Existing law prohibits a marriage license or certificate of death from being altered or changed in any respect after its acceptance for registration by a local registrar, except when supplemental information required for statistical purposes is furnished. Existing law provides for the amendment of a certificate of death, which amendments are filed with the local registrar and State Registrar. Existing law requires the State Registrar to send a certified copy of the newly amended certificate of death to the applicant without additional charge, except for those amendments that are filed within one year of the date of occurrence of the event.

This bill would require the preparation of a new, one-page certificate of death if a person is able to assert that the facts are not correctly stated on the certificate and the incorrect information does not change a finding, conclusion, or determination. The bill would require the State Registrar to send the applicant a certified copy of the new, one-page certificate of death if the amendment results in a new, one-page certificate of death. State Registrar, as soon as practicably possible, in coordination with a major upgrade or replacement of the information technology system, to include the functionality to replace an amended certificate of death with a new, one-page certificate of death. The bill would require, once the functionality is available, the State Registrar to issue the new, one-page certificate of death in place of the amended certificate.

Existing law prohibits a marriage license or certificate of death from being altered or changed in any respect after its acceptance for registration by a local registrar, except when supplemental information required for statistical purposes is furnished. Existing law provides for the amendment of a certificate of death, which amendments are filed with the local registrar and State Registrar. Existing law requires the State Registrar to send a certified copy of the newly amended certificate of death to the applicant without additional charge, except for those amendments that are filed within one year of the date of occurrence of the event.

This bill would require the issuance of an amended original preparation of a new, one-page certificate of death if a person is able to assert that the facts are not correctly stated on the certificate and the incorrect information does not change a finding, conclusion, or determination. The bill would require the State Registrar to send the applicant a certified copy of the amended original new, one-page certificate of death if the amendment results in a new original new, one-page certificate of death.

Existing law prohibits a marriage license or certificate of death from being altered or changed in any respect after its acceptance for registration by a local registrar, except when supplemental information required for statistical purposes is furnished. Existing law provides for the amendment of a certificate of death, which amendments are filed with the local registrar and State Registrar. Existing law requires the State Registrar to send a certified copy of the newly amended certificate of death to the applicant without additional charge, except for those amendments that are filed within one year of the date of occurrence of the event.

This bill would require the issuance of an amended original certificate of death if a person is able to assert that the facts are not correctly stated on the certificate and the incorrect information does not change a finding, conclusion, or determination. The bill would require the State Registrar to send the applicant a certified copy of the amended original certificate if the amendment results in a new original certificate of death.

SENATE COMMITTEE ON APPROPRIATIONS

Senator Anthony Portantino, Chair

2017 - 2018 Regular Session

AB 2367 (Berman) - Certificates of death: amended certificates

This bill meets the criteria for referral to the Suspense File.

Bill Summary:

Requires the State Registrar, as soon as practicably possible and in coordination with a major upgrade or replacement of the information technology system, to include the functionality to replace an amended certificate of death with a new, one-page certificate of death. Requires the new, one-page certificate of death to be issued in place of the amended certificate.

Fiscal Impact:

The Department of Public Health (CDPH) estimates:

• $234,000 (Health Statistics special fund) in fiscal year 2018-19, and annually thereafter, costs of for 3.0 Program Technician II to manually seal the death certificates in the state file system that is used to issue certified copies, assuming there are 30,000 records that must be manually sealed and replaced annually.

Background:

1. The CDPH’s Vital Records Registration Branch (VRRB) is charged with maintaining a uniform, comprehensive, and continuous index for all birth, death, fetal death, and marriage vital events which occur in California, of which are over one million each year. With regard to dissolution records, DPH maintains an index of only case numbers from 1962 to 1984. County superior courts maintain and issue the actual divorce decrees for all years. Certified copies of vital records are available from DPH, 58 county recorders, and 61 local health jurisdictions. DPH maintains, and can provide, birth and death records from 1905 to the present. At the local level, birth and death records for current-year events and one year prior are available from the county health department; records for all years are maintained by the county recorder.

The California Electronic Death Registration System (EDRS) is a Web-based system that provides the ability for coroners, funeral directors, doctors, and hospitals to submit electronic death certificates. According to DPH, the first section of the record is usually completed by a funeral director in coordination with a family member or another individual best qualified to provide the deceased's personal information. The second section must be completed by a physician, medical examiner, or coroner to provide the medical and health data necessary, including information on the manner of death and investigation determinations. The funeral director submits the completed death certificate to the local registrar in the county where the death occurred, and from there it is forwarded to the State Registrar.

