Senate Standing Committee on Business, Professions and Economic Development

Good morning, everybody. Welcome to the third and final sunset review oversight hearing, which is once again being held jointly by the Assembly Business and Professions Committee and the Senate Committee on Business Professions and Economic Development. Today, we will be hearing from five entities responsible for overseeing regulated professionals in California, the respite the Respiratory Care Board, the California Council for Interior Design, the Speech Language Pathology and Audiology and Hearing Aid Dispensers Board, the board of occupational therapy, and the board of naturopathic medicine.

For each portion of today's hearing, we will begin by hearing from representatives of the entity under review. Next, we will open the discussion up for questions or comments from committee members.

Finally, we will invite other interested stakeholders here in the room to provide public comment. Speakers will be limited to a maximum of two minutes per organization. In the interest of time, additional speakers making substantially similar comments will be asked to simply provide their name and state their alignment with prior testimony. I'm looking forward to a productive discussion today and would like to thank committee staff for all their hard work throughout this process. Before we begin, I will I take that back.

We are just going to begin. So today's hearing will begin with representatives of the respiratory care. Good morning. Today's hearing will begin with representatives of the respiratory care board. Testifying today is Ricardo Guzman, board president, and Christina Molina, executive officer, and we are ready whenever you are. Come on up. Thanks so much.

Good morning. Can you hear me? Okay. Excuse me. Good morning, chair chairman Berman and members of the committee.

Thank you for the opportunity to appear before you today as part of the sunset oversight review process. My name is Ricardo Guzman, and I'm the president of the respiratory care board. I'm joined today by vice president Raymond Hernandez and our executive officer Christine Molina. On behalf of the board, I wanna thank the committee and his staff for the time and care devoted to reviewing our sunset report and for the thoughtful questions provided in advance of today's hearing.

We appreciate this process and view it as an important opportunity to reflect on our work, identify areas for improvement, and reaffirm our commitment to public protection.

The board's mission is to protect and serve consumers by licensing qualified respiratory care practitioners, enforcing the provisions of the Respiratory Care Practice Act, expanding the availability of respiratory care services, increasing public awareness of the profession, and supporting the development and education of respiratory care practitioners. Every action the board takes, whether related to licensing or enforcement, is guided by this core responsibility to protect the public. Respiratory care practitioners provide highly specialized, often life sustaining care under physician supervision.

They play a critical role in the prevention, diagnosis, treatment, and management of cardiopulmonary conditions, serving patients ranging from those on life support to individuals with chronic and acute illnesses in various settings. Since our last sunset review, the board has focused on strengthening consumer protection, improving operational efficiency, and responding responding thoughtfully to changes in health care delivery.

This includes modernizing our licensing processes, enhancing enforcement consistency, and engaging in significant regulatory work to clarify scope of practice and address emerging patient safety issues. While this work has not been without challenges, the board has approached this issue with transparency, deliberation, and a strong commitment to stake stakeholder engagement. The board implemented new continuing education framework to better align license education with public protection goals.

The board conducted extensive research, data analysis, and stakeholder engagement to evaluate the potential need to increase the minimum educational requirement for licensure to a baccalaureate degree. The board made significant progress in addressing the unlawful practice of respiratory care by LVNs while continuing to evaluate and pursue regulatory and legislative changes that appropriately balance consumer protection with the availability and continuity of patient care.

And the board implemented a digitized system for application, licensing, and enforcement filing, streamlining operations, and reducing paper based processes. We recognize the sunset review is not simply about continuation, but about accountability. We welcome the committee's feedback and recommendations and look forward to discussing how we are addressing identified concerns as well as the steps we're taking to continue improving our effectiveness as a regulatory agency. Thank you again for your time, for your continued partnership.

And now, I'm going to turn it over to Ray Hernandez, our vice president, for a few opening remarks.

Thank you, President Guzman. Good morning. Chair Berman and members of the committee, my name is Ray Hernandez, and I am the vice president of the Respiratory Care Board and serve as chair of the board's professional qualifications committee. This year marks my fortieth year of being a respiratory care practitioner and a native of California. I've been a licensed respiratory care practitioner for forty years as stated.

I've worked in the hospital setting caring for neonatal and pediatric patients and have been an educator and administrator for the community college system for the past twenty years. The professional qualifications committee is responsible for reviewing and developing related to education, continuing education, and professional ethics for licensure. In carrying out this work, we closely monitor advancements in health care and merchant technologies and evolving care delivery models to ensure our standards remain current and most importantly, continue to protect patients receiving respiratory care services.

In this role, I've had the opportunity to help lead several of the board's recent initiatives aligned with the strategic plan. Most notably, the assessment of whether a bachelor's degree should be incorporated into the Respiratory Care Act to ensure licensees are prepared to meet the increasing complexity of patient care and to further strengthen consumer protection.

As another recent example of the committee's work included a public meeting where we heard testimony and subsequently issued updated guidance on suctioning practices under our basic tasks regulation, an effort aimed at reducing ambiguity, reinforcing appropriate clinical boundaries, and ensuring care is delivered appropriately and safely in health care settings and throughout the community. I look forward to answering any questions of the committee's work, including our assessment of the entry level educational requirements and other consumer protection focused initiatives.

I'm now gonna hand it over to Christine Molina who's our executive officer.

Good morning, Chair Berman and members of the committee. My name is Christine Molina, and I serve as the executive officer of the Respiratory Care Board. Thank you to you and your staff for the time devoted to reviewing our sunset report and for engaging with the board throughout this process. We truly value this opportunity for dialogue and appreciate the insight and guidance you provide. The new issues identified in the board's 2026 report reflect its ongoing commitment to strengthening its consumer protection mandate.

Each of the proposals is designed to enhance oversight, strengthen safeguards for patients, and ensure that respiratory care services delivered in California meet the highest standards of safety and quality. Since its last sunset review, the board has made significant progress to address the issue concerning the performance of respiratory care by licensed vocational nurses, working collaboratively to establish clear statutory and regulatory parameters that protect patients while supporting appropriate access to care. While much has been accomplished, the board recognizes that this work is ongoing.

We remain committed to continuing these efforts, addressing remaining challenges, and seeing this issue through to a thoughtful and effective resolution that prioritizes patient safety. Together, these efforts reinforce the board's mandate to protect the public by ensuring that respiratory care provided to Californians is safe, competent, and accountable.

Later this year, the board will be undertaking its strategic planning process, and we look forward to thoughtfully incorporating the committee's feedback and recommendations as part of that effort. With that, we are open to any questions you may have in response to our report or the background paper.

Thank you very much for the presentation. I'm gonna kick it over to my colleague assembly member Addis. And then colleagues, please just get my attention if anyone else has any other questions.

Thank you so much, chair, and thank you for the presentation and, and for the work that you do. I, represent the Central Coast of San Luis Obispo, Monterey, Santa Cruz area, but, also talk quite a bit with some of our North Coast and rural areas.

And I noticed that, you are looking at changing some of the requirements from associates to bachelor's and just wondering how how you project that will affect areas of need, mostly rural areas in California that already don't have enough access to respiratory care. And and if you make that transition, how you would protect and enhance that access?

Thank you for that question. We've been exploring having meetings with our board open to the public and we started that back in June 2021. So this hasn't been something that all of a sudden this is where we need to go. And it really started with the our national professional organization, the American Association for Respiratory Care. And back in 2015, they started all the work with first looking at, where the profession had been, where it is currently, and where it is going.

So that was really our starting point and both our national professional organization and our state professional organization have created vision statements of moving towards a bachelor's degree. So I start with that just to say that's that's our starting point. And in June 2021, we started with some board study sessions and really looking at it and providing the board an opportunity to see where the profession has been and where we think it's going.

And with that, doing some case studies with other healthcare professions such as nursing and physical therapy, in particular to look at those models. And we know for nursing, that's always been a big conversation, and that there have been, many different opinions about where that profession is going.

So just to say we are looking at the whole landscape. So first and foremost, we understand, the need to get people into workforce as soon as possible and be able to serve the public. We know that. As we've been moving forward and with my background at the community college level, one of the things that the state legislature has done, which has been awesome, is that they've approved baccalaureate degrees, which were originally intended for nursing. And that hasn't come to fruition.

Our hope is that it will because they deserve that pathway as well. But that that has launched and we as respiratory care board have been proactive in supporting community college programs to develop a baccalaureate degree and at this current level, it's a plus two program. And and I say that lightly because really, plus two is is a misnomer at the associate level.

Students, by the time they complete all of their coursework, they've already accumulated for an associate of science degree approximately a 100 units on average for an associate of science. There are a few programs across the state there of applied science which have less general ed and less preparation.

But when we look at that associate degree, it's really not too far from a bachelor's already. And and one of the things that we saw is we saw that it might take maybe six to twelve months more for somebody to complete all of that coursework and have the added skill training and have the added general education that's needed for excellent communication skills and assessment skills.

So so again, looking at all of that, we did that as a a board and engaged in dialogue, did focus groups, surveys, to the public, gained feedback. And so all of that is moving towards that piece. Now I know your question was, what's gonna happen with the workforce if it's instituted?

And right now, this is a really great opportunity, in looking at, the workforce in particular for respiratory care. We see that we're meeting the needs. Is that correct, Christine?

Okay. And so should this enact and move forward, it's really a good opportunity. Okay? And so in looking at that, one of the things that our professional qualifications committee also did was we created a plan and a timeline to help with all of that so it's as streamless as possible. One other note I wanna just bring right now with the bachelor's degree is the unintended consequence to that for our profession.

That is correct.

And and I would say most of the workforce professions that have completed a baccalaureate degree or instituting that, is it is added, at least for our pathway, it's added 20 plus more units to complete a bachelor's degree because once you finish your associate, many of the units that our profession has acquired do not count towards the bachelor's. And for external accreditation, higher education, they require a minimum of 40 units of upper division work.

And our associate degrees already, if you look at a second year for respiratory care, most of that coursework, while it's not classified as upper division, it could easily translate to upper division. And by streamlining that process, while it may add just a little more work, in time in terms of time, it really strengthens the process and reduces the total accumulation of units. And I know that's a discussion the legislature has been looking at in terms of 60 units for an associate degree, no more. 120 units, for a bachelor's degree, no more. So this would actually help with that.

And I I guess, I'm in favor of more education, particularly in health care. I think it's I think it's vital. We all want the most qualified health care professional. To get to the heart of my question, what I'm wondering about is, you know, what the state of play is for our rural areas that traditionally have less less medical professionals across the board. I have visited clinics and other facilities in my district that have talked about shortages and actually specifically mentioned respiratory care shortages.

And we have satellite clinics coming in from other areas, you know, more urbanized areas that are then opening up satellite clinics in our in the Central Coast to help serve the need, which is, you know, largely a positive thing. And you may not have the figures with you now, but I'm wondering about the state of play.

