BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1974
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          CONCURRENCE IN SENATE AMENDMENTS
          AB 1974 (Quirk)
          As Amended August 5, 2014
          Majority vote
           
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          |ASSEMBLY:  |73-0 |(May 23, 2014)  |SENATE: |34-0 |(August 7,     |
          |           |     |                |        |     |2014)          |
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           Original Committee Reference:   E. & R.  

           SUMMARY  :  Specifies that a "special service" does not include a  
          functional division, department, or unit of a nursing facility  
          that is Medicare or Medi-Cal certified and that is organized,  
          staffed, and equipped to provide inpatient physical therapy  
          services, occupational therapy services, or speech pathology and  
          audiology services to residents of the facility.

           The Senate amendments  clarify that this bill does not limit the  
          Department of Public Health's (DPH) ability to evaluate  
          compliance with therapy requirements for nursing facilities and  
          skilled nursing facilities (SNFs) during investigations or  
          inspections.

           AS PASSED BY THE ASSEMBLY  , this bill specified that, for  
          purposes of SNF licensing applications "special service" does  
          not include a functional division, department, or unit of a  
          nursing facility that is organized, staffed, and equipped to  
          provide physical therapy services, occupational therapy  
          services, or speech pathology and audiology services to  
          residents of the facility.  

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, pursuant to Senate Rule 28.8, negligible state costs.

           COMMENTS  :  According to the author, state law and regulations  
          require that SNFs receive approval from DPH to provide "special  
          services" or "optional services" to their patients and these  
          services include physical therapy, occupational therapy, and  
          speech pathology.  The author further states that to receive a  
          license a facility must fill out a detailed application and  
          state licensing officials must conduct a thorough and  
          specialized survey of the facility, however, requiring SNFs that  
          are licensed under Medi-Cal, through the Department of Health  








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          Care Services and certified under Medicare to also obtain  
          approval from DPH to provide therapy services is duplicative and  
          creates an unnecessary burden for both the nursing facility and  
          the state.  

          Health care facilities in California are licensed, regulated,  
          inspected, and/or certified by a number of public and private  
          agencies at the state and federal levels, including the DPH  
          Licensing and Certification Program and the United States  
          Department of Health and Human Services' Centers for Medicare  
          and Medicaid Services (CMS).  These agencies have separate, yet  
          sometimes overlapping, jurisdictions.  DPH is responsible for  
          ensuring health care facilities comply with state laws and  
          regulations.  In addition, DPH cooperates with CMS to ensure  
          that facilities accepting Medicare and Medi-Cal (in California,  
          Medicaid is referred to as Medi-Cal) payments meet federal  
          requirements.  
           
           In 1987 the federal Omnibus Budget Reconciliation Act was  
          implemented, under which to be federally certified and meet  
          Medicare and Medicaid requirements, a SNF must offer physical  
          therapy, occupational therapy, and speech pathology.  Medicare  
          certification surveyors annually review facilities for  
          compliance with these requirements.  California's Title 22  
          regulations relating to optional services have not been updated  
          by DPH since the federal changes were made, and specify that  
          physical therapy, occupational therapy, and speech pathology are  
          "special services" or "optional services," and as such must be  
          listed on a facilities licensing application.  

          The California Association of Health Facilities' (CAHF) is the  
          sponsor of this bill and states that because of an outdated  
          technicality licensed and certified nursing facilities must  
          submit duplicate forms and spend unnecessary time in completing  
          these requirements along with the state wasting unnecessary  
          funding and resources in duplicating a survey.  CAHF further  
          states this bill will address the redundant and obsolete  
          California Title 22 requirements by amending statute to state  
          that Medicare certified nursing facilities will not be required  
          to obtain duplicative approval by state licensing to provide  
          inpatient therapy services already required under their  
          certification.

          The California Hospital Association supports this bill, writing  
          that outdated Medicaid requirements categorize therapy services  








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          as optional under the Medi-Cal program, however, if a SNF wants  
          to participate in the Medicare program (which most facilities  
          do) they must comply with the mandatory requirement that these  
          same therapy services be provided to a patient that has a care  
          plan requiring such services.

          This bill has no opposition on file.
           

          Analysis Prepared by  :    Lara Flynn / HEALTH / (916) 319-2097 


          FN:  
          0004396