BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 1534
                                                                  Page  1

          Date of Hearing:  June 27, 2000

                            ASSEMBLY COMMITTEE ON HEALTH 
                               Martin Gallegos, Chair
                    SB 1534 (Perata) - As Amended:  June 22, 2000

           SENATE VOTE :  24-15

           SUMMARY  :  Specifies the duties and responsibilities of patients'  
          rights advocates and clarifies the rights of mental health  
          clients.  Specifically,  this bill  , among other things:

          1)Specifies that people with psychiatric disabilities residing  
            in specified community care facilities have the same legal and  
            civil rights guaranteed patients hospitalized in mental health  
            treatment facilities, including access to the services of a  
            patients' rights advocate.

          2)Adds mental health clients to the list of persons who can  
            bring an enforcement action for rights violations, and  
            specifies that the aggrieved person need not prove actual  
            damages to bring such an action.

          3)Specifies that the duties of county patients' rights advocates  
            (PRAs) include: a) providing representation in certification  
            review hearings, capacity hearings, and hearings pertaining to  
            the commitment of minors to public hospitals, unless such  
            representation is already provided; b) providing assistance to  
            minors in clinical review proceedings; c) assisting recipients  
            of public mental health services with grievances; and d)  
            providing outreach to recipients of mental health services to  
            ensure that they are aware of their rights. 

          4)Specifies that PRAs have access to mental health clients in  
            community care facilities.  Requires this access to be  
            provided as necessary and reasonable, and if feasible, during  
            normal hours of operation, for routine monitoring.  If a PRA  
            conducting monitoring wishes to interview a patient or  
            resident, the advocate must contact a representative of the  
            facility and the treating provider before conducting the  
            interview.

          5)Permits a PRA to inspect and copy confidential client  
            information and records, without specific authorization by the  
            client or guardian, in the course of investigating a complaint  








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            if the client is deceased, is absent, is unable to authorize  
            the release of information due to his or her physical or  
            mental condition, or in accordance with routine monitoring  
            duties.  Prohibits a PRA from having access to records over a  
            client's objections.

          6)Clarifies the authority of PRAs to refer complaints to any  
            appropriate state or local government agency, and requires any  
            licensing agency that responds to a complaint referred by an  
            advocate to prepare an annual report to the Legislature, as  
            specified.

          7)Requires a county mental health director to be responsible for  
            responding to complaints about any PRA.

          8)Prohibits retaliation against advocates for the performance of  
            their duties and prohibits discrimination and retaliation  
            against a resident of a community care facility who initiates  
            or participates in a complaint.     

           EXISTING LAW  :

          1)Establishes rights of patients in mental health treatment  
            facilities, including the right to receive the services of a  
            patient advocate.  

          2)Requires each local mental health director to appoint or  
            contract for one or more county patients' rights advocates.    
            Requires the duties of these advocates to include, but not be  
            limited to the following:  a) investigating complaints from or  
            concerning recipients of mental health services residing in  
            licensed health or community care facilities regarding abuse,  
            unreasonable denial or punitive withholding of their rights;  
            b) monitoring mental health facilities, services and programs  
            for compliance with statutory and regulatory patients' rights  
            provisions; c) providing training and education about mental  
            health law and patients' right to mental health providers; and  
            d) ensuring that mental health clients in all licensed health  
            and community care facilities are notified of their rights.

          3)Authorizes the court to impose a civil penalty on any person  
            or facility for specified patient's rights violations, in an  
            amount of $50 per day during the time in which the violation  
            is not corrected, not to exceed $1,000 for each violation. 









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           FISCAL EFFECT  :  Unknown

           COMMENTS  :   

           1)PURPOSE OF THIS BILL  .  According to the author, the intent of  
            the bill is to clarify the rights and responsibilities of  
            mental health advocates to create more uniformity in the  
            delivery of patient advocacy services, and to facilitate  
            responses to concerns forwarded by advocates to appropriate  
            state licensing entities.  The author points to a recent  
            series of articles in  the Los Angeles Times  that revealed  
            incidents of neglect and abuse in homes for the mentally ill  
            throughout the state. 

           2)SUPPORT  :  The California Association of Mental Health  
            Patients' Rights Advocates (CAMHPRA) is sponsoring this bill  
            to clarify the responsibilities of patients' rights advocates  
            and consolidate into one provision all of those  
            responsibilities.  County patients' rights advocates have  
            numerous duties that are not listed in the primary statutory  
            provision governing advocates' responsibilities.  This bill  
            proposes to consolidate those functions in one section of the  
            law in order to clarify the advocates' role and diminish  
            confusion.