Geographically across our state, we may not have a shortage, but I'm wondering if if if that's a statewide figure as opposed to a rural versus more urbanized, accounting and how that looks county by county across our state. Because certainly what I've heard in my area is that we do have a shortage, that we have a need that, that we're gonna have that we have to fill.

And I'm wondering how, you know, moving to more education, which is, of course, what we all want, is gonna affect the existing shortage and then how we move through that to make sure that our rural areas are still served, and that we can start to increase service in our rural areas.

And I appreciate that clarification. So I I think I have two comments to that. The first one is we know in underserved areas for all healthcare providers, it's difficult. So and and so not to negate, well, what does that do for respiratory care? I would say, you know, I think in terms of the data, we can get that for you and I would say the the quotes we made were statewide.

And so it doesn't disaggregate for the underserved communities. I grew up in Fresno and while it is a, a metropolitan area, it is underserved in general. And I I go back there and I see that as well. So so I would say two responses to that. One is, again, the legislature has done an excellent job with providing access to education at the community college level.

So I think the respiratory care board can continue to work to do two things. One is to provide that access and ensure that the current educational opportunities remain for both public and private. And then the second is to advocate for more programs in underserved areas. And I

think that that would be something we could do actively. The second piece I think is important to share with you is at a national level, our profession has been looking at increasing the level of education to a bachelor's degree because currently, we do not get reimbursed directly for our services. And part of the struggle is that we're classified as a technician because our level of education maintains us at that level.

If we can get to a bachelor's degree, then there is the opportunity to go to CMS and advocate to a greater degree to get reimbursed directly. And that, I think, then proves to, for respiratory care practitioners then to start serving underserved areas directly.

Thank you. And 11 last question. It's really the same line on your, current caps or excuse me, on your initial licensing fees versus moving those to your renewal fees. It looks like you're looking at, letting go of initial fees and moving that to annual fees and just how that might affect rural areas if that's expected to help folks get into the profession or

That actually is a little more of a cleanup language. We removed the initial licensing fee in 2012. We, at that time, did an analysis, and the systems weren't as automated. And we found that by removing the initial licensing fee and increasing the application fee, it was almost a wash, from a fiscal perspective. But at that time, it knocked off about 21 days of processing so that we could get those applicants that had met the requirements out into the field even sooner.

So the request that we have in place includes permanent elimination of that fee that we have not charged for about fourteen years now.

Thank you. Thank you, chair.

Thank you, Assemblymember Addis. Any additional questions or comments from colleagues? Seeing none, a lot of the questions that I had have I'm I'm gonna try to model for everyone. A lot of the questions that I had have already been answered. I wanna align my my kinda concerns or questions around the bachelor's degree issue with Assemblymember Addis.

You know, obviously, we wanna make sure that our health care professionals are are, you know, properly qualified. I I have concern kind of philosophically, I think as a society, we've we've increased requirements too much and and, you know, require bachelor's degrees for things that probably don't need bachelor's degrees. I don't know that that applies in this specific instance. That's more broader kind of philosophical, societal trend that I don't think has necessarily benefited anyone.

But just keep that in mind as you're doing this analysis and and, you know, making sure that we're not exacerbating health care access challenges in rural areas, not make sure that we're not unnecessarily creating additional barriers to people entering the profession because we we, you know, we wanna be diligent, we wanna be responsible, but we don't wanna be unnecessarily burdensome.

One quick question I have has to do with issue number one around fees. And I noticed in your report that current law requires you to maintain a fund at no more than six months in reserves, while most other DCA entities have a runway of two years. Has this, kind of anomalous six month, cap made it hard to budget?

I don't know that it has made it hard to budget. I think at this point, it's more of a concern as to whether or not that's an a sufficient, a number of months as far as if we were to experience, for some reason, an uptick in enforcement cases or whatever the case may be, we have fortunately main stayed right around six months.

Again, I think it just comes more down to the fact of the current state of finances across the board and wanting to ensure that we remain fiscally solvent so that we can continue to uphold our mandate.

Thank you for that. And then I I know you you spoke to the the, continuing or the the analysis, and and, I guess, the work that's gone into the LVN issues, you know, just look forward to continued updates on that as that progresses.

Yes.

With that, I can open it up to members of the public. If members of the public will come forward, to the microphone that we have at the front. And just a reminder that you have two minutes per organization. And in the interest of time, if there if someone else has already kind of said what you were planning to say, please just say, I align myself with those comments. Please go ahead. Give us one Sec. There you go. Perfect.

Okay. Hi. My name is Bridget Lemaire. I'm a registered respiratory therapist. I work at Emmanuel Medical Center. I've been a respiratory therapist for 23 years. I've done traveler registry throughout California at other hospitals. I do have my bachelor's degree, but I'm here today to testify against the push to require bachelor's degree for all new graduates. My colleagues and I are frontline health care workers. We want California families to have good affordable health care.

We are concerned about short staffing, reduced services, and longer wait times for patients to receive care. Requiring a bachelor's degree for all new respiratory therapists will increase barriers to our profession and barriers to our care for our patients. This is especially true in many low income and rural areas where shortages are most severe already. Do you know how it is to be short of breath waiting for a treatment and the respiratory therapist is busy with another patient with the patient coding? I do.

I have asthma, and I will miss my breaks. I will miss my meals to make sure my patients receive the care because of how short staffed we are, because we already don't have enough respiratory therapists graduating. This is gonna make it harder to bring people into these careers. It's gonna hurt health care workers and our patients.

Most of what I've learned has been on the job and from those coworkers that have not had a degree that are actually certified respiratory therapists that have been gravitated in when they made it registered respiratory therapist.

Also, the debt that people will have to take on for the bachelor's degree is and can be significant, especially because respiratory therapists are subject to the reduced borrowing limits for federal student loans that go in effect this July. A bachelor's degree can be a great option for some, but should not be required for all new graduates because it does not serve California's health care workforce needs. Thank you.

Thank you very much.

Good morning, chair and members. Jennifer Tannehill with Aaron Reed and Associates on behalf of the California Society for Respiratory Care, representing respiratory therapists throughout California. We gladly support, the extension of the sunset, for the respiratory care board. They do great work and, have been, an upstanding board for many years. CSRC supports the RCB's efforts to clarify a pathway for licensed vocational nurses to provide basic and manual respiratory tests for less acute patients in certain settings.

We look forward to working with the committee and stakeholders finalizing outside any outstanding items on that topic. CSRC supports the issues outlined in the respiratory care board's report, particularly item five, which proposes the development of a heart and lung specific graduate level practitioner called the Advanced Practice Respiratory Therapist or APRT. The APRT continues to gain momentum nationally. COARC, the commission on accredited accreditation for respiratory care, has already approved curriculum.

Ohio State, a formal APR, has a formal APRT program, and UNC Charlotte is scheduled to launch their APRT program later this year.

The APRT would add a much needed advanced practice provider already specialized in heart and lungs to, care for patients with cardiopulmonary disease. Respiratory therapists are already trained and managed to trained to manage complex cardiopulmonary conditions such as COPD, asthma, and respiratory failure. This expertise uniquely positions the RTs to help close critical gaps in care and serve more patients. The APRT has support from cardiopulmonary physicians who RTs work with every day.

So thank you for considering, our our thoughts on the sunset, and I'm open to any questions or to help throughout the process. Thanks.

Thank you very much.

Good morning, chair and members. George Soares of the California Medical Association. Just one issue. I wanted to flag issue number five. CMA is monitoring the development of a new, advanced practice respiratory therapist classification.

CMA also notes the proposal's workforce impact is limited. As previously mentioned, well, only one training program exists in Ohio and just two APRTs are known to be recognized nationwide. Thank you. Thank you.

Hello. Thank you for this opportunity, and good morning. My name is Mariam Voskanyan. I'm a registered nurse, and I have owned and operated a congregate living health facility or CLIF, as they're sometimes referred to, in the Los Angeles area since 2012. CLIFs are home and community based settings for individuals with chronic disabilities who want to live their lives in the communities and lead lives that are as normal and independent as possible.

Many of our residents attend school, participate in community events, and even maintain employment. I want to thank the respiratory care board today for working with Cliffs and our association to exempt most Cliffs from the basic respiratory care tasks and services. We appreciate the board recognizing the current regulation does not fit the current cliff model. Today, we respectfully want to ask that all cliffs be exempted from this regulation so that we can continue providing safe appropriate care while allowing our residents to remain integrated in their communities. Thank you for your time and consideration.

Thank you.

Good morning. My name is Irene Docker, and I also own and operate a congregate living health facility. And we've been doing a lot of work explaining how important community based settings are for our people. I am a licensed respiratory therapist for over 25 years myself. And because of that, majority of my patients are respiratory patients who are ventilator, invasive or noninvasive ventilator dependent.

And we take big pride to say that they are able to attend the community events, go to school, socialize with family because our nurses are able to provide nurses are able to provide respiratory care task. We appreciate your understanding of our settings. We appreciate the situation that you were able to carve out six beds congregate living health facilities.

And we really hope that we continue to work with you in the future in clearing all the details and maybe possibly including other congregate living health facility with more beds into this carving out process. Thank you very much.

Thank you.

Hi. My name is Court Green. I own and operate five congregate living health facilities. I just wanna reiterate the importance of allowing licensed vocational nurses to continue to provide respiratory care in in our environment no matter the the bed size. Prohibiting licensed vocational nurses from providing respiratory care will dangerously limit, the access to care that, our committee person was referring to, especially in rural areas, where licensed vocational nurses have safely provided respiratory care for years.

So I I ask that congregate living health facilities, no matter the size, be exempt from that portion of the regulation and that licensed vocational nurses continue to be able to provide respiratory care in that those environments. Thank you.

Thank you.

Good morning, everyone. I'm Ron Ordona. I'm a nurse practitioner, and I would like to thank the board for giving exemptions to CLIFS, congregate living health facilities. And I also lead a group of nurses who run a congregate living health facility here in Sacramento. I work in a a local trauma medical center, and we took care of patients with trachs and vents, and they lived in the hospital for years because there's too few congregate living health facilities in this area.

So thank you for allowing us to or Evian to take care of those patients in these settings. And just like my colleague has said, please allow other all clips to be exempted from from that regulation. Thank you.

Thank you.

Good morning. My name is Julia Ryan. I also own and operate congregate living healthcare facilities in the Fresno area, which as you mentioned, is severely underserved. And I would also like to ask that you guys are able to give us that leniency with the licensed vocational nurses being able to practice even in the larger facilities. Thank you very much for your time.

Thank you.

