BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                   SB 678|
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                                 THIRD READING


          Bill No:  SB 678
          Author:   Negrete McLeod (D)
          Amended:  5/27/11
          Vote:     21

           
           SENATE PUBLIC SAFETY COMMITTEE  :  4-2, 5/3/11
          AYES:  Anderson, Calderon, Harman, Price
          NOES:  Hancock, Liu
          NO VOTE RECORDED:  Steinberg


           SUBJECT  :    Community corrections multidisciplinary teams

           SOURCE  :     Chief Probation Officers of California


           DIGEST  :    This bill (1) authorizes counties to convene 
          "community corrections multidisciplinary teams," as 
          defined, for purposes of providing "evidence-based 
          practices," as defined, and supervision; (2) requires that 
          every member of a community corrections multidisciplinary 
          team (MDT)  who receives "nonprivileged information", as 
          defined, or writings be under the same privacy and 
          confidentiality obligations and subject to the same 
          penalties for violating those obligations as the person 
          disclosing or providing the information or writings; (3) 
          requires that the information obtained be maintained in a 
          manner that ensures the protection of confidentiality; and 
          (4) requires that its provisions not be construed to 
          independently authorize access to, or possession of, 
          information from local, state, or federal information 
          systems or databases that MDT members are authorized to 
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          access or possess in the course of their duties.

           Senate Floor Amendments  of 5/27/11 (1) provide that the 
          bill relates to all information shared by MDT members, not 
          just nonprivileged information; (2) require MDTs to 
          maintain informed consent policies, as specified; and (3) 
          require memorandums of understanding between participating 
          members and agencies regarding the types of information 
          that may be shared and for what purposes.

           ANALYSIS  :    Existing law authorizes the members of MDTs 
          engaged in the prevention, identification, and control of 
          juvenile crime to share certain information with each 
          other, as specified.

          This bill authorizes counties to convene "community 
          corrections multidisciplinary teams" for purposes of 
          providing evidence-based practices and supervision and 
          evidenced-based rehabilitation programs, as specified.  
          This bill requires each community corrections MDT to 
          maintain an informed consent policy in order to authorize 
          the sharing of confidential, privileged, or protected 
          information among members of the team, as specified.  This 
          bill additionally requires the county probation officer in 
          each county utilizing a community corrections MDT to 
          develop and implement a memorandum of understanding between 
          the agencies participating in the community corrections MDT 
          that includes, among other things, a description of the 
          types of information and writings that may be shared 
          between team members. 
          
          This bill provides that every member of a community 
          corrections MDT who receives nonprivileged information or 
          writings shall be under the same privacy and 
          confidentiality obligations and subject to the same 
          penalties for violating those obligations as the person 
          disclosing or providing the information or writings.  The 
          information obtained shall be maintained in a manner that 
          ensures the protection of confidentiality.

          This bill defines, "nonprivileged information" as any 
          information not subject to a privilege pursuant to Division 
          8 (commencing with Section 900) of the Evidence Code.








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          This bill defines, "community corrections" as the placement 
          of persons convicted of a felony offense under probation 
          supervision, with conditions imposed by a court for a 
          specified period.

          This bill defines, "multidisciplinary team" as any team of 
          three or more persons, the members of which are engaged in 
          providing community corrections supervision, treatment, and 
          services.  The team may include, but is not limited to:

           Probation officers.
           Police officers, sheriffs' deputies, and other law 
            enforcement officers.
           Social workers.
           Health and mental health providers.
           Substance abuse treatment providers.
           Education professionals.
           Employment coordinators.
           Representatives from community-based organizations with 
            experience in successfully providing rehabilitative 
            services.

          This bill defines "evidence-based practices" as supervision 
          policies, procedures, programs, and practices demonstrated 
          by scientific research to reduce recidivism among 
          individuals under probation, parole or postrelease 
          supervision.

          This bill states that its provisions shall not be construed 
          to independently authorize access to, or possession of, 
          information from local, state, or federal information 
          systems or databases that MDT members are authorized to 
          access or possess in the course of their duties.

