompanied by fees, as specified. 

           4.   Requires the total of the certificate application and  
               renewal fees collected by DHS to be sufficient to  
               cover the cost of issuing the certificate. If DHS  
               determines that those certificate fees do not fully  
               support the costs of these activities, it shall report  
               that determination to the Legislature. 

           5.   Specifies that this bill should not be construed to  
               prohibit the exercise of DHS's authority to conduct  
               complaint investigations, sample validation  
               inspections, or require submission of proficiency  
               testing results to DHS to ensure compliance of any  
               clinical laboratory with state standards. 

           6.   Requires DHS to charge fees for the application and  
               renewal of the certificate of no more than $100 for a  
               two-year period. 

           7.   Requires a clinical laboratory applying for a license  
               to perform tests or examinations classified as of  
               moderate or of high complexity under CLIA and a  
               clinical laboratory applying for certification to pay  
               an application fee for that license or certification  
               based on the number of tests it performs or expects to  
               perform in a year, as follows: 

                  A.        Fewer than 2,001 tests: $270; 
                  B.        Between 2,001 and 10,000, inclusive,  
                    tests: $820; 
                  C.        Between 10,001 and 25,000, inclusive,  
                    tests: $1,315; 







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                  D.        Between 25,001 and 50,000, inclusive,  
                    tests: $1,580; 
                  E.        Between 50,001 and 75,000, inclusive,  
                    tests: $1,960; 
                  F.        Between 75,001 and 100,000, inclusive,  
                    tests: $2,340; 
                  G.        Between 100,001 and 500,000, inclusive,  
                    tests: $2,740; 
                  H.        Between 500,001 and 1,000,000, inclusive,  
                    tests: $4,910; and, 
                  I.        More than 1,000,000 tests: $5,260, plus  
                    $350 for every 500,000 tests over 1,000,000, up  
                    to a maximum of 15,000,000 tests. 

           8.   Requires a clinical laboratory performing tests or  
               examinations classified as of moderate or of high  
               complexity under CLIA and a clinical laboratory with a  
               certificate as described above to pay an annual  
               renewal fee based on the number of tests it performed  
               in the preceding calendar year, as follows: 

                  A.        Fewer than 2,001 tests: $170; 
                  B.        Between 2,001 and 10,000, inclusive,  
                    tests: $720; 
                  C.        Between 10,001 and 25,000, inclusive,  
                    tests: $1,115; 
                  D.        Between 25,001 and 50,000, inclusive,  
                    tests: $1,380; 
                  E.        Between 50,001 and 75,000, inclusive,  
                    tests: $1,760; 
                  F.        Between 75,001 and 100,000, inclusive,  
                    tests: $2,040; 
                  G.        Between 100,001 and 500,000, inclusive,  
                    tests: $2,440; 
                  H.        Between 500,001 and 1,000,000, inclusive,  
                    tests: $4,610; and, 
                  I.        More than 1,000,000 tests per year:  
                    $4,960, plus $350 for every 500,000 tests over  
                    1,000,000, up to a maximum of 15,000,000 tests. 

           9.   States that the personnel licensing delinquency fee  
               is equal to the annual renewal fee. 

           10.  Requires a clinical laboratory subject to  







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               registration, as specified, and performing only those  
               clinical laboratory tests or examinations considered  
               waived under CLIA to pay an annual fee of $100. 

           11.  Requires a clinical laboratory subject to  
               registration, as specified, and performing only  
               provider-performed microscopy, as defined under CLIA,  
               to pay an annual fee of $150. 

           12.  Requires a clinical laboratory performing both waived  
               and provider-performed microscopy to pay an annual  
               registration fee of $150. 

           13.  Requires the costs of DHS to conduct any  
               reinspections to ensure compliance of a laboratory  
               applying for initial licensure to be paid by the  
               laboratory. This additional cost for each visit shall  
               be equal to the initial application fee and shall be  
               paid by the laboratory prior to issuance of a license.  
               DHS shall not charge a reinspection fee if the  
               reinspection is due to error or omission on the part  
               of DHS. 

           14.  Requires a fee of $25 to be assessed for approval of  
               each additional authorized location. 

           15.  Requires DHS, by July 1, 2013, to report to the  
               Legislature during the annual legislative budget  
               hearing process the extent to which the state  
               oversight program meets or exceeds federal oversight  
               standards and the extent to which the federal  
               Department of Health and Human Services is accepting  
               exemption applications and the potential cost to the  
               state for an exemption. 