Good morning, respiratory care board. Thank you for your commitment to the safety and protection of medically fragile Californians. The right to breathe and the ability to breathe is something all of us take for granted, but we all need to have access to. And what has happened for the last for decades is LVMs has helped that continue for medically fragile children like Eliza here for decades. And it's not just vent and trach, which she does have, but it's also suctioning.

It's also putting on immediate oxygen after a seizure just to stabilize. What we're asking here, and we're so grateful for the respiratory care board is creating a pathway of skilled nursing oversight for in and training from an employer based setting, and we look forward to building that with you so that kids like Eliza from zero to a 100 can remain in their communities and thriving. And thank you for protecting that right.

Thank you.

Good morning, chair and the board. It's an honor to speak with you, and thank you so much for everything you're doing to resolve this matter. Eliza is a 10 year old. She's my daughter. She's fourth grader at Mickey Cox Elementary.

She's had a trach since two months old. She was born with a spontaneous genetic disorder called Pfeiffer Syndrome. So how long is it totally fine? But her nasal passages are fused, so trach was necessary. We have met so many Nurses5060 within, you know, in ten years of Eliza's life.

And we have learned from the LVNs how to take care of Eliza, and they've been excellent. They're trained. They know how to do a breathing treatment. They know how to suction the trach. They know how to turn on the vent.

It's not like they're changing the settings on the vent, and there are plenty of checks and balances from the Violet Children's Home Care. The respiratory therapist does come out to the house and checks the vent every month. So it's not like LVNs cannot push the button to turn on the vent at night to give her that air. And Eliza does go to school and she has one on one nurse, LVN nurse.

And if if LVN cannot suction the trach and she cannot go to school, like, what would that be?

Would that mean that she has to live in the hospital? Because we cannot we need help at home. We need nursing help at home to have that respite and but Eliza is a joyful little girl. She loves life. She live she loves her friends at school.

And when in October and when everything came down and we couldn't have a nurse at home and we couldn't take Eliza to Loretta's little miracles, that was hard. That was very hard. So we thank you so much for everything you're doing and hearing us out as parents, and and we're representing other families too. So thank you. We appreciate your attention to this.

Thank you.

Thank you. And thank you, Eliza, for being here.

Greetings to the committee and to the respiratory care board.

My name is Jen McClelland. I'm here because I'm a parent of a 14 year old, a freshman in high school. He has a tracheostomy, and he uses a ventilator because he has a rare genetic syndrome. I'd like to take a big step back. A lot of these things are getting really bogged down in lists of tasks and who can suction and who can change a trach.

I'd like to have the committee take a step back and look at kids like my son. He couldn't be here today because he has a trigonometry test. He attends school with a nurse so that he can focus on learning and somebody else can focus on breathing. Kids like my son have a right to attend school in the least restrictive setting. That means he doesn't have to be at a segregated site.

He doesn't have to be in a special ed classroom. He can attend our local neighborhood high school. He's in the marching band. One of his marching band assistant, I guess, coaches has been trained to manage his trach so that he can march and not create a whole side project of getting care and interrupting the performance.

What I want the committee to understand is that when we get bogged down in this list of very specific tasks and very specific people who can perform these tasks, the tasks don't matter as much as disabled children and disabled adults' right to access community living, care in the community, and community life.

I've worked with the respiratory care board and I understand that they're looking at patient safety, but we have a competing concern which is that the system as it exists today was built and funded on LVNs doing all of these tasks. So I'd like there to be a coming together of folks from education, folks from long term care, folks from the hospital industry to figure out how we're going to fund and manage a system that gives kids like my son access to care at home. Thank you.

Thank you. With that, I don't see any other members of the public. They just wanna thank everyone for coming in and sharing their their personal experiences and and concerns, and we are going to move on to the next board. Thank you, everybody. Appreciate it.

Which was not a board, it's a council. But next, we'll be hearing from the California Council for Interior Design. Testifying today is George Brazil, chair of the council's board of directors, and Rose Wiebe, executive director, and we're ready when you are. Thank you very much.

Which was not a board, it's a council. But next, we'll be hearing from the California Council for Interior Design. Testifying today is George Brazil, chair of the council's board of directors, and Rose Wiebe, executive director, and we're ready when you are. Thank you very much.

Just hit the little button right in front of you.

Is is that better?

Much. Alright.

Awesome. Thank you for the opportunity to speak with you today. My name is George Brazil. I serve as chair of the CCIDC board, and I'm also a practicing certified interior designer in California. I wanna speak to you not just from a policy perspective, but from real world practice.

Everyday, interior designers, like myself, are working within the built environment on projects that directly affect life safety, accessibility, and codecom compliance. We coordinate with architects, engineers, contractors, and building officials to ensure that spaces are safe, functional, and compliant with California's complex regulatory requirements. The current certification framework supports that work. It establishes a clear standard for competency. It ensures that certified interior designers understand California codes, and it allows us to contribute meaningfully to the design and construction process.

From my perspective, the system is working. I want to address the question of licensure from the standpoint of someone actively practicing in this profession. Licensure may sound like a simple step forward, but in practice, it would create significant and immediately immediate dis disruption. There are thousands of interior designers currently practicing in California. Based on what we know, only a small percentage would initially qualify under a licensure model.

That means experienced professionals, many of whom have practiced safely for decades, would suddenly face barriers to continue their work. That has real consequences, not just for interior designers, but for the entire project delivery system. Interior designers are off often the professionals who develop detailed interior layouts, coordinate finishes and materials, address accessibility requirements, and work closely with clients and contractors to move projects forward. If you restrict that workforce without clear cause, the impact doesn't stop with us.

It affects project timelines, costs, collaboration across disciplines, and, ultimately, the efficiency of the built environment.

Licensure would not exist in a vacuum. It would change how interior designers interact with architects, engineers, and contractors and could unintentionally create overlapping or unclear scope of responsibility, bottlenecks and project approvals, increased reliance on other licensed professionals for work currently performed safely by interior designers. In practice, that means more costs, more delay, and more complexity without a clear improvement in public safety. From both my experiences from both my experience and CCIDC's record, there is no evidence of systemic harm that would justify that level of disruption.

And what we do have is a system that identifies qualified professionals, requires demonstrated competency in California codes, and allows flexibility in a diverse and evolving profession.

And that balance matters. From where I sit, both as board chair and as a practicing designer, this is not a system that needs to be replaced. It is a system that should be continued and refined where appropriate, but not fundamentally changed without clear clear evidence of need. Because when we talk about regulation, we're not talking about policy. We're talking about people, professions, and the way projects actually get built in California.

Thank you for your time, and I'm happy to answer any questions.

Chair and members of the committee, my name is Roze Wiebe. I'm the executive officer of the California Council for Interior Design Certification. Thank you for the opportunity to appear before you today and for the careful, review of our sunset review report. For more than thirty five years, California has made a deliberate policy choice to regulate interior design through a title act.

CCIDC fulfills that role by establishing and enforcing standards for education, experience, and examination that ensure certified interior designers are competent to perform work impacting public health, safety, and welfare.

CCIDC operates as a self funded, efficient, and transparent organization with open meetings, public participation, and ongoing legislative oversight through the sunset review process. The program is appropriately scaled to the statutory purpose and continues to function as intended. CCIDC certification framework is working. It protects the public. It establishes competency standards and should be continued.

The legislature has consistently applied the same standard in evaluating if there has been demonstrated harm to the public that justifies additional regulation. The record shows that there is no pattern of consumer harm associated with interior design practice under the current framework. Complaints are minimal, and none have involved any threats to public health, safety, or welfare. At the same time, certified interior designers are required to demonstrate competency through the education experience and a passage of the IDEXX exam.

The only California examination that's comprehensive, California specific, and tests not only on building codes and regulations, but design standards, professional practice, business practices and ethics, accessibility, and life safety requirements.

The examination is developed and continuously updated by a comprehensive team of subject matter experts, including in collaboration with the International Code Council, which is the council that develops the actual codes. And it is independently validated and administered by, psychometricians and using standards that are consistent with state regulatory expectations. With respect to stamp acceptance, the evidence shows that it's not a systemic issue, but one of inconsistent interpretation that can be addressed through statutory clarification and outreach rather than regulatory change.

Finally, on the question of licensure, CCIDC's position is clear. Licensure is a significant regulatory expansion and it should only be considered the sun Sunrise review process.

That standard has not been met. Licensure would create barriers to entry for a large portion of the existing workforce, increasing cost and restricting access to the profession without a demonstrated public protection benefit. CCIDC also notes that recent licensure proposals were developed without any consultation with, the entity responsible for administering the current framework. Engagement with CCIDC is important to ensure that proposals reflect how the system operates in practice and the impacts on both practitioners and the public.

In closing, CCIDC is a program that is working well working as intended.

It is effective, proportionate, transparent, and aligned with legislative intent. There is no demonstrated need to replace it. CCIDC respectfully recommends continuation of the program and ongoing review through the sunset review process. I thank you, and I'm happy to answer any questions.

Thank you very much. Wanna kick it over to colleagues for any questions or comments. It's the member Ahrens.

Thanks so much, mister chair. Appreciate the testimony here today. I wanna play devil's advocate for a moment. According to this background white paper we have here, I just wanna quote, while the phrase interior design is commonly associated with decorative services focused exclusively on visual elements such as furniture range arrangements or wall colors, CIDs utilize considerable technical knowledge to ensure that indoor spaces are safe and functional in addition to aesthetically pleasing. You noted that the current system's working, minimal complaints.

What would you say to the the this idea that, you know, according to this white paper that they are obviously, you know, functionally serving to provide safety, not just what I think the average Californian thinks of an interior designer not having CCIDC to have enforcement authority, for example, for when things do go wrong, not having consistent training, not having competency standards.

What would what would you say to, you know, the question that, you know, an overhaul of the system is needed and we need more compliance because of the safety aspect and not just a voluntary compliance? As as is other elements of, you know, what we do and and how we regulate, you know, these business businesses or or different professions.

Why can you can you dig a little bit deeper for me and sort of explain why you know, just because, for example, we we get a lot of these sort of we know a lot of these complaints, for example, are sometimes unreported in a sort of voluntary system. So there's no real way to track certain issues if it's if if it's voluntary.

I'm just wondering if you can speak to some of those.

Certainly. We actually get a lot of complaints that and we track all of this and we record it. If if if they're not for certified interior designers, it's we get people that will fill out the complaint and forms in addition to people that we could regulate. And there's not been it's the issues that come across our desk are not issues of, like, public harm or public safety. The issues are usually disagreements about a contractor, disagreements about how things are proceeding.

So there has been no demonstrated public safety or harm in the 35 years that CCIDC has been tracking this. So there are standards and there are, situations already in place through, other, avenues that if there were issues that they could be handled, but there just haven't been. It's not that they're not getting reported. It's there just happens haven't been.

