BILL ANALYSIS                                                                                                                                                                                                    �



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          SENATE THIRD READING
          SB 408 (Ed Hernandez)
          As Amended August 30, 2011
          Majority vote

           SENATE VOTE  :25-15  
           
           HEALTH              13-6        APPROPRIATIONS      12-5        
           
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          |Ayes:|Monning, Ammiano, Atkins, |Ayes:|Fuentes, Blumenfield,     |
          |     |Bonilla, Eng, Gordon,     |     |Bradford, Charles         |
          |     |Hayashi,                  |     |Calderon, Campos, Davis,  |
          |     |Roger Hern�ndez, Bonnie   |     |Gatto, Hall, Hill, Lara,  |
          |     |Lowenthal, Mitchell, Pan, |     |Mitchell, Solorio         |
          |     |V. Manuel P�rez, Williams |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Logue, Garrick, Mansoor,  |Nays:|Harkey, Donnelly,         |
          |     |Nestande, Silva, Smyth    |     |Nielsen, Norby, Wagner    |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Requires a new health facility license application to 
          be filed for a health facility, as defined, when there is a 
          change of ownership, as defined, or a major change in ownership 
          interest, as defined.  Requires a prescribed notice to be filed 
          with the Department of Public Health (DPH) prior to a change of 
          ownership, major change in ownership interest, or a change in 
          control interest, as defined, of certain health facilities.  
          Specifically,  this bill  :  

          1)Defines "change of ownership" to mean any of the following:

             a)   For a partnership, the removal, addition, or 
               substitution of a partner, unless the partners expressly 
               agree otherwise, as permitted by state law;

             b)   For an unincorporated sole proprietorship, the transfer 
               of title and property to another person;

             c)   For a corporation, the merger of the licensee's 
               corporation into another corporation, or the consolidation 
               of two or more corporations, resulting in the creation of a 
               new corporation.  Specifies that the transfer of corporate 








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               stock or the merger of another corporation into the 
               applicant's or provider's corporation does not constitute a 
               change of ownership; or,

             d)   For a lease, the lease of all or part of the licensee's 
               facility constitutes a change in ownership of the leased 
               portion.

          2)Defines "major change in ownership interest" to mean a 
            transaction where any of the following occurs:

             a)   A sale, transfer, lease, exchange, conveyance, or other 
               disposal of a limited partnership interest, corporate 
               shares, or limited liability company interest representing 
               at least 50% of all ownership interests in a general acute 
               care hospital, acute psychiatric hospital, or special 
               hospital or in the current licensee, including the final 
               transfer or assignment of multiple transfers over a 10-year 
               period that cumulatively total at least 50% of ownership 
               interests;
             b)   The merger of an entity that owns or operates a general 
               acute care hospital, acute psychiatric hospital, or special 
               hospital that does not result in a change in the taxpayer 
               identification number of the licensee;

             c)   For a limited liability company, the merger of the 
               applicant's or provider's limited liability company into 
               another limited liability company, or the consolidation of 
               two or more limited liability companies, resulting in the 
               creation of a new limited liability company.  Clarifies 
               that the transfer of limited liability company interest or 
               the merger of another limited liability company into the 
               licensee's limited liability company does not constitute a 
               change of ownership; or,

             d)   For any unincorporated sole proprietorship, corporation, 
               limited liability company, partnership, lessee, nonprofit 
               corporation, or any other entity that operates or controls 
               a general acute care hospital, acute psychiatric hospital 
               or special hospital, a substitution of a new corporate 
               member or member of the governing body, or any arrangement, 
               written or oral, that would transfer voting control of, or 
               responsibility for, or governance of, that general acute 
               care hospital, acute psychiatric hospital or special 








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               hospital.  

          3)Defines "change in control interest" to mean a transaction 
            where any of the following, except a "change of ownership" or 
            "major change in ownership interest" occurs:

             a)   A sale, transfer, lease, exchange, conveyance, or other 
               disposal of any partnership, limited partnership interest, 
               corporate shares, or limited liability company interest 
               representing at least 10% of all ownership interest in a 
               general acute care hospital, acute psychiatric hospital, or 
               special hospital, or in the licensee, but that represents 
               less than 50% of the ownership interests in the health 
               facility or licensee;

             b)   A change in any member of the governing body or 
               principal officers of a general acute care hospital, 
               psychiatric hospital, or special hospital; or,

             c)   Any transaction that affects more than 10% of the value 
               of a general acute care hospital, acute psychiatric 
               hospital, or special hospital that are operated or 
               controlled by the licensee.

          4)Requires a new license application for a general acute care 
            hospital, psychiatric hospital, skilled nursing facility, 
            intermediate care facility, or special hospital to be filed 
            before there is an anticipated change of ownership.  Prohibits 
            a change of ownership from occurring until DPH approves the 
            license application and issues a new license.

          5)Requires a new license application for general acute care 
            hospital, psychiatric hospital, or special hospital be filed 
            before there is a major change in ownership interest in the 
            health facility.  Prohibits a major change in ownership 
            interest until DPH approves the license application and issues 
            a new license.

