SENATE COMMITTEE ON

BUSINESS, PROFESSIONS AND ECONOMIC DEVELOPMENT

Senator Steven Glazer, Chair

2019 - 2020 Regular

Bill No: SB 1054 Hearing Date: May 18, 2020

Subject: Physical Therapy Licensure Compact

SUMMARY:

Requires California to join the Physical Therapy Licensure Compact (Compact), thereby granting an out-of-state applicant a valid privilege to practice physical therapy in California and changing existing out-of-state applicant licensing procedures, as well as enforcement, administrative, fee, and data requirements for those privilege holders.

NOTE: Due to the COVID-19 Pandemic and the unprecedented nature of the 2020 Legislative Session, all Senate Policy Committees are working under a compressed timeline. This timeline does not allow this bill to be referred and heard by more than one committee as a typical timeline would allow. In order to fully vet the contents of this measure for the benefit of Senators and the public, this analysis includes information from the Senate Committee on Judiciary.

Existing law:

1. Establishes the Physical Therapy Practice Act (Act) and requires any individual practicing physical therapy (PT) in California to be licensed by the Physical Therapy Board (Board). (Business and Professions Code (BPC) § 2630)
2. Establishes the Board to regulate the practice PT with the authority to: evaluate qualifications of applicants for licensure; provide for the examination of PTs and physical therapists assistants (PTAs) and establish a passing score for each examination; issue all licenses for the practice of PT in California; suspend and revoke licenses and otherwise enforce its provisions in the relevant portion of the BPC; administer a continuing competency program; participate in applicable committee meetings of the Federation of State Boards of Physical Therapy; publish, at least annually, a newsletter detailing board action; among other things. (BPC § 2605)
3. Requires applicants for licensure be 18 years old at the time they apply, not be addicted to drugs or alcohol, have completed specified education and training requirements, and not committed crimes defined for denial of licensure. (BPC § 2635)
4. Makes it illegal for a person to practice or offer to practice PT for received or expected compensation or hold themselves out as a PT, unless explicitly excepted or a person holds a valid, unexpired, and unrevoked PT license. (BPC § 2630)
5. Requires compliance with PT education requirements, including graduating from an accredited, postsecondary degree program and completing required coursework and an internship in PT, with specific requirements. (BPC § 2650)
6. Allows the Board to issue a citation, impose discipline, deny a license, suspend for not more than 12 months, or revoke, or impose probationary conditions upon any license issued under this chapter for unprofessional conduct. (BPC § 2660)
7. Allows an applicant to receive a license without a written examination if the applicant is already licensed in another state, district, or territory and the Board agrees the applicant has the licensing requirements equal to or higher than those in California. The applicant also has to have passed a licensing examination comparable to California’s examination, graduated from a PT or PTA education program approved by the Board, or met the requirements in BPC Section § 2653 for those who graduate from a PT licensing program not approved by the Board and outside of the United States. (BPC § 2636.5)
8. Permits the Board to require an applicant for licensure in California who is already licensed in another state to provide a statement of past work activity. (BPC § 2636.5(b))
9. Allows a first-time applicant who has filed a PT application to perform as a PT or PTA between receiving notice the application has been filed and receiving a license as long as the applicant is supervised by a California licensed PT. During this period of time, the applicant shall identify themselves as a “physical therapist license applicant” or “physical therapist assistance license applicant,” as appropriate. If the first-time applicant does not qualify and receive a license under this section and does not qualify, the Board may revoke these privileges. An applicant may only qualify once to perform as a PT license applicant or PTA license applicant. (BPC §§ 2636.5; 2639)
10. Requires a licensed PT to provide “direct and immediate” supervision of the applicant in order for an applicant to perform as a PT in California while waiting for a license. Direct and immediate means: 1) a supervisor shall at all times be responsible for and provide adequate supervision of the work performed by the applicant, and 2) shall be in close proximity to the location where the applicant is assisting in the provision of PT treatment. (16 CCR § 1399.12)
11. Requires any PTA license applicant to document each treatment in a patient record with their signature. A supervising PT shall countersign with his or her first initial and last name in the patient's record on the same day as patient related tasks were provided by the PTA license applicant. A supervising PT will conduct a weekly case conference and document it in the patient record. (16 CCR § 1399.12)
12. Requires under the Bagley-Keene Act that the meetings of public bodies and the writings and public officials and agencies must be open to public scrutiny. Additionally, the Act explicitly mandates all California state agencies, boards, and commissions have open meetings. (Government Code (GC) § 11120-111321)
13. Requires under the California Public Records Act that all records must be inspected or disclosed to the public upon request. (GC § 6250-6270)
14. Allows the state to extend deadlines for certain members of the public who might require more time to participate in the public process. (GC § 11125.7)