But how, if it's a voluntary system? Because Or not, how are we track you know, we're only tracking it based on the complaints that you get.

It's not just that. I mean, you look at the the you look at the public safety. If there were issues of public safety that would be handled in a in a legal manner, and and there just have not been there's not happened in Right. ...five years.

And and when you have these complaints since they're you know, CCIDC notes that they don't have enforcement authority when or ability to issue fines or or etcetera. When when you do have these complaints come up, what what is the remedy If there is no enforcement authority?

So if the enforcement authority that we have, if there's a complaint that comes in, we have a strict code of ethics that all of our certified interior designers must adhere to. And the board will sit down with all of the evidence that's been provided on both sides, and they'll review it based off of what the code of ethics says.

And if there's a violation against the code of ethics, then our process is to there's, you know, it could be from requiring additional education to loss of certification or it could there's been a probationary period. So depending on what it is and what violation there is, we do have some it's just not sight and fine. So

But it's a voluntary certification?

Yes. It is voluntary.

Okay. And and and and your position is that the that the current system is working far better than any of the recommendations?

So currently, in California, there's over 8,500 interior designers practicing, and that's from statistics that we've pulled from the labor board. Out of that, approximately 1,700 are certified under the voluntary system. There's still, you know, an additional group of people that have been practicing for decades.

The vast majority of them. Right?

Correct.

Correct. They have been practicing for decades without proven public harm. There have not been lawsuits. There have not been, issues, you know, that we've seen, like, fires in warehouses that have heard do not occur because of interior designers. That's not who created those.

So if there were public harm, it would be reported and there's not been any public harm reported.

Okay. I I just find it interesting that you you mentioned 8,500 Are not certified and only 1,700 are

No. There's 8,500 total of that 1,700 are certified.

Okay.

And under the current licensing proposal that's out there, approximately 600 would qualify under that. So it'd be even less than what's certified.

So around 6,000 or give or take are not certified in the state of California, have not gone through this voluntary certification.

Right.

Are there efforts to

Absolutely.

Help them to try and do that? Have we made progress?

It's it's really, you know, there's some I'm sure people here that can explain their situation, but there's other avenues that they they're taking that work for them. And without, you know, proven consumer harm, we don't understand why it would need to be more regulated.

And and, you know, since this since CCIDC began, we have certified over 5,000 in in interior designers. There are currently 1,700 practicing, but over the course of what we've done, there have been 5,000.

But currently, the vast majority of the industry in California is not certified.

That is correct. And, you know, as as you had sort of stated earlier, you know, there's there's sort of a wide array of what interior design does. So there could be people that are paint consultants. Well, they may not become certified because they don't see the need for that. But they may say they're an interior designer, but they're a color consultant.

In in my experience, relying on individuals to determine if they should be certified or not usually isn't conducive with, you know, making sure that we have set standards for safety reasons. So that's just sort of my only concern. But, mister chair, I'll I'll just wrap up by saying would would love to learn more And perhaps set up a meeting outside the committee.

Definitely.

if I could just quickly add, you know, we do have requirements for certification. There are educational requirements. There's our work experience requirements, and there is examination requirements. Not enforceable. Right?

In enforceable to become certified. Yes.

Yes. And that's it's another thing is that

But it's not enforced.

Not required to be certified.

Correct.

So

No. But of that 8,500 people, there's you have to meet that minimum of qualification to even apply for certification. And so a group of those people have not met that minimum qualification threshold. So that's part of the numbers as well.

Okay. Thank you.

Thank you, Assemblymember Ahrens. Assemblymember Macedo.

Thank you, mister chair. Given that only a portion of your certified interior designers hold the commercial designation, can you provide empirical evidence on what percentage that represents and demonstrate whether this designation has resulted in consistent acceptance of plans by local jurisdictions without additional license sign off, and if not, what problem the designation has actually solved?

Certainly. This commercial designation was actually created with the, interior design commit profession as a whole. We worked with groups like IITA, ASID, NKBA. We all came together and we created that together. That was something they, you know, everybody sat down at the table and created.

And it wasn't meant to solve all the problems. It was meant to educate, building officials as to the level of training and competency that the people that hold that designation have. So shortly after starting the commercial designation, we went through the pandemic and a lot of commercial, projects and a lot of commercial buildings closed down and stopped. So we saw a significant drop off with that during that time frame, and it's slowly coming back.

But we still have many people that are not, you know, going back to work in the office.

So there was there was impacts to that. And I think we've done a good job of going out and using that to educate the building departments. The building departments and the building officials, they're the the people that were are responsible for accepting the plans. Doesn't matter if you're licensed or not. You can ask architects.

They'll tell you that that's not gonna stop what that does. There's not going to ever be blanket acceptance. We track the acceptance issues. We have a plan check denial process. And in the last four years, there have been 16 plan check denials sent in to us, and of that 14 were resolved favorably for the plans to be submitted to are in the still in the process.

They hadn't been closed yet. So I think it's doing what it's supposed to. It's doing what it's intended to do, but it will never licensure certification will never get blanket acceptance. That's not that's not gonna happen.

Well, you said something that they all came together, but it wasn't meant to solve the problem.

It wasn't it the intention was to give education to building up departments of the level of training. It wasn't meant to try and solve this blanket acceptance because that's we understand that that's not going to happen.

So just so I'm understanding. Even with this education, if you have an interior designer do this project, you're still going to have to seek other approvals from an architect before there's sign off on the plan.

That's not necessarily true. No.

Okay. So then what's what you said there was 16 project denials. What are things denied for, potentially?

There were basically, like, they would submit plans and immediately without review, it would come back saying they need an architect stamp. So we would sit down after getting this plan check denial, and we'd sit down with the building official and say, here's the scope of what we're allowed to do. We'd discuss it, and then they'd realize that sometimes it was a training issue for the staff that was not, accepting the plan at the moment. There was there's been several different reasons.

It's never been a, you just can't do it or you have to have an architect.

It was training. It was, sub there was a couple times where the plans that were submitted, worked outside of the scope of what interior designers are allowed to do. And so, they had to adjust those plans for that reason, and then it was accepted. So

I would argue though that licensure in this particular case would clear up that ambiguity that you're talking about that there's not consistency and you do have these projects kicked back. But how many of your currently certified interior designers hold the commercial designation and what percentage of your total certificate holders does that represent?

Well, currently over 1,700 people and I believe there's 228 commercial designations of those.

Okay. I can't do quick math off

the top of my head. And I yeah. I

And that doesn't mean that if you're just a CID and not a commercial CID that you cannot submit commercial stamped drawings. That's just an identifier to the building departments that you have the experience, etcetera, in commercial work. It doesn't deny you. It doesn't bar you from from doing that. But if I can just add, even with licensure, there is no guarantee your plans are going to be accepted.

Every building department is its own jurisdiction, and they have the ability to deny drawings regardless if you're licensed, regardless if you're a CID, regardless if you're the general public. They have the ability to, you know, to do that. So it's not a guarantee. Licensure is not a guarantee that your drawings are going to get accepted Even if you're an architect, even if you're a structural engineer, you have to meet requirements.

So my mom's an engineer, and I went through the planning process. So I understand that. However, there are certain criteria that as a licensed engineer, they weren't gonna look into her background to see if she was qualified. She had a stamp that said, I'm an engineer. I have the training.

I've taken the proper test. I know how to do these calc packages. I know how to draft this. I understand that there are unknowns in this process.

Right.

However, I think clarity would streamline some of this that we're not wasting time trying to figure out if we know need to go look at these people's LinkedIn page to see if they have the qualifications.

Sure. So so that's where CCIDC comes in. As a certified interior designer, you have to prove you have the education, the experience, and the examination.

You have a stamp.

And you get a stamp that proves that. And then it's educating the building department officials that these people that have this stamp are qualified to to work within their work within the the confines that they get to work in as interior designers.

Yes. But that stamp is different than my mom's PE engineering stamp.

Right. But just like an architect stamp is gonna be different than And

it I I just ask you, do me a favor and let the Assemblymember finish their comments

I'm Sorry. My apologies.

And just like my colleague said, this is voluntary, and you're still having project denials that whether they are or are not related, I think we have a real opportunity here. And so, I guess, is there what would be your policy then if an interior designer came to you for you to formally reject them being certified at that point? Like, what what would you say you're not qualified, you can't get our our certification?

Meaning, if they were new to apply or they were already a CID and there was a complaint that's

like you had like, my colleagues said, you had about roughly 6,000 give or take that were not certified.

Correct.

What would disqualify those 6,000 from getting certified currently?

If they didn't meet the minimum education and experience requirements.

And what are those?

So it's a minimum it's a combination of six years of education, and it's minimum of 40 core units plus the additional if you have it it's on a scale kind of similar to the architects board. If you have 40 core units and you need to have an additional four years of experience, if it's six 60, it's three and three. So it it goes on that, it's on a scale of forty, four years, sixty, three years, 80. And that's in core units, not in the other things.

It has to be specific to interior design for those units.

So when I hear those things, I hear I don't hear certification. I hear license. You do have special training. You have special education. You have minimum units, minimum hours, similar to a medical license, a law license, an engineering license.

And so one I think we're, you know, we're gonna have a difference of opinion on this. I think licensure would clear up a lot of ambiguity. And whether it is or is not the reason why things are being denied, you're spending a bunch of time educating people on the certification rather than a standard licensure. That's time wasted, and you're not gonna have continuity throughout the state. So just food for thought.

Like my colleague, I hope to be involved in this going forward, and thank you, mister chair, for the opportunity to speak.

Thank you very much. Turn it over to Vice Chair Johnson.

Hello. Good morning. I'm gonna keep it brief. Some of my questions thank you. Some of my questions were already answered in my colleagues.

I have a quick statement and then a follow-up. So I I'm seeking to understand and the way I'm hearing you describe it is that CCIDC is a private nonprofit, which is performing somewhat of a state regulatory function. And I think what I'm worried and concerned about is the lack of transparency or the accountability for that a state agency would be required to have. So I'm not sure that I understand the model correctly. That that's purely my own thought, and I'm looking to understand that.

And then for some follow-up, I come from local government, so I'm very familiar with some of these challenges.

Of those with this designation, can you give me evidence that has led to consistent acceptance of these plans by local jurisdictions without requiring any additional sign off, of licensed professionals? Because I'm really looking for direct outcomes.

Certainly. I think that we're only able to report on what is reported to us, so of the 16 that we have. But on the other hand, we don't have a reporting of people not having it accepted. Does that make sense? So for us, we can only report on what we've been told.

We have not gotten any numbers, any substantial numbers, any valid numbers of people that are not having plans accepted elsewhere. So we continuously work with the international co counsel with the, building officials to do the educating and see we don't we don't have there's no concrete numbers in a in opposition to what we have.

