CSAC Bulletin Article

Local Government Coalition Offers Mandates Commission Prudent Alternatives

July 27, 2017

An ever-frustrating series of mandate deferrals, suspensions, and modifications at the state level began several years ago. Now, the Commission on State Mandates (Commission) is proposing new regulations which will create even more barriers for counties and other local agencies seeking to obtain reimbursement for mandated services.

Most notably, the proposed regulations amend the filing period requirements for reimbursement claims, making the requirements much more difficult for local governments to meet. Under the proposed regulations, test claims must be filed within 365 days of incurring increased costs, regardless of where it lands in the fiscal year. Currently, the submission deadline is by June 30 of the fiscal year following the fiscal year in which increased costs were first incurred.  The current filing period properly reflects an understanding of the county budgeting process and allows counties enough time to gather the relevant information.  The proposed change, however, hinders a local government’s ability to adequately track associated costs and submit accurate claims. Additionally, the proposed regulations contain concerning modifications as they relate to the standard of evidence required for test claims as well as the joint test claim single representative requirement.

In response, CSAC, the California Special Districts Association, and the League of California Cities submitted written comments on the proposed regulations, outlining the coalition’s concerns and offering sensible alternatives.

The Commission will be considering the proposed regulations and the coalition’s alternative proposals at a public hearing tomorrow, July 28 beginning at 10am (Item 6 on the hearing agenda). CSAC staff will be there to testify on behalf of county claimants and will keep counties apprised of the outcome.

On a final note, CSAC staff would like to thank members of the Mandated Services Working Group for their crucial feedback on this matter. For more information about the Working Group and how to get involved, please contact either Tracy Sullivan or Dorothy Johnson.  

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