Amendments are made to death certificates for various reasons, including correcting spelling errors, adding information not known at the time of death, or correcting factual errors. According to DPH, there are about 34,000 death certificate amendments each year. Approximately 5% of amendments are to correct spelling and technical errors, 10% are to add non-medical information that was unknown at the time of death, 50% are to make changes to the date, time, location, or cause of death, and 35% are categorized as miscellaneous. When an amendment is made to a death certificate it becomes a two page document. 

Proposed Law:

The bill requires:

• As soon as practicably possible, in coordination with a major upgrade or replacement of the information technology system, the State Registrar must include the functionality to replace an amended certificate of death with a new, one-page certificate of death.
• The new, one-page certificate of death be issued in place of the amended certificate.

Related Legislation:

1. The Legislature has recently deliberated proposals related to the State Registrar, including:

• AB 2561 (Flora, Chapter 147, Statutes of 2018) recasts and updates existing law governing the State Registrar, local registrar, and county recorder’s responsibilities related to the transfer, maintenance, and disposal of vital records.
• AB 2750 (Olbernolte, Chapter 131, Statutes of 2018) adds a deceased person’s surviving adult kin and a conservator to the list of persons allowed to obtain a certified copy of a death certificate.

Staff Comments:

The CDPH notes that the existing EDRS and FDRS are designed and programmed to add all amendments to a death record as an additional page. The two systems would need to be redesigned and reprogrammed to generate an amended replacement death certificate after registration of specified amendments, and seal/supplant the previous certificate. The cost of the redesign and the time necessary to implement system changes can only be estimated, unless a detailed proposal is submitted to the EDRS/FDRS system vendor at UCD.

In the future, a major upgrade or replacement of the IT system may cost up to $10 million, according to CDPH. Specifically, using the current cost of building EBRS as a reference, the redesign of the EDRS, FDRS, and VRBIS systems, including programming, contractor costs, user acceptance testing, project management and oversight, and training of statewide facility personnel, could be up to $10 million.

-- END --

SENATE COMMITTEE ON HEALTH

Senator Dr. Richard Pan, Chair

BILL NO: AB 2367

SUBJECT: Certificates of death: amended certificates

SUMMARY:

Requires the State Registrar, as soon as practicably possible and in coordination with a major upgrade or replacement of the information technology system, to include the functionality to replace an amended certificate of death with a new, one-page certificate of death. Requires the new, one-page certificate of death to be issued in place of the amended certificate.

Existing law:

1. Establishes the Department of Public Health (DPH) and sets forth its powers and duties, including, but not limited to, the duties as State Registrar relating to vital records and health statistics. [HSC §102100, et seq.]
2. Requires the State Registrar, local registrar, or county recorder to, upon request and payment of a fee, to supply an applicant with a certified copy of the record of a birth, fetal death, death, marriage, or marriage dissolution registered with the official. [HSC §103525]
3. Permits a person asserting an error in a birth, death, fetal death, or marriage certificate, whenever the facts are not correctly stated, to make an affidavit under oath stating the change is necessary to make the record correct, as specified, and file it with the state or local registrar. Requires the State Registrar, if the amendment is accepted, to transmit copies of the amendment to the local registrar and county recorder in whose offices copies of the original record and information are on file. [HSC §103225 and 103245]
4. Requires the State Registrar to send a certified copy of the newly amended record of birth, death or marriage to the applicant without additional charge, except for those amendments that are filed within one year of the date of occurrence of the event. Requires the amendment to be filed with and become a part of the record to which it pertains. [HSC §103250 and §103255]
5. Prohibits a vital record from being altered or changed in any respect after its acceptance for registration by a local registrar, except when supplemental information required for statistical purposes is furnished. [HSC §102140]

This bill: Requires the State Registrar, as soon as practicably possible and in coordination with a major upgrade or replacement of the information technology system, to include the functionality to replace an amended certificate of death with a new, one-page certificate of death. Requires the new, one-page certificate of death to be issued in place of the amended certificate.

