Roundup: Latest Actions from the Commission on State Mandates and What It Means for Counties 

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By
Jessica Sankus
Date Published
August 6, 2026

Although our updates last week were focused primarily on the upcoming hearing of the Commission on State Mandates (August 14), this week the latest developments related to reimbursable state-mandated programs are related to the State Controller’s Office’s (SCO) roles and responsibilities, such as auditing reimbursement claims and issuing claiming instructions for newly adopted programs. The issues below present opportunities for counties to provide input before decisions are finalized.   

A complete list of all matters pending before the Commission and recent actions is available on the pending caseload webpage. To receive updates directly from the Commission, contact Commission staff directly at csminfo@csm.ca.gov. 

Questions about the Commission on State Mandates or the state mandate reimbursement process in general? Contact Jessica Sankus, Principal Fiscal and Policy Analyst, at jsankus@counties.org.  

NEW INCORRECT REDUCTION CLAIM 

Child Abduction and Recovery, 25-4237-I-07 (View Matter)  

Recent Action: Riverside County filed an Incorrect Reduction Claim with the Commission on State Mandates for this program. An “Incorrect Reduction Claim” is a request that the Commission determine and rule that the SCO incorrectly reduced a county’s reimbursement claim for a reimbursable state-mandated program as the result of an audit conducted by the SCO.  

Next Steps: Comments from interested parties and similarly affected local agencies are due to the Commission on State Mandates on or by November 2, 2026. The Commission tentatively plans to hear this matter during their hearing on June 11, 2027. 

About the program: The Custody of Minors – Child Abduction and Recovery Program is one of the first programs to be deemed a reimbursable state mandate after Proposition 4 (1979) required the state to reimburse local governments for the costs to comply with state-mandated programs. Since 1979, the state has reimbursed counties for the state-mandated requirement that county district attorneys’ offices actively assist in the resolution of child custody problems, including visitation disputes, enforcement of custody decrees, and any other court order in child custody proceedings. The SCO is authorized to perform audits of counties’ claims for reimbursement for state-mandated programs to verify the actual amount of the mandated costs, to determine whether costs claimed are supported by appropriate documentation, and to ensure that claims are not unreasonable or excessive (Government Code sections 17558.5, 17561, and 12410).   When the SCO disallows costs previously claimed by counties, the affected county may choose to either remit the disallowed amount to the state, or the SCO offsets (withholds) commensurate amounts from state-mandated costs reimbursements filed by that county in subsequent fiscal years.  

FOR COMMENT: DRAFT CLAIMING INSTRUCTIONS 

New Reimbursable State-Mandated Programs  
The SCO has circulated the draft claiming instructions for two newly-adopted test claims for reimbursable state-mandated programs. Local agencies follow the SCO’s claiming instructions to file claims for reimbursement with the SCO.   

The draft claiming instructions are open for comment from county governments and other affected parties on or before August 18, 2026: 

Stops: Notification by Peace Officers  
AB 2773 (Chapter 805, Statutes of 2022) requires, beginning January 1, 2024, a peace officer making a traffic or pedestrian stop to state the reason for the stop before asking any other questions (i.e., the ubiquitous initial question “Do you know why I pulled you over today?” is not allowable). Peace officers are also required to document the reason for the stop on any citation or report resulting from the stop. The test claim was approved by the Commission in February 2026.  

Child Physical Abuse and Neglect Exams 
AB 1402 (Chapter 841, Statutes of 2023) intended to provide no-cost medical examinations to victims of child abuse and neglect by prohibiting charging the victims. The bill required counties to set up systems to provide examinations at no cost to the victim and instead submit invoices for reimbursement to the California Governor’s Office of Emergency Services, subject to appropriation by the Legislature. The Legislature did not provide an appropriation for this purpose in subsequent state budgets. The provisions of this bill resulted in the removal of authority for county human services departments (or the appropriate equivalent) to bill Medi-Cal for these services. Prior to AB 1402, counties billed Medi-Cal or private health insurance for physical abuse or neglect exams. 

Next Steps: Initial Reimbursement Process  
When the SCO publishes the final claiming instructions for a new state-mandated program, counties must submit claims for costs incurred during the “initial fiscal years” to the SCO within 120 days of the issuance of the claiming instructions (Government Code Section 17561). The “initial reimbursement claim process” is for costs to be reimbursed for the fiscal years specified in the claiming instructions and the program’s Parameters and Guidelines. 

Questions?  
Submit specific questions about these programs to the SCO at LRSLGPSD@sco.ca.gov. For questions about reimbursable state-mandated programs generally, please contact Emma Jungwirth (ejungwirth@counties.org) or Jessica Sankus (jsankus@counties.org).