BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                  SB 1377|
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                                 THIRD READING


          Bill No:  SB 1377
          Author:   Corbett (D)
          Amended:  4/19/12
          Vote:     21

           
           SENATE JUDICIARY COMMITTEE  :  5-0, 4/17/12
          AYES:  Evans, Harman, Blakeslee, Corbett, Leno

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8


           SUBJECT  :    Protection and advocacy agencies

           SOURCE  :     Disability Rights California


           DIGEST  :    This bill specifies that a protection and 
          advocacy (P&A) agency's authority to access information and 
          records of persons with disabilities, as otherwise 
          specified, shall include access to specified unredacted 
          records.  With respect to persons with developmental 
          disabilities or mental health disabilities, this bill 
          specifies that permissible disclosures of confidential 
          information or records shall also include disclosure to the 
          P&A agency to the extent that the information is contained 
          in specified unredacted records.  This bill also provides 
          that the confidentiality of any information obtained as 
          such must be maintained by the P&A agency.  Additionally, 
          this bill changes various references to the Department of 
          Health Care Services to the Department of Public Health 
          (DPH) and deletes a reference to a section of the 
          California Code of Regulations.  
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           ANALYSIS  :    Existing federal law mandates the creation and 
          maintenance of a P&A system in each state, for the purpose 
          of investigating allegations of abuse or neglect of several 
          classes of disabled persons:  the developmentally disabled, 
          the mentally ill, and other disabled persons that qualify 
          for the services provided by the system.  (Protection and 
          Advocacy for Developmental Disabilities Act �PADD Act], 42 
          United States Code �U.S.C.] 15041 et seq.; Protection and 
          Advocacy for Individuals with Mental Illness Act �PAIMI 
          Act], 42 U.S.C. 10801 et seq.; and Protection and Advocacy 
          of Individual Rights Act, 29 U.S.C. 794e.)  The 
          establishment of a P&A system is required for a state to 
          receive federal funding for services provided to the 
          specified disabled persons. 

          Existing law provides that an independent private, 
          nonprofit corporation designated by the Governor, shall act 
          as the P&A agency for the state, and requires that agency 
          meet all requirements of federal law applicable to P&A 
          systems for people with disabilities.  (Welfare and 
          Institutions Code �WIC] Section 4901) 

          Existing law defines "disability" as a developmental 
          disability, as defined in the federal PADD Act, a mental 
          illness, as defined in the federal PAIMI Act, or a 
          disability as defined under the federal Americans with 
          Disabilities Act of 1990, or as defined under the 
          California Fair Employment and Housing Act.  (WIC Section 
          4900(a)(d))

          Existing law specifies the authorities of the P&A agency, 
          pursuant to its federal mandate, including the authority to 
          investigate any incident of abuse or neglect of any person 
          with a disability if the incident is reported to the P&A 
          agency or if the P&A determines there is probable cause to 
          believe the abuse or neglect occurred.  Among other things, 
          existing law provides that this investigatory authority 
          shall include reasonable access to a facility or program 
          and authority to examine all relevant records and interview 
          any facility or program service recipient, employee, or 
          other person who might have knowledge of the alleged abuse 
          or neglect.  (WIC Section 4902(a)(1))   


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          Existing law requires that the P&A agency have access to 
          the records of a person with disabilities where specified 
          circumstances exist.  (WIC Section 4903(a))  

          Existing law provides that the P&A agency shall have access 
          to various individual records, whether written or in 
          another medium, draft or final, including, but not limited 
          to, handwritten notes, electronic files, photographs, 
          videotapes, or audiotapes.  Such individual records 
          include, but are not limited to, specified records relating 
          to the provision of services, reports of investigations of 
          specified claims including their supporting documents, as 
          well as any discharge records.  (WIC Section 
          4903(b)(1)-(3))  

          Existing law also otherwise lists the types of information 
          in the possession of a program, facility, or service that 
          must be available to the agency investigating instances of 
          abuse or neglect, as specified.  (WIC Section 4903(c))  
           
          Existing law requires that the P&A agency be given access 
          to the records of specified individuals, and other records 
          that are relevant to conducting an investigation of 
          potential instances of abuse or neglect with respect to 
          specified persons with disabilities not later than three 
          business days after the agency makes a written request.  
          Existing law requires that immediate access be granted not 
          later than 24 hours after the P&A agency makes a request, 
          without consent from another party, in specified 
          circumstances, if the agency determines there is probable 
          cause to believe that the health or safety of the 
          individual is in serious and immediate jeopardy, or in a 
          case of death of an individual with a disability.  (WIC 
          Section 4903(e))

          Existing law requires that confidential information kept or 
          obtained by the P&A agency remain confidential and 
          prohibits that information from being subject to 
          disclosure, except that the P&A agency shall not be 
          prevented from, among other things, issuing a public report 
          of the results of an investigation that maintains the 
          individual service recipients' confidentiality or reporting 
          the investigation results to responsible agencies should an 
          investigation reveal information warranting possible 

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          sanctions or corrective action, as specified.  (WIC Section 
          4903(f))

          Existing law requires the P&A agency to inform and train 
          employees as appropriate regarding the confidentiality of 
          client records.  (WIC Section 4903(g))  

          This bill provides that the authority provided under (b) of 
          Section 4903 above, shall include access to the following 
          unredacted records:  a citation report, licensing report, 
          survey report, plan of correction, or statement of 
          deficiency prepared by a department responsible for issuing 
          a license or certificate to a program, facility, or service 
          serving an individual with a disability.

