BILL ANALYSIS                                                                                                                                                                                                    �






                                  SENATE HUMAN
                               SERVICES COMMITTEE
                            Senator Carol Liu, Chair


          BILL NO:       SB 897                                      
          S
          AUTHOR:        Leno                                        
          B
          VERSION:       March 31, 2011
          HEARING DATE:  April 12, 2011                              
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          FISCAL:        Appropriations                              
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          CONSULTANT:                                                
          Park
                                        

                                     SUBJECT
                                         
                  Residential care facilities for the elderly

                                     SUMMARY  


          Requires licensees of residential care facilities for the 
          elderly to notify the Department of Social Services, its 
          residents, and other parties within two business days of 
          specified events indicating financial distress.  Requires 
          the Department of Social Services to take discretionary 
          actions, upon notification of specified events.


                                     ABSTRACT  

          Existing law:


          1.Under the Residential Care Facilities for the Elderly 
            Act, provides for the licensure of residential care 
            facilities for the elderly (RCFEs) by the Department of 
            Social Services (DSS), Community Care Licensing Division 
            (CCL).

                                                         Continued---



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          2.Provides that any person who violates the Residential 
            Care Facilities for the Elderly Act, or who willfully or 
            repeatedly violates any rule or regulation adopted under 
            the Act, is guilty of a misdemeanor, with a fine not to 
            exceed one thousand dollars ($1,000), by imprisonment in 
            the county jail for up to a year, or by both the fine and 
            imprisonment.


          3.Provides broad authority for the director of DSS to take 
            enforcement action, including, but not limited to, 
            actions to suspend or revoke a license and to impose 
            civil penalties (generally between $25 to $50 per day, 
            but no greater than $150 per day) for violations of RCFE 
            statutes.


          4.Provides for a state long-term care ombudsman office 
            (including approved organizations) within the Department 
            of Aging to investigate and seek to resolve complaints 
            and concerns communicated by, or on behalf of, patients, 
            residents, or clients of any long-term care facility.

          This bill:


          1.Requires an RCFE licensee to notify DSS and the State 
            Long-Term Care Ombudsman, in writing or as specified, of 
            the following events within two business days of the 
            event or knowledge of the event:



             o    Failure to make one or more mortgage, lease, or 
               rental payments on the property within 30 days of the 
               due date.



             o    A provider of electricity, gas, or water services 
               has sent notice of intent to terminate a utility on 
               the property.






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             o    A financial institution refuses to honor a check or 
               other instrument issued by the licensee to its 
               employees for a regular payroll due to insufficient 
               funds.


          1.Requires an RCFE licensee to notify DSS, the State 
            Long-Term Care Ombudsman, all residents, and, if 
            applicable, their legal representatives, of the following 
            within two business days of the event or knowledge of the 
            event.


             o    Notice of default, trustee's sale, or any other 
               indication of foreclosure issued on the property.


             o    An unlawful detainer action initiated against the 
               licensee.


             o    Bankruptcy filing by the licensee.


          1.Requires RCFE licensees to notify all applicants for 
            potential residence, and if applicable, their legal 
            representatives, of these same events under 2) or 
            knowledge of those events, prior to admission.


           2.Allows  DSS to initiate a compliance plan, noncompliance 
            conference , or other appropriate action, upon notice of 
            the above in 1), but  requires  DSS to initiate a 
            compliance plan, noncompliance conference, or other 
            appropriate action upon notice of the above in 2).


          3.Authorizes civil penalties in the amount of $100 per day 
            for failure to provide the notifications required above, 
            not to exceed $2,000, and allows DSS to suspend or revoke 
            a license or permanently revoke a licensee's ability to 
            operate, or act as an administrator of, a facility 
            anywhere in the state, if a resident is relocated without 
            the notification required by the section and suffers 




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            transfer trauma or other harm to his or her health and 
            safety.


          4.Exempts RCFE licensees that have obtained a certificate 
            of authority to offer continuing care contracts from the 
            requirements above.


                                  FISCAL IMPACT  

          Unknown.