This bill:

1. Enacts the Compact through which each member state is required to grant a Compact privilege to a PT or PTA holding a license in another state under certain conditions.
2. Requires a criminal background check of applicants through the Federal Bureau of Investigation (FBI).
3. Authorizes a member state to charge a fee for granting a Compact privilege. Clarifies that the bill would prohibit fees collected by the Board for purposes of granting a Compact privilege from exceeding the cost of administering the privilege under the Compact and would require the fees to be deposited in a Physical Therapy Fund.
4. Requires the Board to select a delegate to be a member of the Physical Therapy Compact Commission (Commission), a joint public agency authorized to promulgate uniform rules in accordance with specified rulemaking procedures to implement the compact.
5. Authorizes an Executive Board of the Commission to act on behalf of the Commission, and would specify the Executive Board’s duties, including recommending changes to fees.
6. Authorizes the Commission to levy and collect an annual assessment from each state or impose fees on other parties to cover the costs of the operations and activities of the Commission.
7. Outlines different enforcement authority for states where the applicant is a primary license-holder and a “remote state” where the applicant is a privilege-holder.
8. Requires that continuing education requirements (CEs) only be met in the state in which an applicant received a primary license.
9. Requires particular medical and liability insurance.

1. Requires the Board to transmit specified data on licenses to a coordinated database and reporting system maintained by the Commission.
2. Specifies that the provisions of the Compact and rules promulgated pursuant to the Compact have the force and effect of state law.
3. Voids and makes unenforceable any provisions of the compact if they violate the US Constitution, the CA Constitution, or any state or federal statute or regulation.
4. Requires that all disputes with the Compact are heard in a competent court of jurisdiction where the Compact has its principal place of business.

FISCAL EFFECT:

Unknown. This bill is keyed fiscal by Legislative Counsel.

COMMENTS:

1. Purpose. The Author is the Sponsor of this bill. According to the Author, “[B]y requiring California enter into the Physical Therapist Compact (PT Compact), which is an interstate licensure agreement that provides licensing reciprocity for Physical Therapists (PTs) and Physical Therapist Assistants (PTAs)…PTs and Pas in other compact states (currently there are 26) would be eligible to practice PT in California, and California’s PTs and PTAs would likewise be eligible to practice in those states.”
2. Background and Compact Administration. California PTs are currently regulated by the Board. In order to become licensed to practice, an applicant must complete Board-approved education requirements, take and pass a licensing examination, be fingerprinted for a criminal background check with Department of Justice (DOJ), and submit all required materials to the Board for consideration. After obtaining licensure, the Board requires thirty hours per year of CE. In 1991, the Board adopted the standardized national licensing examination with the recommended standardized passing score. California also developed expedited licensing processes in the last few years to allow those out-of-state applicants to practice in the state.

With a standardized exam format and passing score, an idea like the Physical Therapy Licensure Compact flourished. By joining the Compact, PTs already licensed in one state can gain a privilege to practice in another or multiple compact-member states. In 2016, Oregon became the first state to sign onto joining the Compact. According to the Compact website, today there are twenty states actively operating within the Compact and eight states that have passed legislation to join the Compact. On average, it takes eight to twelve months for a state to join the Compact and begin operation.