          Existing law requires that, notwithstanding the section 
          above, information and records be disclosed, as specified, 
          to the P&A agency designated by the Governor in this state 
          to fulfill the requirements and assurances of the federal 
          PADD Act for the P&A of the rights of persons with 
          developmental disabilities, as defined (42 U.S.C. Section 
          15002(8)).  (WIC Section 4514.3(a))

          Existing law requires that all information and records 
          obtained in the course of providing intake, assessment, and 
          service, as specified, to persons with developmental 
          disabilities be held confidential, and that information and 
          records obtained in the course of providing similar 
          services to either voluntary or involuntary recipients 
          prior to 1969 shall also be confidential, except that such 
          information and records shall be disclosed in specified 
          cases.  (WIC Section 4514(a)-(u))  

          This bill adds to the enumerated exceptions to Section 4514 
          above, that the information and records otherwise subject 
          to the confidentiality requirements of Section 4514 shall 
          also be disclosed to the P&A agency to the extent that the 
          information is incorporated within an unredacted citation 
          report, unredacted licensing report, unredacted survey 
          report, unredacted plan of correction, or unredacted 
          statement of deficiency prepared by an authorized licensing 
          personnel or authorized representatives described, as 
          specified.


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          This bill provides that the information obtained in those 
          records is subject to the confidentiality requirements of 
          Section 4903(f) of the WIC. 

          This bill replaces several references to Department of 
          Health Care Services with the Department of Public Health.  


          This bill deletes a reference to Section 56557 of Title 17 
          of the California Code of Regulations. 

          Existing law provides that, notwithstanding Section 5328 of 
          the WIC, information and records shall be disclosed to the 
          P&A agency established in this state to fulfill the 
          requirements and assurances of the federal PAIMI Act of 
          1991, for the P&A of the rights of people with mental 
          disabilities, including people with mental health 
          disabilities, as defined (42 U.S.C. Section 19802(4)).  
          (WIC Section 5328.06)  

          Existing law provides that all information and records 
          obtained in the course of providing specified services to 
          either voluntary or involuntary recipients of community 
          mental health services shall be confidential, except that 
          information and records may be disclosed, notwithstanding 
          any other provision of law, as specified.  (WIC Section 
          5328.15(a)-(b))  
          This bill adds to the enumerated exceptions to Section 
          5328.15 above, that the information and records otherwise 
          subject to the confidentiality requirements of Section 
          5328.15 shall also be disclosed to the P&A agency to the 
          extent that the information is contained in an unredacted 
          version of any of the following:  a citation report, 
          licensing report, survey report, plan of correction, or 
          statement of deficiency prepared by an authorized licensing 
          personnel or authorized representatives described, as 
          specified.

          This bill provides that the information obtained in those 
          records is subject to the confidentiality requirements of 
          Section 4903(f) of the WIC.

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

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           SUPPORT  :   (Verified  5/8/12)

          Disability Rights California (source)
          California Advocates for Nursing Home Reform
          California Association of Public Authorities
          California Association of State Hospital Parent Councils 
          for the Retarded
          Consumer Attorneys of California
          Disability Rights Education and Defense Fund
          Epilepsy California
          The Arc
          United Cerebral Palsy

           ARGUMENTS IN SUPPORT  :    According to the author, "SB 1377 
          would clarify a protection and advocacy agency's right to 
          review reports of abuse and neglect of individuals with 
          development and mental health disabilities without having 
          to make a separate assertion of probable cause in each 
          case."  

          The author further explains the need for such clarification 
          as follows: 

            Federally mandated protection and advocacy agencies such 
            as Disability Rights California (DRC) are charged with 
            protecting and advocating for the rights of persons with 
            disabilities.  In order to fulfill this function, federal 
            law grants protection and advocacy �P&A] agencies the 
            right to access reports prepared by state agencies that 
            investigate reports of abuse, neglect, injury or death of 
            persons with disabilities and perform certification or 
            licensing reviews.  

            In the past, the Department of Public Health (DPH) 
            provided such reports to DRC in complete and unredacted 
            form.  However, in 2009 the DPH changed this policy for 
            two special populations of vulnerable individuals with 
            disabilities-people with developmental disabilities and 
            people with mental health disabilities.  Citing state 
            privacy laws governing the records of persons with 
            developmental disabilities (W&I Code Sec. 4514) and 
            mental health disabilities (W&I Code Sec. 5328), DPH 
            began forwarding to DRC redacted records with all 

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            relevant information about cases involving individuals 
            with either a developmental disability or mental health 
            disability blacked out.  Under DPH's policy, DRC upon 
            receipt of the redacted report must then submit an 
            individual written request to receive an unredacted 
            record for the case.  For cases involving people with all 
            other disabilities, DRC continued to receive reports from 
            DPH in the usual unredacted for.  

            This extra step is unnecessary and unwarranted.  
            California law (W&I Code Sec. 4903) already requires the 
            P&A agencies to maintain the confidentiality of this 
            information and the right to P&A's to access this 
            information is not in dispute.  Requiring this extra 
            layer of bureaucratic process creates a significant time 
            lag that often extends months before DRC receives the 
            unredacted report.  In some cases the wait has been 
            almost a year.  This delay can jeopardize the well-being 
            of the individuals involved.  In addition, the 
            requirement creates more administrative work and 
            unnecessary costs for the State.


          RJG:kc  5/8/12   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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