BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1890
                                                                  Page  1


          Date of Hearing:   May 6, 2014

              ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER  
                                     PROTECTION
                               Susan A. Bonilla, Chair
                     AB 1890 (Chau) - As Amended:  April 28, 2014
           
          SUBJECT  :   Athletic trainers.

           SUMMARY  :  Establishes title protection for certified athletic  
          trainers.  Specifically,  this bill  : 

          1)Prohibits a person from holding himself or herself out to be  
            an athletic trainer or a certified athletic trainer, or from  
            using the term "AT," "ATC," or "CAT" to imply or suggest that  
            the person is an athletic trainer unless he or she meets both  
            of the following requirements:  

             a)   He or she has done either of the following:

               i)     Graduated from a college or university after  
                 completing an athletic training education program  
                 accredited by the Commission on Accreditation of Athletic  
                 Training Education, or its predecessors or successors; or

               ii)    Completed requirements for certification by the  
                 Board of Certification, Inc. (BOC), prior to January 1,  
                 2004; and,

             b)   He or she is certified by BOC. 

          2)Deems that it is an unfair business practice for any person to  
            use the title of "athletic trainer," "certified athletic  
            trainer," or any other term, such as "certified," "licensed,"  
            "registered," "AT," "ATC," or "CAT," that implies or suggests  
            that the person is certified as an athletic trainer, if the  
            person does not meet the specified requirements.  

          3)Provides that a person who has practiced athletic training in  
            California for a period of 20 consecutive years prior to  
            January 1, 2015, and who is not otherwise eligible to use the  
            title of "athletic trainer," may use the title "athletic  
            trainer."
           








                                                                  AB 1890
                                                                  Page  2


           EXISTING LAW  provides for the regulation of various professions  
          and vocations, including those of an athlete agent.

           FISCAL EFFECT :   None.  This bill is keyed non-fiscal by the  
          Legislative Counsel.

           COMMENTS  :   

           1)Purpose of this bill  .  This bill would enact title protection  
            for athletic trainers certified by BOC, meaning that  
            individuals who are not certified athletic trainers would be  
            prohibited from holding themselves out to the public as  
            athletic trainers.  An exemption is provided to uncertified  
            individuals who have practiced athletic training in California  
            for 20 consecutive years prior to 2015.  This bill is  
            sponsored by the California Athletic Trainers' Association  
            (CATA). 

           2)Author's statement  .  According to the author, "Although many  
            high school and college sports teams already employ [athletic  
            trainers], and several California State University campuses  
            offer bachelor degrees in athletic training, California is one  
            of only 2 states that do not regulate this vital and growing  
            profession. Currently, anyone can label him[self] or herself  
            an athletic trainer without the proper education, training, or  
            certification. Without state oversight, the public could be  
            harmed by relying on someone who calls themselves an [athletic  
            trainer] without the appropriate background. AB 1890 would  
            protect Californians by ensuring that only those people who  
            have the proper education, training, and certification may  
            call themselves an athletic trainer."

           3)The practice of athletic training  .  According to the sponsor,  
            athletic trainers are physical medicine and rehabilitation  
            specialists who generally work in institutional settings under  
            the direction of a physician.  In practice, they may be the  
            first healthcare providers on the scene when injuries occur  
            (whether at sporting events or on job sites), and must be able  
            to recognize, evaluate and assess injuries and provide  
            immediate care when needed.  

            Athletic trainers are considered "health care professionals"  
            by the American Medical Association, which states that  
            "athletic training encompasses the prevention, diagnosis and  








                                                                  AB 1890
                                                                  Page  3


            intervention of emergency, acute, and chronic medical  
            conditions involving impairment, functional limitations, and  
            disabilities."  Athletic trainers are distinct from "personal  
            trainers", who are generally thought of as individuals who  
            prescribe, monitor and modify individual exercise programs in  
            a fitness or sports setting.  Athletic training and physical  
            therapy are also different professions, although there are  
            certainly substantial areas of overlap. 

            The US Department of Labor describes the areas of expertise  
            for certified athletic trainers as: application of protective  
            or injury-preventative devices; evaluation of injuries; first  
            aid and emergency care; development and execution of  
            rehabilitation programs for injured athletes; and program  
            planning for injury and illness prevention of athletes.