The PT Compact has a Commission in charge of its administrative proceedings. The Commission is comprised of one delegate from each state. Each state delegate is selected by the member state’s licensing board. Each delegate is entitled to one vote in proceedings regarding promulgating rules and creating bylaws and will otherwise participate in the business of the Commission. The Commission will meet once a year unless otherwise specified in the bylaws. The Commission also has an Executive Board. That Executive Board is comprised of seven voting members who are elected by the Commission from the Commission’s current membership and two non-voting members. The Executive Board recommends changes to the rules or bylaws of the Commission, changes to this Compact legislation, fees paid by Compact member states such as annual dues, and any commission Compact fee charged to licensees for the compact privilege. The Executive Board also prepares and recommends a budget, maintains financial records on behalf of the Commission, and monitors Compact compliance of member states and provides compliance reports to the Commission, among other things.

States that join the Compact must follow the Compact’s rules. There are a number of key differences between the rules and processes of the Compact and the Board. This means that for California to join the Compact, there are a number of requirements that must be met and changes that must be made.

Changes in Licensing Requirements: Background Checks (FBI v. DOJ). Under current law, California requires all PT applicants to provide a fingerprint at the time of application. An applicant then receives a background check at the time of application through DOJ and the Board is informed of any criminal offenses licensees receive in the future. This is a relatively easy process because all state criminal offenses are recorded by DOJ. The Board in the past has worked with applicants who have a criminal history who, in most cases, were ultimately licensed. For example, in fiscal year 2018-19, 155 of 2,770 applicants had criminal records. 57 of those applicants were out-of-state applicants. Only 2 of the 155 applicants were denied licensure, but both applicants’ denials were stayed and both were issued initial probation licenses.

The Compact requires that all privilege holders go through an FBI criminal background check process. The Compact background check procedures differ from California’s existing procedures in two ways. First, applicants are only checked once at the time of application for offenses and therefore neither the Compact nor any state where privilege-holders practice is notified of any potential future criminal offenses they might commit. Second, the FBI does not report as many crimes as the DOJ. This is because the National Crime Information Center (NCIC) database is not always consistent in the types or amount of violations that it collects from criminal justice agencies. NCIC relies on criminal justice agencies to input crimes, so if those agencies do not input the information or do not have relevant information for the Board, the Board (and the Commission for that matter) will not know about the potential criminal history of an applicant. Additionally, the Compact’s enforcement options described in more detail below do not allow the flexibility for the Board to work with applicants with a criminal background toward licensure as it has done in the past. Therefore, should the Board receive concerning information via the FBI background check about a privilege-holder, the only options to address the situation according to existing Compact language are to remove a licensee’s Compact privilege, impose fines, or take “any other necessary actions to protect the health and safety of [the state’s] citizens.”

Additionally, this background check would provide a two-tiered system for checking criminal history in California applicants: one for applicants who are opting to the be licensed in the state using existing state procedures (DOJ), and one for applicants who are opting to practice in the state through the Compact privilege (FBI). This creates an inconsistent standard for evaluating an applicant in California both at the time of application and into the future. The lack of criminal background information for applicants who join the Compact and the lack of enforcement mechanisms provided to the state by the Compact deny the Board an opportunity to work toward licensure with applicants with criminal records as the Board has done in the past. Therefore, out-of-state applicants with criminal backgrounds could be denied avenues toward licensure that they otherwise could have had if they applied through the existing state licensure process.

