Update: More Actions from the Commission on State Mandates 

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By
Jessica Sankus
Date Published
October 9, 2025

As reported by CSAC last week, the staff at the Commission on State Mandates have been busy beavers in recent weeks and months. Detailed below is an additional action from the Commission and their staff notable for counties and future potential opportunities for reimbursement for state-mandated programs.  

To receive updates directly from the Commission, subscribe to their email lists. 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.

Background: The Commission on State Mandates and the Reimbursement Process
While counties are required to comply with all state mandates, counties only receive funding to carry out a select group of state-mandated programs in the form of after-the-fact reimbursement payments from the state. After a bill is signed into law, reimbursement for counties to comply with state-mandated programs is not automatic. Rather, counties initiate the process to receive reimbursement via filing a “test claim” for reimbursement with the Commission on State Mandates. The Commission on State Mandates deliberates and determines whether the new law meets the criteria for reimbursement. If the Commission determines that it does, the Commission begins work on Parameters and Guidelines, which establish a process and rate for reimbursement for the program. For more information about state mandates and the Commission on State Mandates, see CSAC’s Issue Brief on State-Mandated Programs and CSAC’s publication, Meeting the Mandate: Counties Respond to Shifting Costs, Responsibilities, and Outcomes.

Stops: Notification by Peace Officers (24-TC-03)

Summary: Beginning January 1, 2024, AB 277 (Chapter 805, Statutes of 2022) requires peace officers to state the reason for a stop (whether a traffic stop or a pedestrian stop) before questioning the stopped individual about anything else. AB 2773 also requires the officer to document the reason for the stop on any citation or policy report resulting from the stop. Prior to AB 2773, peace officers were not required to disclose the reason for a stop, nor were they required to document the reason. For example, after January 1, 2024, the common question “Do you know why I pulled you over?” is not permissible. The test claim for reimbursement argues that the state must reimburse counties for, among other things, the costs for printing new citation forms, developing new procedures, and training officers to comply with AB 2773. 

Recent Action: On October 6, Commission staff published a draft proposed decision for this test claim, and therein recommends that the Commission partially approve the test claim. 

Next Steps: Counties can file written comments on the draft proposed decision by 5:00pm on Monday, October 27. The Commission plans to act on this test claim during their hearing on Friday, February 13, 2026.