            Athletic trainers are usually employed by organizations such  
            as professional sports teams, colleges and universities, high  
            schools, outpatient rehabilitation clinics, hospitals,  
            corporations, performing arts groups, physicians groups, the  
            military and health clubs.  Roughly 44% of certified athletic  
            trainers nationwide work with athletes in educational or  
            professional sports settings, with nearly 19% working in  
            health care facilities, and more than 10% working in industry,  
            public safety and the military.  The sponsor reports that  
            large employers use athletic trainers in part because of their  
            utility in reducing employee injuries and workers'  
            compensation costs. 
                
            4)Current state of regulation for athletic trainers  .  The  
            educational system for athletic training has been standardized  
            and accredited by a national agency, the Commission on  
            Accreditation of Athletic Training Education (CAATE).   
            According to the author, all 48 states currently regulating  
            athletic training utilize the BOC certification examination,  
            which is based on CAATE educational principles.  BOC is the  
            only entity that currently provides athletic training  
            certification, which means that it would be the sole provider  
            of the certification exam required by this bill.   
            Certification is not currently required to practice athletic  
            training in California, and noncertified individuals are not  
            subject to regulatory discipline.

            Despite its widespread adoption, BOC has a limited ability to  








                                                                  AB 1890
                                                                  Page  4


            investigate complaints against certified athletic trainers  
            because they have no subpoena power and limited staff with no  
            authority in California.  Its sole disciplinary power is the  
            suspension or revocation of the national certification which  
            is not recognized in California and thus poses no barrier to  
            an individual's continued practice here. 

            According to the sponsor, there are 48 states that regulate  
            athletic trainers, 39 of which provide licensure (five require  
            registration and four require certification).   

            There are 16 accredited athletic training programs in  
            California.  In 2010, 182 Californians became certified  
            athletic trainers.

            Currently, there are approximately 2,500 certified athletic  
            trainers practicing in California.  The sponsor of this bill,  
            CATA, represents roughly 2,300 athletic trainers in  
            California.  

           1)The role of title protection  .  This bill would provide  
            BOC-certified athletic trainers with what is termed "title  
            protection".  Title protection means that certified athletic  
            trainers would have an exclusive right to use the title  
            "athletic trainer", while noncertified athletic trainers who  
            advertise the same title risk legal action.  The only  
            exception would be individuals who have been practicing  
            continuously in California for 20 years or more before 2015,  
            who would be allowed to use the title as well.     

          Title protection is generally intended to be a means of market  
            differentiation, whereas a "practice act" would literally  
            prohibit individuals from engaging in the practice regardless  
            of how it is described.  In this case, other individuals could  
            still practice athletic training in California, but they would  
            not be permitted to call themselves athletic trainers.

          Legislation providing title protection or registration for  
            athletic trainers has been passed and vetoed three separate  
            times in recent years: AB 1647 (Hayashi) of 2010, SB 284  
            (Lowenthal) of 2007, and SB 1397 (Lowenthal) of 2006.   
            Governor Schwarzenegger's veto message of AB 1647 stated "This  
            bill is similar to legislation I have vetoed twice before in  
            the past because there is no evidence that regulating the use  








                                                                  AB 1890
                                                                  Page  5


            of the term "certified athletic trainer" poses any threat to  
            the public health and safety." 

           2)Evidence of substandard practice.   According to the author,  
            "[a] survey of 760 certified athletic trainers?.found more  
            than 60 cases of harm as the result of improper care provided  
            by non-certified 'athletic trainers.' 

          "According to the U.S. Department of Labor Division of  
            Practitioner Data Banks, a voluntary reporting repository for  
            sanctions made by state boards, there were 469 reports of  
            sanctions to athletic trainers - both certified and  
            uncertified - from 2000 to 2010.  These sanctions were based  
            upon misconduct including incompetent practice/harm,  
            practicing beyond the scope of practice, and sexual  
            misconduct.  The BOC reported over 2,700 violations  
            [nationwide] of professional practice standards in five years  
            (2005-10) with nearly 300 violations in California, including  
            three sexual offenses.  In a 2011 case, a collegiate athlete  
            died because of negligence of a collegiate athletic trainer,  
            although no lawsuit has been filed to date. Two additional  
            athletic trainers were fired after being arrested on sexual  
            abuse charges."

            The sponsor reports that it is aware of at least 150  
            individuals practicing as athletic trainers without BOC  
            certification in California high schools, and seven  
            individuals working in California community colleges who are  
            similarly uncertificated.

            Finally, the sponsor contends that "the lack of oversight of  
            athletic trainers is a consumer protection problem.  The  
            athletes with whom these unqualified individuals work, and the  
            employers who hire them, have no way of knowing that these  
            individuals are not qualified to be athletic trainers.  The  
            public has no way to determine if someone practicing athletic  
            training is qualified.  The public has no way to file a  
            complaint, or ask for a practitioner to be investigated and/or  
            sanctioned for incompetence, unethical practice, etc.  This  
            creates a huge regulatory gap in the healthcare system."  