Would you say that that's because they're not reporting those to you? Because I can tell you from the local jurisdiction, there are challenges.

Again, we can't report on what we have and we don't have. So, yes, obviously, that we don't have that information.

Alright. Yeah. I I really would like to see that it is providing direct outcomes and it's it's expedite it there's a need for it and that the certification is helpful versus hurtful. Like, as far as if they're needing an additional someone to sign off, I don't I don't understand that being helpful.

Right. And in most cases from the CIDs that we've talked to, they don't have problem. We have people we have some plans here that I know we've showed some of the lege staff. People are submitting plans all day, every day across the state and having them without requiring an architect stamp.

Yeah. I have some further questions, but I'm I'm willing to hold so for additional conversation outside of this.

Thank you.

Okay.

Thank you very much. I need to oh, excuse me. Assemblymember Pellerin thank you.

Hi. Thank you. Thank you. Now, I'm just curious. I'm looking over the backgrounder, and I'm wondering what your thoughts are about capping the ED salary that it's recommended.

It's fine. I don't think that we're anywhere close to it. If we needed to cap it, we'd be fine where there's no problem.

So so what is the current compensation?

84,000 a year.

Okay. Alright. Thank you.

Any additional questions from colleagues? Seeing none. Just following up a little bit on the vice chair's original comments around kind of transparency and A bit of the difference between a council and a board. And and this is also a conversation that we've had vis a vis another council that we have. And statute requires that CCIDC comply with the Bagley Keene Open Meeting Act, but it appears from the sunset report that your meetings are not in compliance with that act.

For example, my understanding is a 100% of your Board Meetings take place over Zoom, which wouldn't would not comply with the most recent recent version of the law. Can you confirm whether CCIDC believes it must comply with Bagley Keene and what steps you, are taking or plan to take to ensure that your business is transparent and and accessible for the public.

Certainly. We we went to a 100% Zoom meetings when COVID happened, and then we found that our participation remained so significantly much higher than when we were holding it in different parts of the state. We're talking from having maybe, you know, five to 15 people attend a meeting when they were held across the state versus close to a 100 people when we held it on Zoom. So we felt like that was we were reaching more people.

We were able to reach more people if we held them that way, but we're happy to review what the Bagley King law says and and make adjustments as according as necessary.

Perfect. And I hear you. But at the same time, we have to make sure that we're we're . Compliant with the law. And complying with the law. So I appreciate, you know, that that pledge. I think a lot of the other questions were were kind of asked and answered from colleagues. I know we'll have lots more discussion about these issues, you know, moving forward, but I think that's probably pretty good for today. Okay.

So I appreciate y'all's presentation. We're gonna open up to members of the public. If folks have any comments, as a reminder, you have two minutes each. And just as a as soft reminder, if somebody before you says what you were planning to say, feel free to just align yourself with those comments. Please come on up.

Good morning. My name is Janice Plasus, and I am an allied professional practitioner with ASID. I'm the current chapter president for NKBA here in Sacramento. And I'm also sit on the board for CLCID, which is the California Legislative Coalition for Interior Designers. I am not a certified interior designer, but I'm here on behalf of to support the CCIDC because I think their function is is very important.

I think the system as a voluntary system has been working for decades, and many of us make a decision somewhere along the way that we wanna go into residential versus commercial design. But as you know, things change. And I do some amount of work that has has been and continues to be in the commercial realm, whether it's in hospitality, clubhouses, that kind of thing, as well as residential design.

Rather said residential design, we also submit plans, and we have to, put them before the same building officials. They have to meet the same requirements, and we work with contractors, architects, and the like.

And I think that, this is a very, nuanced thing. The thing that is disturbing to me is bifurcating interior design into two separate practices, residential versus commercial. And we all have to know different things at different periods of time. I've gone more into commercial because there was no residential work. Now things are more residentially focused primarily because of COVID, and so I'm doing more residential work.

So it's been allowed me to have a great deal of flexibility. Being associated with these other design associations, especially ASID, I still have to maintain a certain amount of professional standards. I have to have a certain amount of education, and I still have to continue that education. And I also foster that foster that as being a chapter president for our local NKBA chapter. So I appreciate you considering keeping things as they are.

There is no, in my estimation, public harm, public safety, and so issue. So I I would encourage you to consider keeping things like there.

Thank you. I'm sorry. I let you go a little bit longer, but thank thank you so much. Thank you. Appreciate it

My name is Linda Panattoni. I'm past president of CLCID, which is the California Legislative Coalition for Interior Design. I have supported CCIDC for the last 25 plus years, promote their professionalism in what they stand for. I think it's important that all designers have provide the certification and that they are able to know the codes for California.

And the IDEXX is one that promotes codes both for residential and commercial. And the flexibility of being able to choose which way you wanna go as an interior designer. I've done a little bit of both over my years, but I'm also certified through NKBA and NARI, which is the remodeling association. I do permit ready plans for residential at this time in my career. I support what CID has done over the years, and I hope you will support them also.

Thank you very much

Hi, folks. Thanks, chair. Thanks, vice chair. Thanks, committee for having us. I'm Adam. I'm with IAGA representing Northern And Southern California chapters today. Just wanna talk briefly about our concerns about CCIDC sort of general structure. As you

guys have been alluding to, understand it was politically expedient in the nineties, that it was this private sort of public partnership. We don't feel that it's panned out. It's kind of a vacuum of accountability as chair Berman alluded to. That really relies on goodwill and not on more robust safeguards.

So for instance, when things happen like CCIDC, including hundreds of delinquent members in their active numbers or password protecting, you know, an open meeting to the public so we can't get in, or, like, hiring a lobbyist, there's no, like, mechanism for members of the public to, like, file a complaint or hold them accountable.

In our from our perspective, a private entity that's reliant on the continuation of renewals and purchases to sort of maintain their business really just can't work in the best interest of the public because it's sort of a self fulfilling prophecy. So we, you know, thank you for allowing us to participate in this conversation. We urge you to really evaluate the continuation of CCIDC and work here to provide information for our sport. Thank you.

Thank you very much.

Good morning. Thank you to the committee and chairs for your time and attention today. My name is Bonnie Perry. I'm a commercial interior designer in chair Wahab's district, and I've been practicing for twenty years. To start, I wanna say first, I'm embarrassed to be here today. Years ago, I set in motion a plan to finally start a business of my own after years of working under others. The mission of my design business

was to meet other small businesses where they were by offering small but mighty spaces to fees they could afford. I wanted to do things right. And at that time, I thought that meant getting my CID because I understood it would allow me to stamp and sign my own permit drawings because I was led to believe that by the CCID seat. The time came to finally use that CID stamp on my first commercial interior project, a retail tea shop.

Despite my clients' trust me when I showed up to plan check, I was told we don't accept that stamp.

You'll need a licensed architect to even start the process of reviewing my drawings. Of course, I was shocked. I never imagined I'd be turned away at the door, literally kept out of the process that works for my architect and engineer colleagues. I scrambled, and luckily, I was I had an architect who I brought in for an additional fee, to sign my drawings. But when when you're working on a commercial project, even one day of delay can cost a project.

For a small business client like this one, that cost was enough to break the budget, so they had to put the project on indefinite hold. The idea of my CID stamp may be working as just not a sustainable way to run a business, especially for my clients where every dollar is counted. I started my design business to help other small businesses, and sadly, the unreliability of the CID stamp meant I had to close my doors and return to a larger firm.

I encouraged this committee to critically evaluate where the council should continue to operate. This private structure of certification failed me and my independent business, and I urged the committee to evaluate if it's really in the public's best interest for it to continue on because it certainly wasn't serving my best interior interest as a practitioner. Thank you again to the committee and the chairs for your time and attention today.

Thank you.

Hi. I'm Catherine Hampton. I am an interior designer a certified interior designer with a commercial designation. I am also serving as the president of the California Legislative Coalition for Interior Designers. And I want to let you know, I practice in Los Angeles.

I have my own small firm. And with my commercial designation stamp, I'm able to pull permits across the state in Downtown Los Angeles for tenant improvement projects and high rises. I'm holding here a set of plans by a fellow certified interior designer on the 16th Floor of a a project on K Street if you box from here. So the system does work.

If there are any questions that you all have about our ability to to practice independently of other design professionals, I would love to continue that conversation with you. Thank you.

Thank you.

Hello. Thank you to the committee and the chairs for your time today on today's issue of CCIDC. I'm Mary Oliver, and I'm interior designer at DEFCON Construction in Silicon Valley. I'm an NCIDQ holder and 2025 emerging leader for IIDA Northern California. I grew up in Louisiana with both my parents in the design industry.

There having a license as an interior designer is normal. I dreamed of a day of one day having my own practice here in California. I realized that CCIDC misrepresents their certification as a license. Saying things like hundreds of thousands of permits are pulled by CADs every year, or that the CID protects your right to practice. These statements confuse practitioners like me from other states who have no history on the failed structure of a private board in California.

I need my state to support me as an emerging professional. Instead, all I've found is confusion. I strongly encourage the committee to determine if CCIDC is serving in the best interest of the public and young practitioners like me. Thank you again for your time.

Thank you very much. Seeing no additional public comments, that's gonna wrap up this portion of the hearing. Thank you very much for the presentation, and thanks everyone from the public for the the comments that you made. And next, we're gonna turn it over to the speech language pathology and audiology and hearing aid dispensers board. We will be hearing testimony from Gilda Dominguez, board chair, and Amy White, board vice chair, and Chris Burns, executive officer, and we're ready when you are.

Have you hit the button?

Okay. Good morning. Can you hear me okay now? Okay. Thank you.

Good morning, Chairman Berman and joint committee members. My name is Gilda Dominguez, and I'm a California licensed and nationally certified speech language pathologist and chair of the speech language pathology and audiology and hearing dispensers board. Here with me today is board vice chair Amy White, doctor of audiology and California licensed audiologist, and Charisse Burns, executive officer of our board. We want to thank the joint committee for the opportunity to speak with you today about the significant improvements the board has made over the last four years. Our three professions.

As you have read, the board serves to protect consumers and the public by licensing and regulating the professions of speech language pathology, audiology, and hearing aid dispensing. Three separate and distinct professions with their own scope of practice. The board's licensees provide speech and hearing services to California consumers of all ages, from newborn hearing screenings and public school children receiving speech therapy and cognitive services, to adults receiving post stroke rehabilitation care, and senior citizens suffering from hearing loss receiving hearing screenings and hearing aid fitting services.

The board sets entry level licensing standards, including education, examination, and professional experience requirements as appropriate and ensures that licensees meet minimum qualifications to to deliver appropriate speech and hearing health services. This is critical due to the potential harm to consumers of all ages.