                            BACKGROUND AND DISCUSSION  

          Author's statement
          The author writes that current law fails to provide elderly 
          residents living in residential care facilities with 
          adequate notification to avoid harmful last-minute 
          evictions when a licensee suffers severe financial distress 
          or bankruptcy.  The author states that abrupt RCFE closures 
          due to financial distress are particularly traumatic for 
          the residents, who are often very physically frail or 
          suffer from Alzheimer's disease or other form of dementia.  
          The author notes that since the previous bill was 
          introduced (SB 1329, Leno, of 2010) more RCFE closures due 
          to financial distress have forced residents to scramble to 
          find a place to live and points to several examples.

          The author believes that the advance notice requirements in 
          the bill will give residents an opportunity to investigate 
          the stability of their placement and to explore other 
          housing options.  The author notes that, while CCL's 
          response to notifications is discretionary, early reports 
          of financial troubles will enable CCL to counsel facilities 
          through their crisis or at least minimize transfer trauma 
          to residents of the closing facility.  Finally, the author 
          believes that SB 897 will reduce the number of times CCL 
          will have to take over operations of an abruptly closed 
          RCFE.

          Residential care facilities for the elderly
          RCFEs are assisted living facilities for persons 60 years 
          of age and over and persons under 60 with compatible needs. 
          RCFEs, which may also be known as retirement homes or board 




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          and care homes, provide varying levels and intensities of 
          care and supervision, protective supervision, or personal 
          care, based upon residents' needs.  As of March 2011, there 
          were 7,662 licensed facilities in the state with a total 
          capacity of 170,061 residents.  According to DSS data from 
          2007, approximately three-quarters of RCFEs are licensed 
          for six or fewer residents; the remaining RCFEs have an 
          average licensed capacity of approximately 60 residents.

          RCFE foreclosures
          According to the Community Care Licensing division of DSS, 
          41 RCFEs were in foreclosure or had been foreclosed between 
          January 2009 and March 2010, out of 65 foreclosures of all 
          CCL-licensed facility types.  The California Advocates for 
          Nursing Home Reform, a co-sponsor of the bill, states that 
          of these, about half resulted in the building shutting 
          down.  According to DSS, RCFEs do not report any annual 
          financial information to CCL.

          Other sources indicate a much more widespread problem with 
          foreclosures.  An investigation undertaken by the New York 
          Times, published in April 2010, suggested that almost 16 
          percent of the Bay Area's 1,600 properties licensed as 
          small residential care homes had been at some stage of 
          foreclosure since June 2006 (although small residential 
          care homes may not correspond with the RCFE 
          classification), and that perhaps as many as 100 homes had 
          been under foreclosure within a six-month period.  
          Additionally, the San Mateo County ombudsman office 
          reported dealing with 16 foreclosure or bankruptcy cases 
          within a 16 month period, prior to June 2010. Notably, last 
          May (2010), the Press-Enterprise reported that a 102-bed 
          assisted living and respite care home in Hemet (Parkside 
          Gardens) was forced to close immediately following a staff 
          walk-out after the facility could not make payroll, 
          although DSS had been working with the facility managers 
          for more than six months after the report of a financial 
          default.

          According to the federal Administration on Aging's National 
          Ombudsman Reporting System, California reported a six-fold 
          increase in the number of complaints received for 
          "insufficient funds to operate" between 2006 and 2008, 
          increasing from 3 to 20 complaints.  It is worth noting, 
          however, that a high number of complaints in this category 




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          were noted for prior years (17 in 2003 and 25 in 2004).

          Governor's veto of SB 1329 of 2010
          As passed by this committee, SB 1329 of 2010 was broader in 
          scope than the current measure.  The version of SB 1329 
          that was vetoed by Governor Schwarzenegger was 
          substantially similar to SB 897, with the following 
          exceptions: 1) it requires licensees to notify the State 
          Long-Term Care Ombudsman, in addition to DSS for identical 
          events; and 2) it provides that the civil penalty for 
          failure to meet the notification requirements is 
          discretionary rather than mandatory.  The veto of SB 1329 
          reads:

                    I am returning Senate Bill 1329 without my 
                    signature.
                    While I appreciate the author's continued effort 
                    to improve
                    protections for residential care facilities, this 
                    bill would
                    represent a new unfunded workload and redirect 
                    scarce resources that
                    are currently dedicated to immediate health and 
                    safety issues.
                    For this reason, I am unable to sign this bill.