            CAMHPRA argues that this bill ensures that patients who have  
            died, left the area, or are unconscious or otherwise unable to  
            consent to a release of confidential information are able to  
            have equal access to advocacy services.  CAMHPRA asserts that  
            adequate monitoring of psychiatric facilities cannot be  
            accomplished without access to an appropriately sized randomly  
            selected data set of mental health records.  While the current  
            law already allows advocates' access to confidential records  
            in that context, misinformed and misguided interpretations of  
            this access by certain parties who have a vested interest in  
            keeping advocates away from clients who may complain or from  
            records which may reveal noncompliance with laws and  
            regulations.  They also state that sufficient confidentiality  
            protections are in place, and that advocates do not pursue  
            complaint investigations or seek access to confidential  
            records over the objections of their clients, which the bill  
            also makes clear.

            Finally, CAMHPRA supports the bill's provision which extends  
            the basic patients' rights protections currently afforded to  








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            patients in mental health facilities to include persons with  
            psychiatric disabilities who reside in certain community care  
            facilities.  The California Network of Mental Health Clients  
            states that one of the major barriers to treatment is the real  
            and perceived abuses of the mental health system... which is  
            experienced by many clients as abusive, disrespectful, and  
            hurtful.  Protection and Advocacy, Incorporated (PAI) also  
            believes this bill will greatly improve mental health services  
            in California by improving the ability of patients' rights  
            advocates to advocate on behalf of their clients.

           3)BACKGROUND  .  In 1974, the Legislature mandated the  
            establishment of mental health patients' rights.  
            Administrative regulations adopted in 1976 required county  
            mental health departments and state hospitals to provide  
            patients' advocacy services including educating patients about  
            their rights, investigating complaints and advocating on  
            behalf of patients whose rights were violated.
           
            Counties are required to designate a county mental health  
            patients' rights advocacy office that is responsible for  
            offering the statutorily defined services. Advocates must meet  
            qualifications necessary to fulfill the responsibilities  
            established by state law but specific qualifications are not  
            defined.  Advocates are mandated to attend annual training  
            sponsored by the State Office of Patients' Rights.

           4)RECENT ABUSES  .  Following the realignment of responsibility  
            and payment for public mental health services in 1991,  
            counties gained the option of paying to place noncriminal  
            persons with severe mental illness in state-run hospitals, or  
            contracting out with private providers at the local level to  
            provide care.  A recent  Los Angeles Times  article indicates  
            that many counties have chosen to redirect patients to private  
            facilities that tend to be less expensive than state hospital  
            care.  This redirection has also resulted in a large increase  
            in the number of citations issued to a select group of private  
            facilities.  DHS has issued 200 citations against 35 of the 45  
            facilities certified to provide care for the mentally ill  
            since 1992.  Eight facilities received almost half of these  
            citations.  The author believes that one of the solutions for  
            ensuring compliance with patients' rights laws is to clarify  
            the ability of the advocate to monitor facilities and take  
            action when there are abuses.
           








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           5)OPPOSITION  :  A coalition comprised of the California Alliance  
            of Child and Family Services, California Association of Health  
            Facilities, California Healthcare Association, California  
            Mental Health Directors Association, and the California  
            Psychiatric Association (the Coalition), submitted a joint  
            letter opposing this bill unless it is amended. The Coalition  
            opposes any expansion of the duties of patients' rights  
            advocates without additional resources, and argues that this  
            bill sets the system up for failure.

            The Coalition objects to the bill's provisions that would  
            allow, as part of their monitoring duties, patients' rights  
            advocates "to have unlimited access to inspect and copy  
            confidential medical records without specific authorization by  
            the patient or his or her guardian.  The Coalition also  
            asserts that in cases where a child is involved, authorization  
            should be required of the patient's legal guardian prior to  
            any confidential records being disclosed.  The Coalition also  
            argues that the definition of "routine monitoring" for  
            purposes of allowing advocates access to records and patient  
            information is too vague.  

            The Coalition is concerned that the requirements for training  
            of patients' rights advocates are limited, and notes that many  
            advocates appear to receive on-the-job training, which can  
            vary greatly from county to county.  The Coalition recommends  
            a standardized training program to provide a basic knowledge  
            of the services to be provided and instruction on the  
            consistent application and interpretation of laws and  
            regulations.

            Finally, the Coalition argues that expansion of the patients'  
            rights advocates' duties, without additional oversight, will  
            actually lead to services being an inconsistent manner  
            depending upon the strengths and weaknesses of each advocate.   
            The Coalition recommends that the county mental health  
            director exercise additional oversight when an advocate seeks  
            access to medical records.      

           REGISTERED SUPPORT / OPPOSITION  :

           Support  

          California Association of Mental Health Patients' Rights  
          Advocates (sponsor)








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          California Network of Mental Health Clients
          Protection and Advocacy, Incorporated
           
          Opposition  

          California Alliance of Child and Family Services
          California Association of Health Facilities
          California Healthcare Association
          California Mental Health Directors Association
          California Psychiatric Association

           Analysis Prepared by  :  Ann Blackwood / HEALTH / (916) 319-2097