Changes in Promulgating Rules and California Representation. The Compact also requires that rules and regulations are promulgated by the Compact Commission, rather than through typical state processes. In a typical state process, a state agency controls what is a reasonable timeframe for public comment and revision before the regulation or rule goes into effect depending on existing circumstances. A state agency also has the ability to extend deadlines for certain members of the public who might require more time to participate in the public process. The Bagley-Keene Act also requires that the meetings of public bodies, writings, and the public officials and agencies must be open to public scrutiny. Additionally, the Act explicitly mandates all California state agencies, boards, and commissions have open meetings. Finally, the Public Records Act requires that all records must be inspected or disclosed to the public upon request. Because California must assimilate to the Compact’s rules if it were to join, it is unclear whether or to what extent the requirements and spirit of the Bagley-Keene Act and the Public Records Act will be met.

In the Compact, in order to change rules or regulations the full Commission must meet, allow thirty days for comment, send the proposed amendments to each state for public comment, and vote on each of the rules. The Commission allows for one delegate per state to join with one vote per delegate. However, the body that puts forward these changes, known as the Executive Board, may only have seven elected voting members and two non-voting members. Therefore, given that at least twenty-eight states will be part of the Compact by the time California would join, there is no guarantee that a California state representative can be a part of the Executive Board that will propose changes to rule and bylaws.

Applying for and Receiving a License: How Much Delay in Allowing Work for Out-of-State Applicants? The Compact would provide a privilege to practice within a member state between one day and a few weeks of beginning an application. California already has mechanisms to expedite the approval process of non-state licensed PTs and PTAs within a few weeks.

Additionally, the state also already provides an opportunity for licensed PTs in other states to come to California and immediately begin practicing and earning a paycheck under the supervision of a California-licensed PT while they wait for their applications to process. Supervision must be “direct and immediate”: a supervisor must always be responsible for and provide adequate supervision of an applicant’s work and be in close proximity to the location where the applicant is assisting in providing PT treatment. If finding a supervisor proves manageable, applicants using the existing state system can immediately practice and receive a paycheck while waiting for a California license. If finding a supervisor proves difficult, an applicant through the Compact may or may not receive their license faster than applicants through the existing state system given that each process could take around a few weeks. Given these existing regulatory options, the argument that joining the Compact will provide more opportunities for licensed non-state PTs to practice quickly in California may or may not be true.

Enforcement. Under current state practices, the Board may take a multitude of actions upon receiving news that a licensee had committed a criminal offense. It can do nothing, issue a citation or probationary orders, or deny licensure, among other actions. In contrast, the language of the Compact states that a “home state shall have exclusive power to impose adverse action against a license issued by the home state.” That means that the Compact believes that the state where the person is originally licensed will handle enforcement. However, the Compact also states that a remote state, or a state that has privilege-holding PT professionals, may “remove a licensee’s compact privilege in the remote state for a specific period of time, impose fines, and/or take any other necessary actions to protect the health and safety of its citizens.” The question remains open as to what actions are considered “necessary” ones that a remote state could take that would qualify as protecting the health and safety of a remote state’s citizens. It is worth noting that enforcement mechanisms would be different for those who are licensed in the state vs. those who hold compact privileges, which could lead to privilege-holders losing licenses rather than the Board having the authority to issue citations or probationary orders.

The Compact also does not specifically address where a case against a licensee should be heard if one is brought. For example, would a suit against a licensee in California have the case heard in California, the state where the PT is originally licensed, or another location? By stating that the Compact has exclusive power to impose adverse action against a license issued in a home state, it might be implied that cases against licensees would be heard in that state. Additionally, the Compact does say that a remote state could issue subpoenas for hearings and investigations into a privilege-holding PT professional, but does not delegate any authority to hear the case to remote states.

The Compact also states that any case would be heard in the venue with its principal place of business, which is in Alexandria, Virginia. In legal proceedings, venue is the location where the lawsuit can be filed and the place where the case can be heard. The Compact states that the venue for any disputes that arise against the Compact will be in the Compact’s principal place of business, which is in Alexandria, Virginia. Should any disputes arise that require legal action against the Compact, those interested in bringing the action will have to go to Virginia. These issues will likely remain if California were to join the Compact unless the Compact were to provide clarity or revision on the subject.