           1)Arguments in support  .  According to the sponsor, CATA, "The  
            unregulated status of the athletic training profession is a  
            major public concern, which would be partially addressed if AB  








                                                                  AB 1890
                                                                  Page  6


            1890 were to pass.  Unqualified individuals are posing as  
            athletic trainers and providing healthcare to our children  
            without the proper education or training.  Also, individuals  
            who have lost their national certification or license in other  
            states are coming to practice in California with impunity.   
            Currently, there is no mechanism for the public to lodge a  
            complaint or to remove an individual that is practicing  
            incompetently.  Only licensure will rectify the aforementioned  
            issues however, AB 1890 would at least ensure that individuals  
            who call themselves athletic trainers have had the proper  
            education and training and are certified by a nationally  
            recognized certifying agency." 

           2)Arguments in opposition  .  According to the California  
            Federation of Teachers (CFT), which has an Opposed Unless  
            Amended position, "CFT is concerned that this bill does not  
            have a provision to exempt from the licensure requirements  
            persons who are currently employed and have worked as athletic  
            trainers for years. CFT represents athletic trainers who have  
            worked in this field for years and the enactment of this bill  
            could result in the termination of their employment.  
            Therefore, we respectfully request an amendment that would  
            grandfather in persons who have worked in this profession for  
            15 years and allow them to continue to practice as athletic  
            trainers and use the title of an athletic trainer." 
           
           3)Technical amendment  .  Given that the bill restricts its  
            effects to those working as athletic trainers (which title is  
            restricted) rather than those practicing athletic training  
            (which remains unrestricted), the exemption granting title  
            protection to uncertified individuals in practice more than 20  
            years should be recast to apply to those who have actually  
            worked as athletic trainers, rather than anyone who practiced  
            athletic training.

               Page 2, line 29, strike the words "practiced athletic  
               training" and insert "worked as an athletic trainer"

           4)Previous legislation  .  AB 864 (Skinner) of 2013 would have  
            established the Athletic Training Practice Act to license and  
            regulate athletic trainers through the creation of an Athletic  
            Trainer Licensing Committee under the Physical Therapy Board  
            of California.  AB 864 was held in the Assembly Appropriations  
            Committee.     








                                                                  AB 1890
                                                                  Page  7



            AB 252 (Yamada and Eggman) of 2013 would have prohibited an  
            individual from holding himself or herself out professionally  
            as a "social worker" unless he or she has received a degree  
            from an accredited academic institution.  AB 252 was held in  
            the Assembly Appropriations Committee.   

            SB 1273 (Lowenthal) of 2012 was very similar to AB 864 in most  
            respects.  SB 1273 failed passage in the Senate Business,  
            Professions and Economic Development Committee.

            AB 374 (Hayashi) of 2011 in its most recent version would have  
            extended title protection to athletic trainers. AB 374 was  
            amended in the Assembly Appropriations Committee to address an  
            unrelated issue. 

            AB 1647 (Hayashi) of 2010 would have extended title protection  
            to athletic trainers.  AB 1647 was vetoed by Governor  
            Schwarzenegger. 

            SB 284 (Lowenthal) of 2007 would have provided for  
            registration of ATs.  SB 284 was vetoed by the Governor.  

            SB 1397 (Lowenthal) of 2006 would have provided for  
            registration of ATs.  SB 1397 was vetoed by the Governor. 

            AB 614 (Lowenthal) of 2003 would have required the Department  
            of Consumer Affairs to review the need for licensing of ATs.   
            AB 614 was held in the Senate Business, Professions and  
            Economic Development Committee. 

            AB 2789 (Lowenthal) of 2002 would have required the Department  
            of Consumer Affairs to review the need for licensing of ATs  
            and undertake an occupational analysis.  AB 2789 was held on  
            the Assembly Appropriations Committee Suspense file.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Athletic Trainers' Association (sponsor)
          American Medical Society for Sports Medicine (4/10/14 version)
          2333 private individuals (2/19/2014 version)









                                                                  AB 1890
                                                                 Page  8


           Opposition 
           
          California Federation of Teachers (4/21/14 version)
          301 private individuals (2/19/2014 version)
            
          Analysis Prepared by  :    Hank Dempsey / B.,P. & C.P. / (916)  
          319-3301