FISCAL EFFECT:

According to the Assembly Appropriations Committee, one-time information technology system project costs are unknown, but this functionality will be folded into the next major upgrade or system replacement (Health Statistics Special Fund). Workload includes programming, contractor costs, user acceptance testing, project management and oversight, and training of statewide facility personnel.

PRIOR VOTES:

COMMENTS:

1. Author’s statement. According to the author, arguably, one’s original death certificate should match the name on their Social Security card, birth certificate, and driver’s license. Under existing law, however, an original death certificate may not be changed – even if to correct an error such as the misspelling of the deceased’s name. Instead, an addendum is stapled to the unchanged original death certificate. This practice is inconsistent with state laws governing birth certificates. For example, a new birth certificate may be issued to reflect a change of sex or change of name. Furthermore, unlike a marriage certificate, a death certificate is not available for review prior to being finalized because it is jointly filled out by a medical professional and a funeral director. Mistakes are often made at no fault to the deceased’s loved ones and are not caught until after the death certificate has been issued. Surely, a death certificate should be reissued to correct technical errors. It is neither respectful to the deceased nor compassionate to put family and friends through the anguish of seeing their loved one’s information – especially their name – misspelled or inaccurate on the death certificate.
2. The State Registrar. DPH’s Vital Records Registration Branch (VRRB) is charged with maintaining a uniform, comprehensive, and continuous index for all birth, death, fetal death, and marriage vital events which occur in California, of which are over one million each year. With regard to dissolution records, DPH maintains an index of only case numbers from 1962 to 1984. County superior courts maintain and issue the actual divorce decrees for all years. Certified copies of vital records are available from DPH, 58 county recorders, and 61 local health jurisdictions. DPH maintains, and can provide, birth and death records from 1905 to the present. At the local level, birth and death records for current-year events and one year prior are available from the county health department; records for all years are maintained by the county recorder.
3. EDRS. The California Electronic Death Registration System (EDRS) is a Web-based system that provides the ability for coroners, funeral directors, doctors, and hospitals to submit electronic death certificates. According to DPH, the first section of the record is usually completed by a funeral director in coordination with a family member or another individual best qualified to provide the deceased's personal information. The second section must be completed by a physician, medical examiner, or coroner to provide the medical and health data necessary, including information on the manner of death and investigation determinations. The funeral director submits the completed death certificate to the local registrar in the county where the death occurred, and from there it is forwarded to the State Registrar.
4. Death certificate amendments. Amendments are made to death certificates for various reasons, including correcting spelling errors, adding information not known at the time of death, or correcting factual errors. According to DPH, there are about 34,000 death certificate amendments each year. Approximately 5% of amendments are to correct spelling and technical errors, 10% are to add non-medical information that was unknown at the time of death, 50% are to make changes to the date, time, location, or cause of death, and 35% are categorized as miscellaneous. When an amendment is made to a death certificate it becomes a two page document. 
5. Related legislation. AB 2561 (Flora) recasts and updates existing law governing the State Registrar, local registrar, and county recorder’s responsibilities related to the transfer, maintenance, and disposal of vital records. AB 2561 is set for hearing on June 25, 2018 in the Senate Appropriations Committee.

AB 2750 (Olbernolte) adds a deceased person’s surviving adult kin and a conservator to the list of persons allowed to obtain a certified copy of a death certificate. AB 2750 is set for hearing on June 25, 2018 in the Senate Appropriations Committee.

SUPPORT AND OPPOSITION:

Support: None received

Oppose: None received

-- END --

ASSEMBLY THIRD READING

ATR Bill Id:AB 2367

Author:(Berman)

As Amended Ver:

Majority vote

SUMMARY: Requires the State Registrar, as soon as practicably possible, in coordination with a major upgrade or replacement of the information technology system, to include the functionality to replace an amended certificate of death with a new, one-page certificate of death. Requires the new, one-page certificate of death to be issued in place of the amended certificate once the functionality, as specified, is available.

FISCAL EFFECT: According to the Assembly Appropriations Committee, one-time information technology system project costs are unknown, but this functionality will be folded into the next major upgrade or system replacement (Health Statistics Special Fund). Workload includes programming, contractor costs, user acceptance testing, project management and oversight, and training of statewide facility personnel.

