BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                  SB 1407|
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                                 THIRD READING


          Bill No:  SB 1407
          Author:   Leno (D)
          Amended:  4/30/12
          Vote:     21

           
           SENATE JUDICIARY COMMITTEE  :  5-0, 5/8/12
          AYES:  Evans, Harman, Blakeslee, Corbett, Leno

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8


           SUBJECT  :    Medical information:  disclosure

           SOURCE  :     Author


           DIGEST  :    This bill prohibits a psychotherapist from 
          disclosing mental health records or information based 
          solely on an authorization signed by a parent or guardian 
          of that minor if the minor has been removed from the 
          physical custody of that parent or guardian in dependency 
          proceedings for severe abuse or neglect or risk of abuse, 
          unless the court has issued an order authorizing the parent 
          or guardian to be the minor's representative for the 
          release of such information, upon finding that it would not 
          be detrimental to the minor patient.  This bill creates an 
          exception for written mental health records maintained in 
          electronic or physical form by hospitals, as specified, or 
          for an oral disclosure of information.

           ANALYSIS  :    Existing federal law, the Health Insurance 
          Portability and Accountability Act (HIPPA), specifies 
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          privacy protections for patients' protected health 
          information and generally provides that a covered entity, 
          as defined, may not use or disclose protected health 
          information except as specified or as authorized by the 
          patient in writing.  (45 Code of Federal Regulations 
          Section 164.500 et seq.)  

          Existing law defines "medical information" to mean any 
          individually identifiable information, in electronic or 
          physical form, in possession of or derived from a provider 
          of health care, health care service plan, pharmaceutical 
          company, or contractor regarding a patient's medical 
          history, mental or physical condition, or treatment.  
          Existing law defines "individually identifiable" to mean 
          that the medical information includes or contains any 
          element of personal identifying information sufficient to 
          allow identification of the individual, such as the 
          patient's name, address, electronic mail address, telephone 
          number, or social security number, or other information 
          that, alone or in combination with other publicly available 
          information, reveals the individual's identity.  (Civil 
          Code (CIV) Section 56.05(g))

          Existing law prohibits a health care provider, health care 
          service plan, or contractor from disclosing medical 
          information regarding a patient, enrollee, or subscriber 
          without first obtaining an authorization, except as 
          specified.  (CIV Section 56.10(a).)  Valid authorizations 
          comply with HIPPA and Confidentiality of Medical 
          Information Act (CMIA).  (CIV Section 56.11) 

          Existing law provides that a health care provider may 
          disclose health information to another health care provider 
          for diagnosis and treatment purposes without a signed 
          authorization.  (CIV Section 56.10(c)(1))

          Existing law authorizes minors, 12 years of age and older, 
          to consent to mental health treatment or counseling 
          services if, in the opinion of the attending professional 
          person, the minor is mature enough to participate 
          intelligently in the mental health treatment or counseling 
          services.  (Health and Safety Code (HSC) Section 124260)

          Existing law provides that an adult patient of a health 

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          care provider, any minor patient authorized by law to 
          consent to medical treatment, and any patient 
          representative shall be entitled to inspect the patient's 
          records upon presenting to the health care provider a 
          written request for those records and upon payment of 
          reasonable clerical costs incurred in locating and making 
          the records available.  (HSC Section 123110)

          Existing law provides that representatives are not entitled 
          to inspect or obtain copies of a minor patient's medical 
          records if the minor has a right to consent to the medical 
          care or where the health care provider determines that 
          access to the records would have a detrimental effect on 
          the provider's professional relationship with the minor or 
          the minor's physical safety or psychological well-being.  
          (HSC Section 123115(a)(2))

          Existing law provides that a plaintiff may bring an action 
          against any person or entity who has negligently released 
          his or her confidential information or records in violation 
          of the CMIA as follows:

            nominal damages of $1,000; and 
            the amount of actual damages.  (CIV Section 56.36(b))

          Existing law provides that a minor may be removed from the 
          physical custody of his or her parents for serious abuse or 
          neglect, or risk of serious abuse or neglect.  (Welfare and 
          Institutions Code Section 300)

          This bill provides that a psychotherapist shall not release 
          mental health records of a minor patient or disclose the 
          information therein based solely on an authorization to 
          release those records signed by the parent or guardian if 
          that child has been removed from the custody of the parent 
          in dependency proceedings, unless authorized to do so in a 
          court order, issued upon the finding that the order would 
          not be detrimental to the minor patient. 

          This bill provides that the above prohibition does not 
          apply to a written mental health record maintained by a 
          general acute care hospital, an acute psychiatric hospital, 
          or a special hospital, as defined. 
           

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          This bill provides that the above prohibition does not 
          apply to oral disclosures made to family members directly 
          related to that person's involvement with the care or 
          related to payment for the care, pursuant to CIV Section 
          56.1007.

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

           SUPPORT  :   (Verified  5/22/12)

          California Academy of Child and Adolescent Psychiatry
          Children's Advocacy Institute of San Diego Law School
          Children's Partnership
          Court Appointed Special Advocates 
          East Bay Children's Law Offices
          Junior Leagues of California
          Legal Advocates for Children and Youth
          Mental Health Association of San Francisco
          National Association of Social Workers
          Privacy Rights Clearinghouse
          University of San Diego School of Law's Children's Advocacy 
          Institute

           OPPOSITION  :    (Verified  5/22/12)

          Executive Committee of the Family Law Section of the State 
          Bar of California

           ARGUMENTS IN SUPPORT  :    In support of this bill, the 
          author writes: 

            California law allows parents whose children have been 
            removed because of abuse, abandonment, or neglect to 
            access their children's mental health information, 
            subject to some discretion by the therapist.  However, a 
            noncustodial parent may not be acting in their child's 
            best interests when authorizing use of the child's mental 
            health treatment information, and may use this 
            confidential information to further their own legal 
            purposes, undermining the child's stated wishes or best 
            interests. 

            Children who lose trust in the confidentiality of their 

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            communications may be unwilling to trust future 
            therapists, social workers or counselors.  Treatment of a 
            child who has experienced abuse or neglect requires a 
            sense of trust, autonomy, and personal boundaries.

           ARGUMENTS IN OPPOSITION  :    The Executive Committee of the 
          Family Law Section of the State Bar of California (FLEXCOM) 
          opposes this bill, unless it is amended.  FLEXCOM writes 
          that it "would withdraw its opposition if the bill were 
          amended to place the burden on the child welfare or other 
          counsel to show, by clear and convincing evidence, that the 
          parent or guardian's continued access to or ability to 
          authorize the release of mental health information is 
          detrimental to the child, while family reunification 
          services are being provided."  FLEXCOM argues that this 
          would better reflect the dependency system's policy to 
          support family reunification.  
           

          RJG:kc  5/22/12   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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