          6)Requires a notice of change to be filed with DPH, at least 90 
            days prior to an anticipated change of ownership, a major 
            change in ownership interest or change in control interest in 
            a general acute care hospital, psychiatric hospital, or 
            special hospital.  Requires that a new license application be 
            filed with the notice if the transaction is a change in 








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            ownership or a major change in ownership interest.  Requires 
            the licensee to notify DPH of the change on a form provided by 
            DPH, if the transaction is a change in control interest. 

          7)Requires DPH, within 10 days of the receipt of notice 
            referenced in 6) above, to post receipt of the notice on DPH's 
            Web site.

          8)Permits DPH, with regard to a transaction that is a change in 
            control interest, within 90 days of the notice referenced in 
            6) above, to require a new license application to be filed, or 
            withhold approval of the transaction, if DPH has a reason to 
            believe, based on past compliance history, that any person or 
            entity whose control interests in the facility or facilities 
            operated or controlled by the licensee are affected by the 
            transaction, has not complied with state or federal laws or 
            regulations, or is under investigation for any alleged 
            violation of state or federal laws or regulations.

          9)Permits DPH, if a licensee of a specified health facility 
            fails to comply with in this bill, to assess the licensee an 
            administrative penalty in an amount not to exceed $25,000 per 
            violation.  Permits the licensee, if the licensee disputes a 
            determination by DPH regarding the alleged violation, within 
            10 days of receipt of the penalty assessment, request a 
            hearing pursuant to existing law.  Requires administrative 
            penalties to be paid when appeals have been exhausted and the 
            penalty has been upheld.  Requires all administrative 
            penalties collected by DPH to be deposited in the Internal 
            Department Quality Improvement Account of the Special Deposit 
            Fund created under existing law.

          10)Requires DPH, in enforcing the provisions of this bill, to 
            take into consideration the special circumstances of small and 
            rural hospitals in order to protect access to quality care in 
            those hospitals.

          11)Permits DPH to implement the provisions of this bill by means 
            of all facility letters, or similar instructions, without 
            taking further regulatory action.

           EXISTING LAW  :

          1)Provides for the licensing and regulation of health 








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            facilities, including general acute care hospitals, acute 
            psychiatric hospitals, and special hospitals by DPH.

          2)Requires any person desiring a license for a health facility, 
            or approval to manage a health facility, to file an 
            application with DPH, and to provide evidence that they are of 
            reputable and responsible character and have the ability to 
            comply with statutory and regulatory requirements applicable 
            to health facilities.

          3)Requires, under DPH regulations, a new owner of a health 
            facility to submit a license application and pay an 
            application fee when a change of ownership occurs.  Although 
            the term "change of ownership" is not defined in regulations 
            governing general acute care hospitals, it is interpreted by 
            DPH to mean when a new legal entity assumes responsibility for 
            the operation of the hospital.

          4)Requires, under the Attorney General's (AG's) administration 
            of charitable trust laws, a nonprofit corporation that 
            operates or controls a health facility to obtain the consent 
            of the AG prior to entering into any agreement or transaction 
            to:
             a)   Sell, transfer, lease, exchange, option, convey, or 
               otherwise dispose of, a material amount of its assets to 
               either a for-profit or nonprofit entity; or,

             b)   Transfer control, responsibility, or governance of a 
               material amount of the assets or operations of the 
               nonprofit corporation to a for-profit or nonprofit entity.

           FISCAL EFFECT  :  According to the Assembly Appropriations 
          Committee, this bill would trigger an unknown number of 
          additional new hospital licensure applications.  Assuming a new 
          hospital licensure application is required in 10% of the cases 
          of licensure-related changes that are reported to the DPH, this 
          bill would result in increased costs to DPH of approximately 
          $150,000 (special fund) annually to process the applications.  
          According to the Assembly Appropriations Committee, this bill 
          will all result in potential unknown increases in penalty 
          revenue to DPH from administrative penalties assessed for 
          failure to comply with this bill's provisions.

           COMMENTS  :  According to the author, this bill closes a loophole 








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          in hospital licensing laws to ensure that when a hospital 
          changes ownership or when day-to-day operations of a health 
          facility are handed over to a new individual or entity, the new 
          owner must obtain a license to operate the facility.  The author 
          asserts that the licensing process through DPH is designed to 
          ensure that those operating a health facility in the state are 
          decent and have a history of complying with the law.  According 
          to the author, a recent example of where the loophole was 
          employed to avoid the licensing process was Prime's acquisition 
          of Alvarado Hospital from Plymouth Health, LLC (Plymouth) in 
          November 2010.  The author is concerned that the acquisition of 
          Alvarado Hospital by Prime, the largest for-profit hospital 
          system in California, could serve as a blueprint for other 
          operators to acquire hospitals and avoid California's licensing 
          process.  The author states this bill is intended to ensure that 
          individuals or entities acquiring hospitals must adhere to the 
          state's transfer of ownership laws regardless of the manner in 
          which the hospital was acquired.


           Analysis Prepared by  :  Tanya Robinson-Taylor / HEALTH / (916) 
          319-2097 


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