COMMENTS: According to the author, an individual's original death certificate should match the name on their Social Security card, birth certificate, and driver's license. However, under existing law, an original death certificate may not be changed – even if to correct an error such as the misspelling of the deceased's name. Instead, an amendment, a second piece of paper, is attached to the original death certificate. The author argues that this practice is inconsistent with state laws governing birth certificates. For example, a new birth certificate may be issued to reflect a change of sex or change of name. Furthermore, unlike a marriage certificate, a death certificate is not available for review prior to being finalized because it is jointly filled out by a medical professional and a funeral director. The author states that mistakes are often made through no fault of the deceased's loved ones and are not caught until after the death certificate has been issued. The author argues that a death certificate should be reissued to correct technical errors. The author concludes it is neither respectful to the deceased nor compassionate to put family and friends through the anguish of seeing their loved one's information – especially their name – misspelled or inaccurate on the death certificate.

Under existing law, a death certificate consists of three sections which require personal information, medical and health data, and coroner's information regarding death. The California Electronic Death Registration System is a Web-based system that provides the ability for coroners, funeral directors, doctors, and hospitals to submit electronic death certificates. According to the Department of Public Health (DPH), the first section is usually completed by a funeral director/home in coordination with the individual best qualified to provide the deceased's personal information. The second section must be completed by a physician/surgeon, medical examiner, or coroner to provide the medical and health data necessary, including information on the manner of death and investigation determinations. The funeral director will then send the completed death certificate to the local registrar in the county where the death occurred. The local registrar then forwards the locally registered death certificate to the State Registrar.

Amendments are made to death certificates for various reasons including, to correct spelling errors, add information not known at the time of death, or whenever facts are not incorrectly stated on a death certificate. According to DPH, on average there are 34,000 death certificate amendments each year. Approximately 5% of amendments are to correct spelling and technical errors, 10% of amendments are to add non-medical information that was previously unknown at the time of death, 50% of amendments are to make changes to the date, time, location, or cause of death, and approximately 35% of amendments are considered miscellaneous. It is important to note, there is no provision in law that authorizes the issuance of a new amended one page death certificate. When a death certificate is amended it automatically becomes a two page document. The original death certificate is currently prohibited by law to be amended.

Analysis Prepared by: Monica Montano / HEALTH / (916) 319-2097 FN: 0003375

Date of Hearing: April 25, 2018

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Lorena Gonzalez Fletcher, Chair

ABPCA Bill Id:AB 2367

Author:(Berman) – As Amended Ver:April 18, 2018

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill requires the State Registrar within the California Department of Public Health (CDPH) to issue a one-page replacement death certificate, upon a successful assertion by a person that the certificate to be replaced contains incorrect information.

It also requires the new certificate to supplant the original, be transmitted to the appropriate county recorder, and be the only death certificate open to public inspection.

FISCAL EFFECT:

1. One-time information technology system project costs are unknown, pending a detailed analysis and proposal for a systems update, but could be well in excess of $1 million based on similar systems redesign projects (Health Statistics Special Fund). Workload includes programming, contractor costs, user acceptance testing, project management and oversight, and training of statewide facility personnel.
2. Annual staff costs in the range of $250,000 to process an estimated 30,000 amended documents (Health Statistics Special Fund).

COMMENTS:

1. Purpose. Currently, amendments to a death certificate are reflected as such, as an attachment to the original certificate as issued. According to the author, it is disrespectful to a decedent's family to have a death certificate reflect a misspelled or incorrect name, and this occurs regularly as certificates are often not reviewed by family prior to their issuance. This bill seeks to instead replace the original certificate with an amended certificate that would not reflect the incorrect information.
2. Vital Records. Local registrars create and issue birth and death certificates based on such events, while county recorders maintain these records and issue certified copies. The State Registrar maintains the original documents and issues certified copies.
3. Current Amendment Process. Death records and amendments are registered in the state's Electronic Death Registration System (EDRS) and Fetal Death Registration System (FDRS) and subsequently exported to the state file system (FileNet), from which certified copies are generated. The EDRS and FDRS are designed to add all amendments to a death record as a separate page.

This bill would require the EDRS/FDRS to generate a new, corrected original, to be exported to the FileNet system. Currently, certified copies include the originally registered death record and any registered amendments to that record. FileNet, which holds and generates certified copies, does not accommodate automated supplanting or replacing of records.