Fees. California currently charges out-of-state applicants who are gaining the ability to practice through California’s expedited licensing process an amount close to in-state-applicants seeking licensure in the state ($150/yr). The state also requires a small fee for necessary fingerprints for the expedited licensing process. The Compact charges $45 per member for the privilege of having a Compact privilege with one state, which it states is enough to stay within its budget. Its annual budget is around $6,000/yr. The Compact says that each state is not required to charge a fee for privilege-holders to join the Compact, but each state could. However, the language of the bill clarifies that the Board could not, for the purposes of granting a privilege, collect fees exceeding the cost of administering a Compact privilege and would require that the fees be deposited in the Physical Therapy Fund. The Compact argues that joining could be a financial benefit to the state for a number of reasons, even citing removing licensure rather than having the option to engage in other enforcement procedures that would require finances as a potential cost saving. Given the disparity in fees, there is some question as to whether $45 per member could keep an organization like the Compact going when the Board would likely have to charge its original licensing fee for non-state applicants to cover its existing costs. Additionally, the Compact assesses fees for privilege-holders depending on when an applicant’s home state requires payment of licensing fees. For example, California assesses fees biannually, so a California-licensed PT that had a privilege through a Compact would pay all of their fees once every two years.

No Shortage of PTs or PTAs in California. California currently has 16 accredited PT schools in the state, each producing between 50-100 applicants per class. Some PT schools produce two classes per year. This means that each year, between 50-200 applicants for the profession are produced per year, bringing the total number to between 800-3,200 graduates per year. Reports indicate that California needs 1600 PTs and 900 PTA jobs annually. Last year, around 3,000 people applied for licensure as PTs and PTAs in California. 30-40% of those were applicants from out of state. There does not seem to be a shortage in the profession at this time.

Continuing Education Credits. Anyone who joins the Compact will only have to complete continuing education (CE) requirements if that person’s licensing state of origin requires it. California requires thirty hours of CE requirements per year, but some states require less. This means that, were California to join the Compact, some privilege-holders licensed in another state might not be required to take as many CE requirements as those who were licensed in California. But those privilege-holders will be able to practice in California.

Liability and Medical Insurance. The Compact states that the process for licensed PTs to get liability coverage remains the same as it would under the existing process in California. The Compact indicated there were initial difficulties in receiving MediCare reimbursement, but that this problem has since been resolved.

Data Privacy. Currently, California uses a secure, encrypted database system to provide data of licensees to the Federation of State Boards of Physical Therapy (the Federation), such as examination scores. The Compact currently also requires Compact states to provide data to the Federation. Should remote states need information about a privilege-holder, they could search this database. It is still unclear how the Compact would ensure consent and data privacy of California-licensed PTs and PTAs who might want to take advantage of privilege-holder status.

1. Senate Judiciary Committee issues. This bill raises various issues within the jurisdiction of the Senate Judiciary Committee, including, among others, limited liability, public access to meetings and records, delegation of legislative authority, and privacy.  The Senate Judiciary Committee has historically tended to disfavor the types of immunities and limitations on liability that exist within this bill.  The Judiciary Committee has also historically disfavored legislation that provides for the sharing of personal information of Californians without adequate protections.  This bill appears to require the sharing of personal information, with other states, about licensees without the licensees’ affirmative permission.  Moreover, the bill would require California to disclose information about California licensees as determined by the out-of-state Commission and turn over all investigative documents and information requested by another party state.  Of particular concern is the provision that provides that “notwithstanding any other provision of state law to the contrary, a member state shall submit a uniform data set to the data system on all individuals to whom this Compact applies as required by the rules of the Commission…” 

