Roundup: Latest Actions from the Commission on State Mandates and What It Means for Counties
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We return this week with an update on the latest actions in the world of state-mandated programs after a brief hiatus while CSAC staff attended the respective annual conferences for the California Association of County Executives and the State Association of County Auditors; two groups of county officials that are essential to the state mandates process.
What happened over the last two weeks during this busy conference season? Let’s find out!
NEW STATEWIDE COST ESTIMATES
Internet Websites and Email Addresses, 24-TC-04
Recent Updates: Last week, the Commission published the draft statewide cost estimate for this mandate, and estimates that the initial (retroactive) reimbursable costs for cities and counties to comply with this new requirement ranges from $2.7 million to $36.5 million. The broad range depends highly on the amount of cities and counties that choose to pursue reimbursement.
- Don’t leave money on the table! The Commission reports that 12 counties submitted claims for reimbursement for this newly approved state-mandated program for costs incurred between January 1, 2024 and June 30, 2025. Reimbursement claims were due by September 16, however late reimbursement claims may be filed until September 16, 2027, subject to a 10 percent penalty.
Next Steps: Written comments on the draft proposed statewide cost estimate are due to the Commission by November 9. This matter is scheduled to be heard during the Commission’s upcoming hearing on December 4.
About this issue: AB 1637 (Chapter 586, Statutes of 2023) requires cities and counties to ensure that their Internet website utilizes a “.gov” or a “.ca.gov” domain, and to ensure that each email address provided to its employees utilizes a “.gov” or a “.ca.gov” domain name by January 1, 2029.
Criminal Procedure: Discrimination, 24-TC-02
Recent Updates: In late October, the Commission published the draft statewide cost estimate for this mandate, and estimates that the initial (retroactive) reimbursable costs for counties to comply with this new requirement ranges from $781,000 to $6.5 million.
- Don’t leave money on the table! The Commission reports that seven counties submitted claims for reimbursement for this newly approved state-mandated program for costs incurred between July 1, 2023 and June 30, 2025. Reimbursement claims were due by September 16, however late reimbursement claims may be filed until September 16, 2027, subject to a 10 percent penalty.
Next Steps: This matter is scheduled to be heard during the Commission’s upcoming hearing on December 4.
About this issue: AB 256 (Chapter 739, Statutes of 2022) expanded the provisions of AB 2542 (Chapter 317, Statutes of 2020), the original Racial Justice Act, and made these requirements both retroactive and prospective. The Racial Justice Act provides that individuals charged with or convicted of a crime may file habeas corpus petitions to raise issues of bias or discrimination based on race, ethnicity, or national origin in their cases.
DEPARTMENT OF FINANCE FILES COMMENTS
Local Agency Officials: Training, 26-TC-01
Recent Updates: Last week, the Department of Finance (DOF) filed comments on this test claim, where they argue, amongst other things, “that some activities the Claimant performed or intends to perform are one-time in nature or not a reimbursable state mandate because they are not required by existing law.”
Next Steps: Interested parties (any county, not just the claimant) can file rebuttal comments with the Commission in response to DOF’s letter within 30 days (November 27).
About this issue: SB 827 (Chapter 661, Statutes of 2025) expanded the local officials who must complete the ethics training initially required under AB 1234 to department heads or similar administrative officers of local agencies. It also requires all officials to conduct the training within six months of assuming office, instead of the prior requirement to do so within one year. The new law also requires some local officials to complete fiscal and financial training that must be at least two hours in duration and must be completed every two years. Read the test claim here.
STATE CONTROLLER’S OFFICE FILES COMMENTS
Child Abduction and Recovery, 25-4237-I-07
Recent Updates: The State Controller’s Office (SCO) filed comments with the Commission regarding Riverside County’s Incorrect Reduction Claim for the longstanding Child Abduction and Recovery program. In their letter, the SCO continues to argue that their audit findings were correct.
- Why is this single-county matter included in our bulletin? Many counties have reported high disallowance rates as the result of audits from the SCO for this program and are considering (or already have) filed Incorrect Reduction Claims with the Commission to dispute the audit findings.
About this issue: The Custody of Minors – Child Abduction and Recovery Program reimburses 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.
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. To receive updates from the SCO, sign up for their email lists here.
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.