1. Importance of Accurate Vital Records. Because of the critical importance of maintaining accurate records and the potentially serious consequences to individuals if vital records cannot be located or are incorrect, changes to vital records systems cannot be undertaken lightly. According to the summary of a workshop held by the National Academies in 2009 examining the U.S. vital statistics system, because vital records are legal documents, it is not trivial to make changes to them after they have been registered and filed. Families that want to correct or amend a record must follow detailed procedures prescribed by the jurisdiction. Typical examples of corrections are spelling, date, and typographical errors. Corrections and amendments must be treated carefully to ensure that the documentation is proper and to prevent fraud.
2. Related Legislation. AB 2561 (Flora), of the current legislative session, pending consideration in the Senate, revises requirements related to the transmission of birth and death records from local registrars to county recorders and to the State Registrar. It modifies the same code section as this bill but does not conflict on a substantive policy basis.

Analysis Prepared by: Lisa Murawski / APPR. / (916) 319-2081

Date of Hearing: April 3, 2018

ASSEMBLY COMMITTEE ON HEALTH

Jim Wood, Chair

ABPCA Bill Id:AB 2367

Author:(Berman) – As Introduced Ver:February 14, 2018

SUBJECT: Certificates of death: amended originals.

SUMMARY: Requires the State Registrar to issue an amended original certificate of death if an assertion is made that the facts are not correctly stated on a certificate of death and the incorrect information does not change a finding, conclusion, or determination and requires an amended original certificate of death to be transmitted with the amendment to the local registrar and county recorder in whose offices copies of the original record and information are on file.

EXISTING LAW:

1. Establishes the Office of Vital Records within the Department of Public Health (DPH) to maintain a uniform system for registration and a permanent central registry with a comprehensive and continuous index for all birth, death, fetal death, marriage and dissolution certificates registered for vital events which occur in California. Requires the Director of DPH, acting as the State Registrar, to administer the registration of births, deaths, fetal deaths, and marriages.
2. Requires each death to be registered with the local registrar of births and deaths in the district in which the death was officially pronounced or the body was found, within eight calendar days after death and prior to any disposition of the human remains.
3. Requires a funeral director to prepare the certificate and register it with the local registrar and to obtain the required information, other than medical and health data, from the person or source best qualified to supply this information.
4. Requires the first section of a death certificate to contain those items necessary to establish the fact of the death, including personal data concerning decedent including full name, sex, color or race, marital status, name of spouse, date of birth and age at death, birthplace, usual residence, and occupation and industry or business.
5. Requires the medical and health section data and the time of death to be completed by the physician and surgeon last in attendance, or in the case of a patient in a skilled nursing or intermediate care facility, by a licensed physician assistant legally authorized to certify and attest to the facts, or in certain cases, to be completed by the county coroner.
6. Requires the second section to contain those items relating to medical and health data.
7. Prohibits any alteration or change in any respect shall be made to any marriage license or certificate after its acceptance for registration by the local registrar except where supplemental information required for statistical purposes is provided.
8. Requires the State Registrar to transmit copies of accepted amendments to the local registrar and county recorder in whose offices copies of the original record and information are on file.
9. Authorizes an affidavit to be made by the person asserting that the error exists, whenever the facts are not correctly stated in any certificate of death already registered, but must be supported by the affidavit of one other credible person having knowledge of the facts, and filed with the state or local registrar.
10. Requires the State Registrar, a local registrar, or a county recorder, upon payment of a required fee, to supply applicants a certified copy of birth, fetal death, death, marriage, or divorce records.

FISCAL EFFECT: This bill has not yet been analyzed by a fiscal committee.

COMMENTS:

