Roundup: Latest Actions from the Commission on State Mandates and What It Means for Counties
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Since our update last month, the Commission on State Mandates posted a new test claim for reimbursement to their website, described in more detail below.
Additionally, the Commission had planned to hear several matters relevant to counties during a hearing tomorrow, April 10, but has canceled and rescheduled this hearing to May 15 instead. Click here to access the hearing materials and Zoom link.
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.
NEW TEST CLAIM
Emergency Communications in Non-English Languages (25-TC-03)
Summary: In December 2025, Sonoma County filed a test claim for reimbursement with the Commission on State Mandates for the costs for counties to comply with AB 1638 (Chapter 587, Statutes of 2023).
AB 1638 requires local agencies to do the following:
- By January 1, 2025, local agencies were required to use data from the American Community Survey or data from an equally reliable source to determine which languages within their jurisdiction are spoken jointly by 5% or more of the population that speaks English less than “very well.”
- In the event of an emergency, a local agency must provide information related to the emergency in English and in all languages spoken jointly by 5% or more of the population that speaks English less than “very well.”
- Local agencies must reassess the language data every five years.
- Local agencies must ensure that the quality of the information in translated languages has parity with information provided in English for comprehension, action, and timeliness.
Next Steps: Counties and other interested parties can file comments with the Commission about this test claim by May 7, 2026. The Commission will tentatively hear this matter during their hearing in February 2027.
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.