There is a growing need for these professions. The board's licensing population continues to grow and is now over 44,500 individuals and entities. Nationally, the need for speech and hearing professionals is expected to grow anywhere between nine to 18% by 2034, with the California growth rate expected to be even higher.

Factors contributing to the demand include special education services in California's public schools, hearing loss detection via the newborn hearing screening program, and the aging population that will experience hearing loss, suffer strokes, cognitive decline, and other debilitating illnesses. This increased consumer demand for speech and hearing services will make the board's role even more critical to ensure the safety and efficacy of these professions over time.

I'd like to share some of the board's accomplishments since the last sunset review. The board's most significant achievement since our last sunset review was a successful completion of our board's modernization project for initial licensure applications, which provided applicants with a streamlined and user friendly licensure process that allows them to submit their application and payment online, as well as check the status of their license application, remediate deficiencies through the application system.

This project also allowed the board to review, streamline, and automate many internal staff processes leading to a 71% reduction in application processing times within two years of implementation, overall enhanced staff efficiency, and increased workload capacity of approximately 32%. The streamlining of the application process and staff workload has enabled the board to successfully meet the continued increase in application workload over the past four years.

The board hopes to be able to engage in a business modernization project for its enforcement and administrative functions in the future, and is ready and willing to initiate this work once board and departmental resources allow.

Since the last sunset review, the board has also been able to obtain additional staffing for its enforcement unit through the budgetary process, which enabled the board to start ongoing continuing education audits of 5% of its licensees. The board began ongoing continuing education audits in fiscal year twenty twenty four, twenty twenty five, and has completed 249 audits since that time, and is in the process of completing an additional 135 audits by the end of this fiscal year.

Currently, the average failure rate for the continuing education audits is about twenty eight percent, resulting in the board spending considerable time educating licensees regarding the board's requirements, as well as engaging in the board citation and fine process for violation of these requirements. Both the board vice chair, executive officer, and I can provide educational opportunities with groups of licensees to help educate licensees on the board's requirements.

We strongly believe that the board's educational efforts will result in a reduction of continuing education audit failures over the next few years.

On the regulatory side, the board continues to work on updating its regulatory framework. Since our last sunset, we have successfully strengthened supervision requirements for both speech language pathology assistance and required professional development licensees, updating continuing education requirements for licensees, and enacted additional consumer protection measures against false, fraudulent, misleading, and deceptive advertising practices in hearing aid sales. There is a need for the board.

Overall, the board has shown itself to be a good steward of its limited resources, successfully leading a small but mighty tight team of public servants to achieve the most effective administration possible over the mission critical responsibilities of the board. We continue to do everything in our power to create efficiencies and cost savings where we can, while strongly enforcing the board's laws and regulations to protect California consumers of speech and hearing services.

To that end, we strongly urge the joint committee to recommend the continued regulation of the practices of speech language pathology, Audiology, and hearing aid dispensing by the board. We are pleased to take any questions at this time.

Thank you very much. Anyone else like to make any opening remarks? Nope. Open to colleagues for questions or comments. See any questions or comments.

This one's a little less a little less interest. I guess there's interest as a little less activity. No? No? One quick question regarding the California Academy of Audiology's request to establish a new license category of audiology assistance.

Could the board talk a little bit about the impact this would have on access to care, on consumer protection, diversity within the profession, or or anything else that you think is important to touch upon?

Yes. I'd like to take that one. So I've been an audiologist for almost twenty years working in a variety of environments, owning my own private practice, working in major health care settings, working at the VA, working in university settings. So I can speak to having help in the clinic from different levels of support. So the audiology practice committee and then the full board discussed this issue and is very supportive of the creation of this audiology assistant license type.

We currently have an audiology aid category that is not licensed and has led to, you know, limited use by audiologists due to, those individuals not having significant education or training, and therefore not being able to be unsupervised in any way, to assist in the clinic. So I see many people wearing glasses here. So audiologists, you know, a lot of people don't really understand what an audiologist's clinic might look like or operate like, but it's it's unlike an optometry office.

Right now, when you go to get your eyes checked, you know, you generally will see an optometric assistant to do the screenings and the general annual type of tests. Then you will meet with the optometrist who will create your prescription, and create the plan, make sure that there's no medical need for you to continue on to, like, an ophthalmologist or or other medical professional.

And then they'll send you out to the optician who will fit your prescription, make sure everything is comfortable, and you may go back and see them a few times. So those support staff, those support assistants that are educated and trained is what audiology really needs. Currently, the audiologist sees the patient for all of that from start to finish. So every patient encounter is probably about an hour on average.

So if you can imagine the the load of patients that can get through an audiologist door in a day is much smaller than what an optometrist, for example, can can handle.

We know that the demand for audiology services is there. We have a lack of access. There's only 2,500 audiologists in the state, for 39,000,000 residents. We know 65 percent of adults over the age of 70 have hearing loss, and we know that over a thousand babies are identified every year in California with having hearing loss. So the demand on audiologists to take care of people in the state is is quite high.

Having an actual trained category of an assistance would really help the audiologists pump through more patients and serve more constituents and patients throughout California. The California Academy of Audiology also submitted a survey they did recently in the last month here stating that 88% of respondents did state that they would hire an audiology assistant. And on average, most of them anticipate hiring three of them. So if you do the math, that equates to over 6,000 audiology assistants of potential demand.

So it does look like the demand is is there for this licensee category and that audiologists throughout the state believe it would be helpful.

Great. Thank you for the additional context. Appreciate it. Seeing no additional questions, we're gonna open up to members of the public. Folks, just as a reminder, you've got two minutes each.

Thank you, mister chair members. Andrea Ball here today on behalf of the California Speech Language Hearing Association. Thank you for the, opportunity to comment and thank the committee staff for meeting with us previously. CSLHA represents speech language pathologists, speech language pathologists assistants, audiologists, students, and other related professionals. They work in a variety of settings across California, education, health care, and private practice settings.

We support the continued licensing and regulation by the board. I wanna thank them and their leadership, for collaboration, ongoing, proactive communication. It's been really valuable. Three topics we wanted to highlight, that were included in the report. First, on the business modernization, project, and you you heard the president, speak to this.

The online licensing system has really had a significant, positive impact improving the timelines, being it having people be able to get submit, get questions answered online, and it's really approved application accuracy and reduced the processing time frames. As you may know, they had to limit the scope of the modernization project to initial licensing applications. So CASA does support continued modernization board procedures and the remaining projects, which include shifting the paper based process to a tonic base as the board and the DCA resources and funding allow.

Second, on the continuing education and competency requirements, Kasia commented on the on these changes and really appreciate the additional flexibility, including the increase of the hours that can be accrued via self study. Third on the, and this came up in another context, but on the webcast of meetings, board meetings, that's really made a difference and we've been able to have members across the state observe, participate, provide public comment, and they've really value that as well.

So for these reasons, we appreciate and value the work of the board and support not only its continuation, but providing with the resources necessary to continue to make some of those business improvement and other, projects. Thank you.

Thank you very much.

Good morning, mister chairman and members. Nick Brokaw here on behalf of the California Academy of Audiology. First and foremost, wanna voice our continuing support and appreciation for the board and the wonderful work that the Board Members and their staff do. And second, I I think doctor White said it better than I ever could, but we're obviously here to express our support for the creation of a new license type new to this state, but commonplace elsewhere for audiology assistance. She said everything.

I don't wanna repeat it. The only thing I would add is that there is great precedent here. Our sister profession, the speech language pathology profession, they came up here about 28 years ago voicing the same concerns, access to care, and they created an assistant, an SLP assistant. They had aids. They still have aids, but now they have a profession that has far fewer access to care issues than we do in the audiology profession.

So we're expecting to see similar, improvements there, and, you know, there's a place for both aids and audiology assistance and appreciate, your consideration. Thank you.

Thank you very much.

Hello. My name is William Truong, and I'm a law student at the University of San Diego speaking on behalf of the Consumer Protection Policy Center. While we support retention of the board, we have three recommendations that we urge the community to consider. First, we recommend that the legislature add four public members to the board's composition to establish a public member majority on the board.

The board's current majority licensee membership creates the impression that licensees the board is supposed to be regulating actually wield control over the board and its decision making.

This would better align the board with the US Supreme Court's decision in North Carolina State Board of Dental examiners versus FTC, which warned against boards that are dominated by active market participants. Second, we recommend that the legislature grant statutory authority for the board to establish a proactive and routine inspection program. An inspection program would benefit the public by deterring unlawful conduct from licensees and allowing the board to detect unlawful practices without the public needing to initiate complaints.

And third, we recommend that the committee scrutinizes the board's failure to meet its performance targets for completing investigations and opposing formal discipline. Since 2021, the board has, on average, taken over three hundred days to close investigations upon receipt of a complaint and more than a thousand days to impose discipline, ensuring that the board conducts investigations and opposes discipline in a timely manner, which strengthen public faith in the board and better protect the public.

We've included more information in our letter to the committee. Thank you for your time and consideration.

Thank you very much. Seeing no additional members of the public wishing to speak on this item, that'll wrap up this part of it. Thank you for the presentation and answering some of the questions. Appreciate it. Looking forward to future conversations.

The next item the next item on our agenda today is the board of occupational therapy. Testifying today is Christine Wietlisbach, board vice president, and Austin Porter, executive officer. Come on up, and we're ready when you are.

Okay. Thank you.

We would like to thank chair Berman and the entirety of the joint legislative committee for this opportunity to show you why regulation of the occupational therapy profession remains necessary for the protection of California consumers and for your time and consideration today. My name is doctor Christine Wietlisbach. I'm vice president of of the board. I'm standing in for our president, Beata Morcos. She unexpectedly had to fly overseas to attend to a family emergency in Ukraine, and her thoughts are with miss Markos and her entire family.

I've been a practicing occupational therapist for 37 years, nearly 35 of those years at Eisenhower Medical Center. That's in the Palm Springs area in Cal in Southern California. And I'd also like to introduce our executive officer, mister Austin Porter. Regulation of the occupational therapy profession in California began in 2001, following passage of the occupational therapy practice act. Since then, the born the board has grown to regulate approximately 17,000 licensed occupational therapists and 4,000 licensed occupational therapy assistants.

As the profession grew, the board successfully sought necessary legislative and regulatory changes that supported its consumer protection mandate, and it continues to do so today. Notably, these changes include the establishment of the board's disciplinary guidelines, supervision standards, advanced practice education and training requirements, minimum standards for infection control, and robust continuing competency requirements. The board consistently seeks stakeholder feedback and uses this information to improve its licensing and regulatory programs.

In January 2025, the board uses feedback to help develop its latest strategic plan, which addresses licensing, enforcement, outreach, laws and regulations, and organizational and administrative effectiveness. The new strategic plan also affirms the board's mission to protect California consumers receiving occupational therapy services through effective regulation, licensing, and enforcement.

