BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1816
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          Date of Hearing:   April 30, 2014

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                  Mike Gatto, Chair

                    AB 1816 (Yamada) - As Amended:  April 7, 2014 

          Policy Committee:                              HealthVote:19-0

          Urgency:     No                   State Mandated Local Program:  
          No     Reimbursable:              No

           SUMMARY  

          This bill requires the Department of Public Health (DPH) to  
          complete investigations of complaints in long-term care  
          facilities within 40 working days from receipt of the complaint,  
          and allows extension of this time frame under specified  
          circumstances.  It also requires DPH to:

          1)Provide additional information about the investigation to the  
            complainant, if investigations take longer than 40 working  
            days.

          2)Analyze and report on its compliance with these time frames.

          3)Provide specific findings concerning each alleged violation,  
            and include in the findings a summary of the evidence upon  
            which the determination was made.

          4)Apply the time frames established by the bill to facility  
            self-reports.

           FISCAL EFFECT  

          1)Additional staff costs of up to $18.5 million annually to DPH  
            to meet the tighter time frames for completion of  
            investigations (Licensing and Certification (L&C) Fund, paid  
            for by facility licensing fees).  Of this amount, up to $1.2  
            million is attributable to state-run facilities, whose  
            licensure fees are paid for with GF dollars.  This additional  
            cost represents a 10% increase in total funding for the L&C  
            program.

          2)Additional minor costs to DPH to expand notification pursuant  








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            to the bill's requirements. 

          COMMENTS  

           1)Purpose  . According to the author, timely investigations are  
            critical to reduce risk by identifying and acting to protect  
            dependent adults from dangerous situations.  The author  
            indicates DPH struggles to meet its workload demands and often  
            does not complete investigations of complaints in a timely  
            manner.  This bill is intended to address this issue by  
            establishing a 40-day limit on the length of an investigation,  
            with allowable extensions for difficult conditions.

           2)Background  .  Existing law requires DPH Licensing and  
            Certification (L&C) division to issue state licenses and to  
            certify a number of facility types meet federal requirements  
            for participation in Medicare and Medicaid.  The department's  
            duties include inspecting facilities to verify compliance with  
            licensing and certification standards, citing and penalizing  
            facilities that fail to meet requirements, investigating  
            alleged complaints, certifying and investigating related  
            personnel, and conducting various quality improvement  
            programs.  Although DPH L&C is responsible for a wide variety  
            of facility types and personnel, the majority of staff time is  
            devoted to inspections and complaint investigations of  
            long-term care facilities.  DPH L&C is funded through facility  
            license fees, which are based on the staff time devoted to  
            different facility types. 

            Current law requires DPH to make an onsite inspection within  
            10 working days of the receipt of a written or oral complaint  
            (24 hours for serious complaints), but does not specify a time  
            frame for completion.  It requires DPH to notify the  
            complainant of the name of the inspector, and provides for the  
            complainant to accompany the inspector to the site of the  
            alleged violation. It also requires DPH to notify the  
            complainant of their determination within 10 working days of  
            the completion of the complaint investigation, and allows an  
            appeal process. Finally, current law excludes, for the  
            purposes of these complaint investigation timelines, a  
            self-report of a potential violation from a facility itself.   
            This bill would extend the requirements to facility  
            self-reports.

           3)Complaints  . The timeliness of L&C complaint investigation has  








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            been a subject of criticism by advocates, as well as long-term  
            care facilities themselves, for several years. Information  
            provided by DPH indicates the department receives about 5,500  
            complaints per year. Over the last several years, about half  
            were resolved within 90 days.  The department does appear to  
            be making progress in resolving more cases within a 90-day  
            time frame.  Data indicates about 60% were resolved within 90  
            days in 2012-13.  However, data also indicates there is a  
            growing backlog of complaint investigations, as more  
            complaints are received than closed each year.  At the end of  
            fiscal year 2012-13, there were more than 1,000 cases in  
            queue.   
            
            4)Oversight  . In 2007, the Bureau of State Audits published a  
            report that found the former Department of Health Services  
            struggled to initiate and close complaint investigations and  
            communicate with complainants in a timely manner.  On Jan. 1,  
            2014, the Assembly Committee on Aging and Long-Term Care and  
            the Assembly Committee on Health held a joint oversight  
            hearing on DPH L&C, taking testimony from stakeholders on the  
            issue of complaint timeliness.  On March 12, 2014, the Joint  
            Legislative Audit Committee approved Assemblymember Yamada's  
            request for an audit examining the effectiveness DPH L&C  
            complaint investigation processes.  
                 
            5)Staff Comments.   This bill establishes an expectation for DPH  
            to go from a status quo where over 40% of complaints take  
            longer than 90 days to complete, to a process where the vast  
            majority are completed within 40 days.  Although this time  
            frame may be preferable from the perspective of reaching  
            speedy and fair resolutions for stakeholders, it appears  
            unlikely the department will meet this standard January 1,  
            2015, given significant process and staffing changes may be  
            required.  Thus, DPH is likely to be out of compliance with  
            this standard immediately.  
                 
             In addition, staff notes the L&C division has many competing  
            priorities, including timely licensing and certification  
            inspections of long-term care facilities and other facility  
            types, as well as personnel.   Placing time and documentation  
            constraints on certain aspects of L&C duties may be desirable,  
            but any new mandate should be considered in context of the  
            universe of L&C priorities.  The relative importance of speedy  
            complaint investigations could differ depending on L&C  
            performance in other areas. For example, placing greater  








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            emphasis on speedy resolution of new cases may conflict with  
            addressing a backlog of older cases or allocating staff to  
            meet federally mandated time frames for annual certification.   
            It is certainly possible to prioritize certain areas over  
            others, or set higher expectations for certain functions, but  
            trade-offs in terms of higher resource levels and/or the  
            possibility of deprioritizing other functions should be  
            considered.   

          Analysis Prepared by  :    Lisa Murawski / APPR. / (916) 319-2081