           16.  Prohibits the total fees collected under this chapter  
               from exceeding the costs incurred by DHS for  
               licensing, certification, inspection, or other  
               activities relating to the regulation of clinical  
               laboratories and their personnel. 

           17.  Requires the annual renewal fee for a clinical  
               laboratory license or registration to be paid during  
               the 30-day period before the expiration date of the  







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               license or registration. 

           18.  Requires that if the license or registration is not  
               renewed before the expiration date, the licensee or  
               registrant, as a condition precedent to renewal, must  
               pay a delinquency fee equal to 25% of the annual  
               renewal fee for up to 60 days after the expiration  
               date, in addition to the annual renewal fee in effect  
               on the last preceding regular renewal date. Failure to  
               pay the annual renewal fee in advance during the time  
               the license or registration remains in force shall  
               result in the forfeiture of the license or  
               registration after a period of 60 days from the  
               expiration date of the license or registration. 

           19.  Requires all fees and interest to be deposited and  
               maintained in the Clinical Laboratory Improvement Fund  
               (CLIF) and to be used for the purpose of administering  
               the regulation of clinical laboratories only, as  
               specified. 

           20.  Adds an urgency statute, stating that in order to  
               protect the public health by providing strong clinical  
               laboratory oversight as soon as possible, it is  
               necessary that this bill take effect immediately. 

           21.  Makes legislative findings and declarations. 

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

          According to the Senate Appropriations Committee:

                          Fiscal Impact (in thousands)

           Major Provisions               2009-10     2010-11     
           2011-12   Fund  

          Clinical laboratory                     ($3,000)   
          ($5,000)($5,000)Special*
            licensing, registration,
            and laboratory staff
            fee revenue








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          *Clinical Laboratory Improvement Fund

           SUPPORT  :   (Verified  9/3/09)

          California Department of Public Health (source)
          Blood Centers of California
          California Association of Public Health Laboratory  
          Directors

           ARGUMENTS IN SUPPORT  :    According to the DPH, the Sponsor  
          of this bill, DPH is currently unable to adequately enforce  
          state laws and regulations regarding licensing,  
          certification and registration of clinical laboratories,  
          because of insufficient funding.  DPH points out that this  
          funding shortage has resulted in an inability for LFS to  
          conduct inspections, investigate complaints, promptly  
          process licensure applications, and take enforcement action  
          when needed.  It states that the provisions in this bill  
          will help address this problem, 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.  DPH also indicates that in order to improve LFS  
          inspection activities, this bill implements a  
          recommendation by the California State Auditor to leverage  
          accrediting organizations for the purposes of clinical  
          laboratory inspections.  A strong clinical laboratory  
          oversight program is necessary to protect public health,  
          and that this bill provides additional resources for the  
          laboratory oversight program within DPH.


           ASSEMBLY FLOOR  :  
          AYES: Adams, Ammiano, Arambula, Beall, Bill Berryhill,  
            Blakeslee, Block, Blumenfield, Brownley, Caballero,  
            Charles Calderon, Carter, Chesbro, Conway, Cook, Coto,  
            Davis, De La Torre, De Leon, DeVore, Emmerson, Eng,  
            Evans, Feuer, Fletcher, Fong, Fuentes, Fuller, Furutani,  
                    Gaines, Galgiani, Garrick, Gilmore, Harkey, Hayashi,  
            Hernandez, Hill, Huber, Huffman, Jeffries, Jones,  
            Krekorian, Lieu, Bonnie Lowenthal, Ma, Mendoza, Monning,  
            Nava, Nestande, Niello, Nielsen, John A. Perez, V. Manuel  
            Perez, Portantino, Ruskin, Salas, Saldana, Silva,  







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            Skinner, Smyth, Solorio, Audra Strickland, Swanson,  
            Torlakson, Torres, Torrico, Tran, Villines, Yamada, Bass
          NOES: Anderson, Tom Berryhill, Knight
          NO VOTE RECORDED: Buchanan, Duvall, Hagman, Hall, Logue,  
            Miller,  


          CTW:do  9/3/09   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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