Since the last sunset review, the board has made noticeable strides. Our enforcement division has nearly doubled the number of complaints it processes while exceeding intake timeline and case aging targets and reducing the number of pending cases. The licensing division has issued over 7,000 licenses to qualified applicants while exceeding processing timeline targets. The board has also successfully navigated recent leadership changes in the form of a new board president and vice president, new executive officer, and five new board members all in the same year.

These accomplishments demonstrate adaptability and commitment that will serve the board in the years to come as it continues to uphold its mandate.

The board currently oversees a budget of over 300 and I'm sorry, $3,000,000 and has five months in reserve. Further details regarding the board's activities since the last review can be found in the sunset review report provided to the committees. We feel that the information contained in our report demonstrates our continued commitment to refining and enhancing the board's ability to protect consumers, and we're eager to provide any requested information as part of our testimonies today. Thank you.

Thank you. Any opening comments or do you have questions?

For now, I'd just like to echo Vice President Wietlisbach's sentiments that we're grateful to the committee for the opportunity to be here today and testify. Great. Appreciate you being here.

Open up to colleagues for any questions or comments that folks might have. It's a word a calm group today or at least now. So one quick question I have. I understand that the board is seeking some new fee authority during the course of this sunset. Can you talk a little bit about the what specific cost pressures have most affected the board's budget and if there are other fees, that might be able to be offset.

Absolutely. I'd be happy to answer that. And if I could, just provide a little bit of background information about our request for fees in addition to answering about the cost pressures. So when I was appointed to the position of the board's executive officer in June, one thing that was immediately apparent was that we needed to address our fund condition. So that became a top priority for me and for the board moving into 2026.

At the time, we were expected to finish fiscal year twenty five, twenty six with about three point nine months in reserve, and we were projected to reach solvency by fiscal year twenty twenty eight, twenty nine. Since then, a couple of things have changed. The first being that the budget office reevaluated our projected revenues for the current fiscal year, and we had expenditure reductions. So we are now finishing or expected to finish fiscal year twenty five, twenty six with about five point one months in reserve.

However, we're projected to be operating with only point eight months in reserve by fiscal year 2028-29.

Concurrently, while this was going on, the board voted to increase our renewal fees to the current statutory cap of $300 biannually. And when this is factored in along with the, expenditure reductions and higher than projected revenue mentioned earlier, we're expected to have about eight point four months in reserve by fiscal year twenty twenty eight, twenty nine. However, with that said, we would be spending the next four years capped out on all of our fees.

So to answer your question, chair Berman, the cost pressures that are affecting the board are the same as they were at our last sunset review in 2022. These consist largely of DCA pro rata costs and enforcement costs relating to the Department of Justice and court reporter costs, which have gone from hourly rates to half day or full day rates.

In addition to that, the cost of personnel is simply increasing. Employee state employee benefits and pay rates have gone up, and our fee increases have not been enough to account for those changes. In summary, the position that the board is taking currently on its fund condition is fee and fees is that we expect to have a $300 renewal fee, which is the statutory cap by July.

And we are requesting additional statutory authority so that we're not capped out on all of our fees for the next four years. We also, while working on the regulatory package with the DCA budget office, took stock of all the fees that the board charges currently and looked at what the administrative cost for those fees were.

So some of those, additional services include things like, licensure verification, duplicate licenses, so if you need a replacement license or a pocket card, application fees, as well as the review of advanced practice applications. The review we conducted with the budget office determined that the fees we were charging simply just did not cover the administrative cost of providing those services.

So that brings us me to the second thing that we're requesting in terms of our caps, which is additional caps for some of those, additional fees so that we can evaluate those in more in-depth and adjust through regulation as we navigate through the next four years. Great.

Thank you for the very thorough answer. I think with that, we'll open up to members of the public to see, if any folks have any comments. Please come on up as a reminder of two minutes.

Good morning, chair members. Jessica Moran with Capital Advocacy on behalf of the Occupational Therapists Association of California, here in support of the OT sunset, extension. Just wanna thank the committee staff and the board for all of the work that went into the legislative report. On behalf of OTAC's 22,000 members, again, we support the extension of the sunset, appreciate all the work that the board does to regulate the profession and perfect, protect consumers.

We submitted comments to the committee and really, just wanna point out one thing that we are extremely thankful and grateful for the, proposal to reduce the number of hours for hand for advanced practice hand therapy from four hundred and eighty hours to eighty hours.

This is on the job training. This is really important, an update to curriculum that, recognizes how curriculum has been updated in the last twenty years and will increase access to care and reduce barriers for those who are trained well in their programs. I'm looking forward to working with the committee and the board to do this interpretive process, and that's it for today. Thank you.

Alright. Thank you very much. Seeing no additional, questions from members of the public, that'll wrap up this section of our sunset hearing. Thank you very much for the presentation and answering the questions.

Thanks. The final item on our agenda today is the Board of Naturopathic Medicine. Testifying today is doctor Dara Thompson, board president, and Rebecca Mitchell, executive officer. And we're ready whenever you are. Take your time. You bet. And just hit the little microphone buttons in front of you.

Does that work?

Perfectly.

Alright. Well, thank you so much for having us here for this hearing. I am doctor Dara Thompson. I am the president of the California Board of Naturopathic Medicine, and this is Rebecca Mitchell, our executive officer, and we are so appreciative that she's here in person. It was no small effort, but I'm lost without her.

So I'm gonna introduce myself, and then Rebecca can introduce herself, and we can move forward with the questions.

Great. And if you just bring the microphone. Yeah.

A bit closer.

A little bit closer. There you go.

Is that better?

That's perfect.

Okay. Great. I'm actually a little, like, vertically challenged.

Alright. I'm doctor Dara Thompson. I'm the president of the California Board of Naturopathic Medicine. I am a native Californian, and I've been a naturopathic doctor for 24 years. I have been licensed in California, since 2005, and I've been on the board since 2015.

I practice currently in San Rafael, California and San Francisco, where I have an broad reaching practice that treats a lot of different demographic groups. And I just really, really love naturopathic medicine. I'm passionate about what we're doing for people and also very, very passionate about protecting the consumers of California. As board president, it is my foremost responsibility shared by all Board Members to provide public protection. Our mission is to ensure that consumers are safe from individuals who violate the Naturopathic Doctors Act.

Either licensed individuals who violate their practice act or unlicensed individuals practicing outside of their scope. As our sunset review details, the distinction between those two groups is critical. And many complaints we receive come from consumers who believe that we that they are seeing a licensed naturopathic doctor only to learn later that they are being treated by an unregulated individual. California's naturopathic doctors are rigorously educated in accredited doctoral level programs and held to the highest professional and ethical standards.

They serve communities across the state, including a little over 85% practicing in underserved areas, and they play a meaningful role in California's health care landscape.

However, limitations in the current statute create confusion for consumers, restrict safe and appropriate practice for licensed providers, and undermine our ability to enforce against unlicensed activity. The board is committed to transparent accountability and thoughtful regulation that keeps the public safe while supporting a modern well functioning health care system. We welcome the opportunity to work collaboratively with the legislature on solutions that strengthen consumer protection, clarify statutory authority, and enhance the oversight of both licensed and unlicensed practice.

Thank you so much for your consideration in your partnership in advancing public safety. We're happy to answer any of your questions.

Great. Thank you very much.

Alright. Can you hear me?

Perfect.

Alright. Great. My name is Rebecca Mitchell, and I am the executive officer of the naturopathic I'm sorry, the California Board of Naturopathic Medicine. It is my privilege and and total honor to be here with you guys today and to answer any questions that you have. The board's primary mission is to cons is to consumer protection, and we take that responsibility seriously.

More than 70% of our enforcement workload involves unlicensed activity, and the risks to the public are significant. Modern naturopathy

Modern naturopathic medicine intentionally split from traditional naturopathy decades ago because unregulated practices lacked scientific training, clinical standards, and public safety safeguards, problems so serious that many states ultimately created licensed naturopathic doctors. Today, more than 70% of our enforcement cases involve unlicensed individuals using medical sounding titles, and consumers routinely mistake them for medically trained naturopathic doctors. Confusion that has already resulted in real harm, including a recent fatality. This is not a philosophical difference.

It is a life or death distinction between a regulated medical profession and individuals with no required training, oversight, or accountability.

We continue to be deeply concerned about the deliberate efforts by some unlicensed individuals to project legitimacy. As our report shows, these cases are increasing and our recent fatality case underscores why strong title protection and clear statutory authority are essential. Since the last sunset review, the board's also made meaningful progress, modernizing operations, improving enforcement timelines, strengthening staff capacity, and adopting a strategic plan that guides our work through 2030. A central component of that plan is our commitment to the diversity, equity, inclusion, and accessibility.

All boards and staff complete DCA required DEIA and unconscious bias training.

DEIA principles are embedded directly into our decision making, our environmental scans, our stakeholder engagement, and policy planning. For us, equity and safety are inseparable. Every Californian deserves access to safe regulated health care regardless of language, background, or community. Despite these improvements, significant structural issues remain, persistent consumer confusion caused by the lack of title protection, practices train barriers that limit access to qualified care, and fiscal realities of regulating a small licensee profession.

We look forward to working with the legislature to strengthen the tools needed to protect the public and ensure that Californians can clearly distinguish between licensed naturopathic doctors and unlicensed individuals.

And thank you so much for your time, and I'm happy to answer any questions you may have.

Thank you both very much. Open up to colleagues for any questions or comments. Seeing none, the presentation was that thorough. Appreciate that. One question I'll ask has to do with sustainability.

You're one of the smallest boards in terms of the number of licensees with a little over a thousand naturopathic doctors. Do you think this presents a concern for the long term sustainability of your fund condition? And are there any opportunities to grow the number of licensees under your jurisdiction as an alternative to simply raising fees?

That's a that's a great question. Thank you so much for it. You know, in our, sunset report, I think we highlighted, some of the problems with the population and and keeping the population here. We have one of the, naturopathic schools down in San Diego, California, Ambassador University. And we should really be getting a lot of their graduates, and they should be remaining here and having businesses.

But, unfortunately, because of the current scope of practice that Kinda keeps them from practicing at their full the full scope of their training, a lot of the graduates will leave and go on to Arizona up to Oregon or Washington where they have a full scope practice.

Gotcha. Definitely something worth Yeah. Looking into. Appreciate that. With that, we'll open it up to members of the public. Thank you very much.

Thank you.

So if members of the public have any comments they'd like to make, just to remind you, you have two minutes each.

Good morning, chair and members. George Soares of the California Medical Association. Just wanted to flag a few, issues that we have with the with the report. And on the front end, I wanna say really appreciate everyone here today and and, the reaching out from the board and all the interest and stakeholders in this over the last few months.

