BILL ANALYSIS                                                                                                                                                                                                    �



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          ASSEMBLY THIRD READING
          AB 450 (Wieckowski)
          As Amended  May 2, 2011
          Majority vote 

           HIGHER EDUCATION    6-3         APPROPRIATIONS      12-5        
           
           ----------------------------------------------------------------- 
          |Ayes:|Block, Brownley, Fong,    |Ayes:|Fuentes, Blumenfield,     |
          |     |Galgiani, Lara,           |     |Bradford, Charles         |
          |     |Portantino                |     |Calderon, Campos, Davis,  |
          |     |                          |     |Gatto, Hall, Hill, Lara,  |
          |     |                          |     |Mitchell, Solorio         |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Donnelly, Achadjian,      |Nays:|Harkey, Donnelly,         |
          |     |Miller                    |     |Nielsen, Norby, Wagner    |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Requires the California State University (CSU) service 
          contractors to disclose and credit manufacturer rebates to CSU 
          campuses.  Specifically,  this bill  :  

          1)Provides that policies and procedures developed by the CSU 
            Trustees for the acquisition of services shall specify that 
            any direct or indirect rebates from a third party shall be 
            fully disclosed and credited to the campus or other unit of 
            the CSU, and be available for review as part of any audit, as 
            specified.

          2)Provides the CSU Trustees, in conjunction with the State 
            Controller (Controller), the right to examine, at reasonable 
            times and upon reasonable notice, the books, records and other 
            compilations of data of the services contractor that relate to 
            the provisions and requirements of all service contracts, 
            including records related to any rebates received by a 
            contractor from a third party as a consequence of, or 
            incidental to, a contract.  

          3)Defines "services contractor" to include those providing food, 
            janitorial, laundry, maintenance, window cleaning or landscape 
            services.

          4)Defines "rebate" to include any return of monetary value 








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            including, but not limited to, any volume discounts, 
            allowances, or discount purchase incentives. 

           EXISTING LAW  :

          1)Provides the CSU Trustees broad powers to establish policies 
            and procedures governing the acquisition of services, 
            facilities, materials, goods, supplies, or equipment.  
            Requires the policies to include a competitive means for 
            obtaining best value while complying with legislative intent 
            regarding competitive bids or proposals as expressed in the 
            California Public Contracts Code (Education Code �89036).  

          2)Authorizes the CSU Trustees to establish a process that allows 
            a campus to make payments directly to vendors and provides the 
            CSU Trustees authority to draw from appropriated funds  
            amounts necessary to make payments of obligations of the 
            university directly to vendors. Provides that payments in 
            excess of 10% of the fund total must be approved by the 
            Director of Finance (Government Code �12400.1).  

          3)Requires the CSU Trustees to contract with one or more public 
            accounting firms to conduct systemwide and individual campus 
            annual financial statement and compliance audits.  Requires 
            audits to test compliance with procurement procedures and the 
            integrity of the payments made (Government Code �12400.1).

          4)Requires every contract involving the expenditure of public 
            funds in excess of $10,000 by any public entity to be subject 
            to the examination and audit of the State Auditor for a period 
            of three years after final payment under the contract.  
            Requires every contract to contain a provision stating that 
            the contracting parties shall be subject to that examination 
            and audit (Government Code �8546.7).  
           
          FISCAL EFFECT  :  According to the Assembly Appropriations 
          Committee, to the extent the Controller conducts the authorized 
          audits of services contractors, CSU would be required to 
          reimburse the Controller for these services.  Based on previous 
          costs of Controller audits of vendor payments, conducting just 
          three audits in one year would cost $150,000.  The above costs 
          could be much more than offset by recovering of rebates.

           COMMENTS  :








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          Background  :  According to the sponsor, food manufacturers 
          commonly give rebates for purchases from large food service 
          companies such as Sodexo, Chartwells, and Aramark.  In 2010, 
          after significant controversy surrounding the amounts of those 
          rebates, the U.S. Department of Agriculture (USDA) enacted 
          regulations requiring contractors under the federally-subsidized 
          school meals program to disclose all discounts, rebates and 
          other applicable credits received by the contractor and to 
          credit those rebates back to the school.  The regulations are 
          designed to ensure that the limited school meals program 
          resources are used as efficiently as possible and that federal 
          agencies are only paying "net costs."  After concerns were 
          raised that large food service vendors were not returning all of 
          the rebates received, the New York Attorney General conducted an 
          investigation revealing that, over a five-year period beginning 
          in 2004, Sodexo received significant rebates from suppliers 
          without acknowledging or passing the savings on to these 
          schools-in violation of the contracts between Sodexo and the 
          schools as well as state and federal laws.  In July of 2010, 
          Sodexo agreed to pay New York $20 million to settle complaints.  
          While federal regulations are in place to prohibit contractors 
          from pocketing rebates from food manufacturers in California's 
          federally-subsidized K-12 district meals programs, there appears 
          to be no federal or state laws governing this practice in 
          California's higher education segments.  

           Purpose of this bill  :  According to the author, "There is no 
          specific law or policy in this area related to rebates nor are 
          there laws relating to the ability of the CSU Trustees or the 
          State Controller to examine a service contractor's books or 
          records to determine if the contractor is receiving off-invoice 
          rebates from its suppliers.  This bill will allow CSU to 
          determine if for example, food service companies are receiving 
          rebate payments for their food purchases on behalf of the 
          university and whether these rebate payments are being credited 
          back to the campus. The audit provisions will allow CSU to 
          discover if off-invoice rebates exist which may point to receipt 
          of rebates from suppliers to the contractor."
           

          Analysis Prepared by  :    Laura Metune / HIGHER ED. / (916) 
          319-3960 









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