This bill also contains provisions that will bind California to terms that are established in the future by an out-of-state Commission on which California has very limited representation.  Specifically, the Commission, under this Legislation, would have the power to promulgate rules that “shall have the force and effect of law and shall be binding in all member states.”  Additionally, the bill provides that the “provisions of the Compact and the rules promulgated hereunder shall have standing as statutory law” and the bill requires that the “executive, legislative, and judicial branches of state government in each member state shall enforce this compact and take all actions necessary and appropriate to effectuate the Compact’s purposes and intent.”  This Commission will also operate outside of California’s open meeting and open records requirements.  The Committee may wish to ensure that the open meeting requirements of the Commission must be consistent with the Bagley-Keene Act and public records requirements of the Commission must be consistent with the California Public Records Act.  The bill also contains provisions that would prohibit specified future legislation from taking effect until six months after legislation would otherwise be effective, effectively binding a future legislature to the decisions that are made by today’s legislature.  (See County Mobilehome Positive Action Committee v. County of San Diego (1998) 62 Cal.App.4^th 727, 734, "An act of one legislature is not binding upon, and does not tie the hands of future legislatures [citations omitted];" and see State Bd. of Dry Cleaners v. Thrift-D-Lux Cleaners (1953) 40 Cal.2d 436, 447 regarding the prohibition against delegation of legislative power.) 

1. Related Legislation This Year. SB 1053 (Moorlach) enacts the Nurse Licensure Compact which would authorize the Board of Registered Nursing (BRN) to issue a multistate license to practice as a registered nurse and the Board of Vocational Nursing and Psychiatric Technicians (BVNPT) to issue a multistate license to practice as a licensed vocational nurse, in all party states under a multistate licensure privilege and designates the BRN and the BVNPT to alternate as the administrator of the NLC for California. (Status: This bill will also be heard by the Committee on May 18.)

AB 3016 (Megan Dahle of 2020) would require the BRN in consultation with the DCA to develop recommendations for the implementation of the Nursys online license verification system, as specified. (Status: This bill is currently pending in the Assembly Committee on Business and Professions.)

1. Arguments in Support . AMN Healthcare argues that joining the Compact is necessary given an increasingly mobile society, changes to the access and delivery of health care, and changes to the delivery model of education. AMN believes that the Compact will allow patients access to needed PT services while also encouraging greater protection and provider accountability, and fostering a 21^st century model for healthcare delivery.

The California Association of Health Facilities argues for California to join the Compact because more PTs and PTAs would help meet rising demand for such professionals in aging populations. It would also provide patients with a wider pool of applicants that might provide more opportunities for specialized care.

According to the California Association of Health Services at Home, this policy will increase the number of PTs and PTAs in California, a policy it has long supported. This is particularly the case now given the expanding aging population.

The California Defense Communities Alliance believes that California joining the Compact will facilitate access to the profession particularly for military spouses who are stationed in the state.

According to the California Hospital Association, the bill would reduce “costs for hospitals and interstate health care systems by easing the administrative and financial barriers associated with multi-state practice. It would also improve educational opportunities, as virtual education and visiting instructors could be utilized as part of a physical therapy curriculum.”

The California Physical Therapy Association argues that a health manpower shortage in physical therapy professionals will be solved by California joining the Compact. It also argues that joining the Compact will improve access to PT services, increase choice of PT providers, and facilitate alternative methods of delivery of services such as telehealth.

CORE Rehabilitation Services, Inc. writes that California should join the Compact because the Compact would provide an opportunity for the company to expand outside of California and place physical therapy professionals in other states.

According to the Department of Defense, California should join the Compact because it would more quickly allow military spouses in the profession to gain licensure and begin working and earning a paycheck. The department also believes joining the Compact would improve continuity of care, improve access to and provide more choice of physical therapy providers, and facilitate telehealth and other alternative healthcare delivery methods.

KPG Healthcare argues that California should join the Compact for increased availability of quality physical therapy professionals in the state to meet the increased needs of all, including an increased aging population. It will also provide additional telehealth opportunities.