                    Sincerely,

                    Arnold Schwarzenegger

          Prior legislation
          SB 1329 (Leno) of 2010, was substantially similar to this 
          measure.  Would have required licensees of residential care 
          facilities for the elderly (RCFEs), with certain 
          exceptions, to notify the Department of Social Services 
          (DSS) and, in some instances, residents, applicants and 
          potential residents, of specified events, and would have 
          required DSS to initiate compliance plans, noncompliance 
          conferences, or other administrative actions upon receipt 
          of the notification.  Vetoed by Governor.

          SB 781 (Leno), Chapter 617, Statutes of 2009, requires a 
          residential care facility for the elderly to include 
          additional information when providing a notice of eviction 
          to a resident, including the reason for the eviction, the 




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          effective date of the eviction, and additional information 
          informing the resident of his/her rights regarding 
          evictions

          AB 407 (Beall), Chapter 442, Statutes of 2009 imposes 
          requirements on continuing care retirement communities in 
          the event of their permanent closure, including requiring 
          the continuing care retirement community to provide written 
          notice to DSS and to the affected residents or designated 
          representatives 120 days prior to the intended date of 
          closure of a continuing care retirement community.

          SB 1137 (Perata, Corbett, Machado), Chapter 69, Statutes of 
          2008, imposes requirements related to real estate 
          foreclosures, including requiring the holder of a mortgage 
          to mail a specified notice to the tenant(s) of a property 
          on which foreclosure proceedings have begun.

          AB 949 (Krekorian), Chapter 686, Statutes of 2007, 
          established procedures to be followed by a residential care 
          facility for the elderly prior to transferring a resident 
          to another facility or living arrangement as a result of 
          forfeiture of a license or change in the use of the 
          facility, and provides remedies for noncompliance.

          Arguments in support
          California Advocates for Nursing Home Reform (CANHR), a 
          co-sponsor of the measure, writes that reports of RCFE 
          properties in foreclosure or bankruptcy have surged.  CANHR 
          believes that the notification provided for in the bill 
          will ensure that residents will be better able to plan for 
          a possible move and avoid dangerous last-minute evictions.

          AARP writes that evaluating long-term care options and 
          making good decisions is difficult enough under normal 
          circumstances, but trying to make good decisions on short 
          notice is problematic.  AARP believes this measure will 
          provide DSS and residents an early warning of financial 
          distress so that DSS may take appropriate action and that 
          residents can consider whether to reevaluate their 
          continued residence.
           
           Bet Tzedek Legal Services, another co-sponsor, writes that 
          the foreclosure crisis is severely impacting housing for 
          California's RCFE residents, and that, increasingly, RCFE 




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          owners are losing their homes and residents are being 
          forced to move with little or no notice.  Bet Tzedek points 
          out that such residents are more vulnerable to emotional 
          and physical trauma and placement in facilities that cannot 
          meet their care.  Bet Tzedek writes that notice to RCFE 
          residents will enable them to assert legal challenges to 
          involuntary relocations and give them additional time to 
          prepare for possible transfer to a new facility.


                                     COMMENTS
           
          1.Is the State Long-Term Care Ombudsman the right dual 
            reporting entity?  The author may wish to consider 
            whether a local long-term care ombudsman office might not 
            be better able to intervene.  Does the author intend for 
            the state office to respond directly, or to pass along 
            information to the local offices?

          2.Penalties exist in current law. 
             a.   Currently, DSS already has authority to issue civil 
               penalties in varying amounts, generally between $25 to 
               $50 per day, and even up to $150 per day, and beyond 
               if certain conditions are met.  Is it the author's 
               intent to give DSS less flexibility in applying a 
               particular amount of penalty, e.g., applying a civil 
               penalty of $25 a day, rather than $100 a day, or 
               preventing providers from accumulating a penalty of 
               more than $2,000 total?

             b.   DSS currently has the ability to suspend or revoke 
               a license, or permanently exclude persons from 
               obtaining a license.  It is unclear how the bill's 
               current discretionary language on suspension, 
               revocation, or permanent revocation varies from the 
               authority in current law.


                                    POSITIONS  

          Support:  Bet Tzedek Legal Services (co-sponsor) 
                    California Advocates for Nursing Home Reform 
               (co-sponsor)
                    California Senior Legislature (co-sponsor)
                    AARP California




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                    California Long Term Care Ombudsman Association
                    Professional Fiduciary Association of California
                    Ombudsman Services of Northern California
                    Ombudsman Services of San Mateo County

          Oppose:None received

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