1. PURPOSE OF THIS BILL. The author argues that, one’s original death certificate should match the name on their Social Security card, birth certificate, and driver’s license. However, under existing law, an original death certificate may not be changed – even if to correct an error such as the misspelling of the deceased’s name. Instead, an amendment, a second piece of paper, is attached to the original death certificate. The author argues that this practice is inconsistent with state laws governing birth certificates. For example, a new birth certificate may be issued to reflect a change of sex or change of name. Furthermore, unlike a marriage certificate, a death certificate is not available for review prior to being finalized because it is jointly filled out by a medical professional and a funeral director. The author states, that mistakes are often made at no fault to the deceased’s loved ones and are not caught until after the death certificate has been issued. The author argues that a death certificate should be reissued to correct technical errors. The author concludes it is neither respectful to the deceased nor compassionate to put family and friends through the anguish of seeing their loved one’s information – especially their name – misspelled or inaccurate on the death certificate.
2. BACKGROUND.
   1. Death Certificate Process. Under existing law, a death certificate consists of three sections which require personal information, medical and health data, and coroner’s information regarding death. The California Electronic Death Registration System, is a Web-based system that provides the ability for coroners, funeral directors, doctors, and hospitals to submit electronic death certificates. According to DPH, the first section is usually completed by a funeral director/home in coordination with the individual best qualified to provide the deceased’s personal information. The second section must be completed by a physician/surgeon, medical examiner, or coroner to provide the medical and health data necessary, including information on the manner of death and investigation determinations. The funeral director will then send the completed death certificate to the local registrar in the county where the death occurred. The local registrar then forwards the locally registered death certificate to the State Registrar.
   2. Amendments to Death Certificates. Amendments are made to death certificates for various reasons including, to correct spelling errors, add information not known at the time of death, or whenever facts are not incorrectly stated on a death certificate. According to DPH, on average there are 34,000 death certificate amendments each year. Approximately 5% of amendments are to correct spelling and technical errors, 10% of amendments are to add non-medical information that was previously unknown at the time of death, 50% of amendments are to make changes to the date, time, location, or cause of death, and approximately 35% of amendments are considered miscellaneous. It is important to note, there is no provision in law that authorizes the issuance of a new amended one page death certificate. When a death certificate is amended it automatically becomes a two page document. The original death certificate is currently prohibited by law to be amended. When requesting an authorized certified copy of an amended death certificate an individual must provide the following items to DPH-Vital Records:
      1. Completed Affidavit to Amend a Record;
      2. Separate Form stating corrections;
      3. Signed and notarized Sworn Statement; and,
      4. Appropriate fee, $21 if death occurred within a year.
3. RELATED LEGISLATION.
   1. AB 2561 (Flora) would delete and recast existing law and instead require each local registrar to transmit a copy of each original birth certificate and death certificate to the county recorder for the special county record, and at the same time, forward the original certificate to the State Registrar. AB 2561 is currently pending in the Assembly Health Committee.
   2. AB 2750 (Obernolte) would authorize an appointed conservator of a person or estate to request a certified copy of a death certificate. AB 2750 is currently pending in the Assembly Health Committee.
4. PREVIOUS LEGISLATION.
   1. SB 179 (Atkins), Chapter 853, Statues of 2017, requires the State Registrar to issue a new birth certificate if an individual submits application to change gender status or to nonbinary status.
   2. AB 1726 (Health Committee), Chapter 215, Statues of 2017, authorizes access to the confidential portion of any certificate of live birth or fetal death, the electronic file of birth information, and the birth mother linkage information to DPH, the Department of Health Care Services, and the Department of Finance.
   3. AB 1546 (Olsen), Chapter 255, Statues of 2016, permits local registrars to release vital record indices to the county recorder within its jurisdiction for purposes of the preparation or maintenance of the indices of the county recorder.
   4. AB 2636 (Linder), Chapter 527, Statues of 2016, authorizes until January 1, 2021, if a request for a certified copy of a birth, death, or marriage record is made electronically, a state or local official to accept electronic acknowledgement verifying the identity of the applicant using a multilayered remote identity proofing process.
   5. AB 1053 (Mathis), 2015, would have required the local registrar to make information on veteran suicide available to the Department of Veterans Affairs and the United States Department of Veteran Affairs. AB 1053 died in the Assembly Health Committee.
   6. AB 464 (Daly), Chapter 78, Statutes of 2013, allows digitized images, as defined, to be included as part of a request for a certified copy of a birth, death, or marriage record.
   7. AB 247 (Speier), Chapter 914, Statutes of 2002, authorizes the State Registrar, local registrar, or county recorder to provide a certified copy of a birth or death record to an authorized person who submits a statement sworn under penalty of perjury that the requester is signing his or her own legal name and is an authorized person.

REGISTERED SUPPORT / OPPOSITION:

Support

None on file.

Opposition

None on file.

Analysis Prepared by: Monica Montano / HEALTH / (916) 319-2097