OCHIN, California Telehealth Network believes that California joining the Compact will increase the mobility of its physical therapy community. It argues the Compact will also increase opportunities for California licensees by allowing them the ability to be licensed in other Compact states, work via telehealth, and potentially work as visiting instructors or otherwise participate in new virtual education models and platforms.

The San Diego Military Advisory Council argues for California to join the Compact to reduce licensing challenges of military spouses since these challenges are the top contributor to military spousal unemployment.

1. Policy Issues for Consideration.

Data Privacy and Consent. While California and the Compact use the same secure, encrypted system and report information to the Federation, there is nothing that says that currently California licensee information is searchable by other states within that database. As described above, the Compact assumes that all privilege-holders are comfortable with sharing their licensing information with other states, or this is at least a cost of joining the Compact. If addressed with informed consent options and alternatives, this does not have to be the case. Given that California has some of the strongest privacy laws in the country, it is important to consider alternatives that will allow licensees to keep sensitive information private if they so choose.

Sunset Review Oversight. The Board is subject to the Legislature’s sunset review oversight process which, through public hearings and materials, allows for an evaluation of each program and a comprehensive means by which to make necessary changes to board operations and the regulation of the profession. The Board will be reviewed by the Legislature in the near future.

There is a strong argument that this idea is better assessed during the sunset review process because it questions the very structure and functionality of the Board and PT professional licensing process. Topics for discussion typically include an evaluation and assessment of any changes that need to be made to agency process, including: licensing requirements, CEs, enforcement, rule changes, fees, renewals, and other administrative tasks.

Almost all of these topics are ripe for discussion with SB 1054. Are background checks conducted through the FBI and not DOJ, combined with the lack of enforcement options for remote states, going to leave California with fewer options to work toward licensure for those with criminal backgrounds just when the state has a track record of helping these applicants? Will the requirements of Bagley-Keene and the Public Records Act be met if California were to join the Compact, and will California have enough of a say in the changes the Compact decides to make in the future? Do the existing supervision and expedited processes for receiving licenses from out-of-state applicants adequately allow for entering and quickly having the ability to practice within the state? How should the disparity in fees between those collected by California and the Compact be addressed? Does it matter that there does not appear to be a workforce shortage of PTs and PTAs in the state? How should the lack in consistency of CEs between California-licensed PTs and privilege-holder PTs?

Even the Author’s main arguments for the bill focuses on issues related to sunset review. He argues that: the current licensing system is based on antiquated model where applicants go to school, become licensed in one state, and practice in that state for their lives, whereas the Compact is a way to provide more mobility and practice opportunity between states; allowing more PTs into the state will increase the provided quality of care; the Compact will immediately allow those like military spouses and traveling PTs and PTAs to work six- to eighteen-month jobs in rural areas where clinics and hospitals need more people to work; joining the Compact will reduce costs for hospitals and interstate healthcare systems by easing the administrative financial barriers associated with multi-state practice; mobility will also increase virtual educational opportunities. These are all issues that at their heart ask the question, “Is the current system working? Or is it time to make a change?”

Because these issues review and question the current structure of the Board itself, because there are a number of programmatic issues listed above to analyze, and because doing so through the sunset review process will provide more time to fully consider these issues, it is strongly advisable to discuss this conversation during the Board’s next sunset review.

SUPPORT AND OPPOSITION:

Support:

AMN Healthcare

California Association of Health Facilities
California Association for Health Services at Home

California Hospital Association

California Telehealth Network (OCHIN)
California Defense Community Alliance (San Diego Military Advisory Council, Monterey Bay Defense Alliance, Beale Military Liaison Council, China Lake Alliance, Regional Defense Partnership for the 21st Century)

CORE Rehabilitation Staffing

California Physical Therapists Association
Department of Defense

KPG Healthcare

242 Individuals

Opposition:

None on file

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