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

           SUPPORT  :   (Verified  5/31/11)

          Chief Probation Officers of California (source)
          California Mental Health Directors Association
          California Probation, Parole and Correctional Association
          California State Association of Counties








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           OPPOSITION  :    (Verified  5/31/11)

          American Civil Liberties Union
          California Public Defenders Association

           ARGUMENTS IN SUPPORT  :    A fact sheet provided by the 
          author's office describes the following purposes for this 
          bill:

           Clarify - The probation officer's authority to develop 
            and implement community corrections programs that 
            incorporate MDT �multidisciplinary teams] teams.  
            (Current state authorizes juvenile justice, child abuse 
            and mental health MDT's, but does address MDTs adult 
            probationers.)     

           Ensure that members of a probation MDT can be held to the 
            same level of confidentiality and to the same level of 
            consequences for failure to maintain confidentiality as 
            probation employees are.  For example, not disclose to 
            unauthorized persons an offender's status as a 
            probationer, without the permission of the probationer.

           Ensure that if employees of probation who come into 
            possession of confidential information from other 
            participants in the MDT the probation employees can be 
            held the same level of confidentiality as the original 
            processor of that information.  For example: confidential 
            information contained in an Addiction Severity assessment 
            administer by a substance abuse provider.

           As to the consent issue, Court opinions have consistently 
            found a grant of adult probation requiring the consent of 
            the offender.  Once a person accept adult probation, the 
            probation officer has the authority to determine level 
            and type of supervision consistent with the court ordered 
            conditions of probation.  Probationers have the right to 
            challenge the level and type of supervision based on 
            whether it is consistent with the conditions of 
            probation.  In addition probationers have certain 
            confidentiality rights, the most basic being the 
            confidentiality of his/her status as a probationer. 
            Therefore, probation obtains both the consent of the 
            probationer to participated programs, as well as consents 







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            from probationer for release of information from 
            treatment providers.  This legislation is intended to 
            preserve those rights.

          The California Mental Health Directors Association states:  
          "County mental health departments in many counties actively 
          participate in local multidisciplinary teams and other 
          collaborative efforts for serving local criminal justice 
          populations, a significant number of whom have serious 
          mental health disorders.  As the devolution of 
          responsibility for criminal justice and other health and 
          human services continues to move from the state to the 
          counties, it will be increasingly critical that 
          multidisciplinary team members have the authorization to 
          share information with one another in order to ensure that 
          service providers can meet the holistic needs of 
          probationers in a timely and effective manner."

           ARGUMENTS IN OPPOSITION  :    The American Civil Liberties 
          Union states:

            "Current law already permits community corrections 
            personnel access to confidential information about the 
            student or family with either the consent of the 
            individual or where authorized under the terms of 
            probation.  The California Constitution provides that all 
            people have inalienable rights, including the right to 
            pursue and obtain privacy. (Cal.Const. art. I, sec.1).  
            In addition, California's Confidentiality of Medical 
            Information Act (CMIA) (California Civil Code Section 
            56.10 (a)) and the federal Health Insurance Portability 
            and Accountability Act of 1996 (HIPAA) generally prohibit 
            health care providers from disclosing medical information 
            about patients or subscribers without first obtaining 
            authorization.  And, the California Department of Justice 
            carefully guards the confidentiality of criminal justice 
            databases. 

            "SB 678 would allow health and mental health providers, 
            social workers, and probation officers among others to 
            communicate confidential "non privileged" information 
            about a probationer or his or her family without first 
            obtaining consent.  California only allows seizures that 
            interfere with fundamental privacy rights with a showing 







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            of compelling interest.  White v. Davis, 13 Cal. 3d 757, 
            775 (1974)  (holding the privacy right prohibits the 
            disclosure of personal information unless justified by a 
            compelling interest), Hill v. National Collegiate 
            Athletic Assn., 7 Cal. 4th 1, 34 (1994) (holding a 
            'compelling interest must be present to overcome the 
            vital privacy interest').  

            "In addition, the Court has held that California 
            Constitution requires that there be no other less 
            intrusive means of serving the party's interest before 
            medical records can be discovered.  American Academy of 
            Pediatrics v. Lungren, 16 Cal. 4th 307, 341 (1997) 
            (discovery of private medical records is allowed only if 
            the discovering party's interest 'cannot be served by 
            alternative means less intrusive on fundamental rights').

            "While we have asked for evidence of the 'need' for this 
            legislation, we have not been provided that information.  
            Nor have we been provided with information that this 
            community corrections approach actually works and that it 
            is necessary to share individual's private information 
            without their consent.  We are concerned that the goal of 
            rehabilitation will actually be undermined by the 
            non-consensual sharing of participant's information."

          RJG:mw  5/31/11   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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