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

What’s cooking this week at the Commission on State Mandates? Hot from the oven, a fresh draft proposed decision from Commission staff for Local Public Employees:  Vacant Positions, 25-TC-01 (view matter).  

This test claim was submitted in December 2025 and argues that local governments should be reimbursed from the state for the cost to comply with AB 2561 (Chapter 409, Statutes of 2024). This measure requires, amongst other things, all local agencies to hold an annual public hearing on the status of vacancies before their governing board (City Council, Board of Supervisors, etc.) at least once per fiscal year, with more extensive reporting requirements for a local agency that has a bargaining unit that experiences a vacancy rate of 20% or more for any period of time.  

This week, Commission staff recommend in the draft proposed decision that the Commissioners approve this test claim for reimbursement when it is heard during their hearing on October 9. Commission staff caveat, however, that any activities undertaken pursuant to AB 2561 that are also requirements of the Brown Act (open meetings for local governments) or the California Public Records Act should not be included as costs to comply with the Brown Act have already been found to not qualify for reimbursement from the state.  

Written comments from the claimant or interested parties regarding this decision can be filed with the Commission on or by July 20.  

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, 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.