Really appreciate that dialogue and look forward to continuing that. First up for us is issue number three. CMA has concerns with replacing the physician member of the board with another professional or public member. The board in their sunset report noted that a physician's participation is essential to ensure that medical standards are appropriately considered and not held in the advisory committee's reviews and recommendations.

In the absence of a second appointed physician, the sole physician member has to serve on both advisory committees that require physician and surgeon representation.

Next up is issue number 11. CMA opposes the, proposal to expand, naturopathic doctors' scope of practice to include prescribing medications, including controlled substances, administering vaccines, and performing office procedures as a mean to address the declining number of licensees. Issue number 12, CMA is surprised to read the board did not receive any complaints relating to COVID nineteen vaccines while naturopathic doctors had this authority during the pandemic emergency. CMA has concerns about including vaccine administration in the scope of practice without physician supervision for vaccination.

And then lastly, issue number 14, CMA has concerns with authorizing naturopathic doctors to provide documentation for workers' compensation and for the DMV. Thank you.

Thank you very much.

Good morning. Honorable members of the joint session, my name is Brenda Generali and I represent the International Iridology Practitioners Association, which is a research and educational organization serving iridologists in The United States and abroad since 1991. Iridology is the non diagnostic study of the colors, fibers, and structures of the iris to assess inherent tendencies and strengths. In California, it has been practiced legally since 2001 under the alternative and complementary health care act business and professions code section two zero five three point six.

Today, over 1,000 practitioners of different health care disciplines including iridologists utilize this method within the bounds of the law.

We are here today because of serious concerns regarding the California Board of Naturopathic Medicine. In a public meeting of the Idaho Board of Naturopathic Health Care, the board's administrative director, miss Rebecca Mitchell, stated that iridology is diagnostic and indicated she would prefer practitioners she would refer practitioners to the attorney general. This statement was recorded and shared with legislative staff. This position is inconsistent with California law. The Department of Consumer Affairs has confirmed that the board has no purview over alternative and complementary health care practitioners.

Iridologists are not licensed by nor regulated under the board. We believe these actions have created confusion, exceeded statutory authority, and risk infringing on the legal rights of practitioners operating in full compliance with state law. We respectfully urge the legislature to clarify the board's authority and ensure it remains limited to regulating naturopathic doctors without encroaching on lawful alternative health care practitioners. We will be opposed to this act otherwise. Thank you.

Thank you.

Good morning. I'm Christine Issel, and I'm a reflexologist and also administrative director of the California Coalition on complimentary, excuse me, natural practitioners. Our organization represents a thousand practitioners across the field of alternative and complimentary health care throughout California. As you're aware, in 2001, the legislature enacted the alternative and complementary health care act codified business and professional code 2053.5 and 2053.6. The law establishes three health care three key protections.

First, it protects the right of California to seek and receive complimentary and alternative health care services from unlicensed practitioners provided that the required disclosure and safeguards are followed by practitioner. Second, it protects the right of the practitioner to provide these services so long as they comply with the statute's transparency and consumer protection requirements. Third, it establishes a clear structure that has successfully functioned for over 25 years and within the existing framework. And that the excuse me. The statute is working as designed.

Granting the naturopathic medicine board authority or oversight over unlicensed complimentary therapies would contradict both the language and the legislative intent of the alternative complementary health care act. It would also create redundant regulations and serves neither the public nor the practitioners operating fully under the existing statute. Therefore, the naturopathic medicine board's jurisdiction should remain limited to its licensees, not to the unlicensed practitioner.

If you could wrap up, that'd be great. Thank you. Thank you.

Good morning. I'm Susie Danette Brown. I represent the Reflexology Association of California, a 501 c three organization established in 1992 to represent reflexologists. Reflexology is a noninvasive practice that maps the body through the feet, hands, and outer ears using specialized manual technique to stimulate neural pathways to promote relaxation and support optimal body function. Our field maintains its own national testing agency with a psychometrically valid examination along with established state, national, and international professional organizations.

Educational standards are overseen by the National Council of Reflexology Educators. In California, reflexologists practice lawfully under the alternative and complementary health care act. Business and professional code sections 2053.5 and 2053.6. The statute provides safeguards while preserving public access to complimentary care. Importantly, it predates the Neuropathic Doctors Act and operates independently of it.

Our concern is with is that the California Board of Naturopathic Medicine has begun attempting to regulate alternative and complementary health care practices that fall outside its statutory authority. We stand in solidarity with other practitioners including naturopaths. We do not seek regulation under this board. The legislation legislature has already established a clear framework through the medical practice act. We respectfully urge that you to adopt the proposed amendments to clarify the board's authority, protect established protect practitioners, and prevent further regulatory overreach. Thank you for your time.

Thank you.

Hello. My name is William Truong. I'm a law student at the University of San Diego. Once again, speaking on behalf of the Consumer Protection Policy Center. While we support retention of the board, we have several recommendations that we urge the committee to consider.

The naturopathic medicine profession wield significant control over the board and its decision making, which is a concern when the board unduly protects the interests of its licensees over public protection. Over the previous sunset cycle, the board has disciplined a shockingly well number of licensees, only two licensees disciplined out of 276 investigations. Additionally, we are concerned that the board's quick average times for completing investigations, which were as low as eighteen days at one point, suggests its investigative process may not be sufficiently thorough.

Accordingly, we recommend that the board's composition be restructured to three naturopathic doctor members, one physician or surgeon member, and five public members. We also recommend that each advisory committee within the board should have at least one public member.

Additionally, we recommend that the legislature reject the board's recommendations made in section 10, issue three of the sunset review report. First, we oppose the board's request to eliminate the requirement for NDs to have supervisory protocol agreement with a physician to furnish drugs, because eliminating it would remove oversight and increase the risk of medication related errors.

Second, we believe that the standardized protocol for administering vaccinations should be maintained because various studies show higher rates of vaccine hesitancy among NDs, meaning granting them independent access to vaccinations could pose risks to public safety? And, Dird, we believe that NDs should be denied authority to perform searching. We've included more information in our letter to the committee. Thank you for your time and consideration.

Thank you.

Good morning. Thank you for your time today and your time on such a thorough analysis. I'm doctor Meredith Bull. I'm here on behalf of the California Naturopathic Doctors Association in support of SB 1303 and, the board of naturopathic medicine.

I specifically want to emphasize the issue of title protection. It is exhausting to continually have to have conversations with patients, prospective patients, and in just general conversations about the differences between what I do as a licensed naturopathic doctor with the ability to practice medicine and those that are not licensed and cannot practice medicine. I previously practiced in Washington state. I did not have to have these conversations. It was not an issue because naturopath is a protected term there and reserved for licensed naturopathic doctors.

I also wanna be clear that this is not an attack on those that aren't licensed. We do sympathize in some way because the work that they do, that some of these other practitioners talk to are meaningful in their own way. But the issue is, it's often conflated with the practice of medicine, and that is something that kind of needs to be delineated a little bit more. And that is what the practice or the title protection would do for us.

We want to protect the integrity of what it means to practice naturopathic medicine, and that would come with the protection of the term naturopath in all of its iterations.

It's really too confusing otherwise and ultimately an issue of consumer safety as we've discussed. Thanks for your time.

Thank you.

Good morning. Roxanne Gould representing the California Naturopathic Association, the other CNA. I know that you regularly say please don't duplicate previous testimony, so I'm gonna say me too to the we're talking about the complimentary health care act that was authored by John Burton. He also authored the acupuncture act and the naturopathic doctors act. I do wanna say that when the board of naturopathic medicine bill was being debated, it was carefully crafted and included language that specifically said they are not authorized to regulate traditional naturopathy.

We fall under the, board of, medical board of California. What we're seeing now is an attempt by the board of naturopathic medicine to duplicate and expand existing authority, and we ask that the, legislature reaffirm its original intent and maintain the integrity, excuse me, of the, complimentary health care act. Thank you.

Thank you.

Honorable chair Berman, members of the joint session. My name is Mark Murad Hay. I serve as the president of California Naturopathic Association. For over three decades, our association has represented naturopaths, traditional naturopaths, and naturopathic practitioners across California. We are here today to respectfully raise concerns regarding the proposed expansion of authority by the California Board of Naturopathic Medicine.

We fully support the legislature's commitment to public protection. However, we believe existing California law already provides a clear and effective framework. Since 2001, the alternative and complementary health care act has allowed these practices to operate lawfully while ensuring that any harm or negligence is addressed through the courts. Our concerns is not with regulation itself, but with jurisdictional overreach. The board's current proposals would extend authority beyond licensed naturopathic doctors to include educational content, wellness guidance, and practitioners who are not under its statutory authority.

This risks creating confusion, limiting lawful practice, and expanding enforcement beyond what the legislature originally intended. When the Naturopathy Doctors Act was enacted, it was understood that licensure would not be used to eliminate or restrict the broader practice of naturopathy. We believe it is important to reaffirm that boundary. We respectfully ask the legislator to clarify that the board's authority applies only to licensed naturopathic doctors. Preserve to legal protections established on the lawfully and safely working California Senate Bill P 577.

Ensure that lawful alternative and complementary health care practices remain protected. This approach maintains public safety while respecting existing law and long standing practice in California. Thank you for your time and consideration.

Thank you.

Good morning. Thanks for opportunity to support the Board of Naturopathic Medicine SB1303. My name is doctor Aliza Cicerone. I'm the past president of the California Naturopathic Doctors Association and the past legislative chair. We're in full support of the board and the continued licensing and of educated and trained naturopathic doctors where we have all completed four years of postgraduate medical school and extensive licensing exams.

We also support the board's recommendation for title protection as it's a necessary step to ensure patient safety and transparency regarding education and licensing. I began practicing here in California, in Southern California thirteen years ago. I completed my residency at Indiana University, my fellowship at Cancer Treatment Centers of America. I've seen a number of patients who believe that they were seeing a licensed naturopathic doctor because they were told that both verbally and in print.

Because of the inaccuracy in that verbiage, patients believe that they were seeing a provider who was licensed to practice medicine, which they were not.

We don't have an issue with natural health practitioners working within the boundaries of lifestyle coaching as long as they're not falsely misrepresenting themselves as doctors and misrepresenting their training and education while they diagnose and treat. And that happens a lot by using the terms naturopath, naturopathic doctor, or ND. Thank you so much for your time and consideration.

Thank you. Seeing no additional members of the public, that will complete this section of today's hearing. Thank you very much. Appreciate it. And that completes the hearing.

So thank you very much. I wanna just emphasize thanks to staff for all the amazing work that they've done, on all these sunset reports and and the boards and councils, working with us and more conversations to come. Thanks so much.