Bill Text: CA SB411 | 2011-2012 | Regular Session | Introduced
NOTE: There are more recent revisions of this legislation. Read Latest Draft
Bill Title: Home Care Services Act of 2012.
Spectrum: Partisan Bill (Democrat 9-0)
Status: (Vetoed) 2012-09-30 - In Senate. Consideration of Governor's veto pending. [SB411 Detail]
Download: California-2011-SB411-Introduced.html
Bill Title: Home Care Services Act of 2012.
Spectrum: Partisan Bill (Democrat 9-0)
Status: (Vetoed) 2012-09-30 - In Senate. Consideration of Governor's veto pending. [SB411 Detail]
Download: California-2011-SB411-Introduced.html
BILL NUMBER: SB 411 INTRODUCED
BILL TEXT
INTRODUCED BY Senator Price
FEBRUARY 16, 2011
An act to add Chapter 13 (commencing with Section 1796.10) to
Division 2 of the Health and Safety Code, relating to public health,
and making an appropriation therefor.
LEGISLATIVE COUNSEL'S DIGEST
SB 411, as introduced, Price. Home Care Services Act of 2011.
Existing law provides for the In-Home Supportive Services (IHSS)
program, a county-administered program under which qualified aged,
blind, and disabled persons receive services enabling them to remain
in their own homes. The IHSS program includes various eligibility
requirements for individuals who provide services to recipients under
the program. Under existing law, a private provider of in-home care
services is not subject to the requirements of the IHSS program.
Existing law provides for the licensing and regulation of various
community care facilities by the State Department of Social Services.
This bill would enact the Home Care Services Act of 2011, which
would provide for the licensure and regulation of home care
organizations, as defined, by the State Department of Public Health.
The bill would specifically exclude entities that provide services
under the IHSS program from the definition of a home care
organization. The bill would impose various licensure requirements on
a home care organization and would also impose a civil penalty on an
individual or entity that operates a home care organization without
a license. The bill would require a home care organization to inform
a client of certain things before arranging for the provision of home
care services, as defined, to that client, including, but not
limited to, the types and hours of available home care services and
the extent to which payment may be expected from specified sources.
In addition, the home care organization would be required, among
other things, to distribute to the client its advance directive
policy and provide a written notice to the client of certain rights.
The bill would also prohibit a home care organization from hiring an
individual as a home care aide unless that individual meets certain
requirements, including, but not limited to, demonstrating that he or
she has specified language skills and completing a minimum of 5
hours of training as specified.
This bill would require a home care organization to conduct
background clearances on home care aides, as specified, and to
require home care aides to demonstrate they are free of active
tuberculosis. The bill would also require a home care organization to
conduct regular evaluations of its home care aides, as specified,
and to ensure that home care aides demonstrate basic competency in
certain areas. The bill would establish the Home Care Organization
and Home Care Aide Certification Fund, would authorize the department
to impose various fees to be deposited in that fund, and would make
a continuous appropriation from that fund, except as specified, to
the department to carry out the provisions of the bill. This bill, in
addition, would prescribe enforcement procedures, fines, and
penalties for violations of the act.
Vote: majority. Appropriation: yes. Fiscal committee: yes.
State-mandated local program: no.
THE PEOPLE OF THE STATE OF CALIFORNIA DO ENACT AS FOLLOWS:
SECTION 1. The Legislature hereby finds and declares all of the
following:
(a) Seniors, individuals with disabilities, and the frail elderly
frequently find themselves in need of part-time to full-time
assistance from a caregiver in order to live at home independently.
(b) Out of the 701,000 estimated home care aides working in the
country, more than 70,000 work in California.
(c) The Employment Development Department has identified home care
services as one of the fastest growing fields of employment.
(d) In California, most individuals hiring a home care
organization believe that the home care aide entering their home has
been thoroughly screened and trained. However, a business license is
the only requirement needed to provide nonmedical home care services
in an individual's home.
(e) In view of the increasing number of home care aides entering
private homes, the number of incidents of abuse and neglect by home
care aides currently being reported in the media is alarming and
concerning because, according to prosecutors, for every reported
incident of abuse or neglect, four others go unreported.
(f) Twenty-three states, including Texas, Illinois, Florida, and
New York, have standards requiring home care organizations to
register or obtain a license.
(g) Discharge planners commonly maintain lists of home care aides
and home care organizations for purposes of patient referral without
any information about the individuals or the organizations, thereby
placing both the patient and the referring organization at risk.
(h) Typically, family members looking for home care services are
in a crisis and will not ask all of the "right" questions when
choosing a home care organization. In addition, there is currently no
centralized list of home care organizations in California for family
members, seniors, or disabled individuals to consult when in need of
home care services for their loved ones or themselves.
SEC. 2. Chapter 13 (commencing with Section 1796.10) is added to
Division 2 of the Health and Safety Code, to read:
CHAPTER 13. HOME CARE SERVICES
Article 1. General Provisions
1796.10. This chapter shall be known and may be cited as the Home
Care Services Act of 2011.
1796.11. The State Department of Public Health shall administer
and enforce this chapter.
1796.12. For purposes of this chapter, the following definitions
shall apply:
(a) "Client" means an individual who receives home care services.
(b) "Department" means the State Department of Public Health.
(c) "Home care aide" means an individual who provides home care
services to a client in the client's residence, and is synonymous,
for purposes of this chapter, with "caregiver," "custodial care,"
"personal care attendant," "homemaker," and "companion." In addition,
"home care aide" includes an individual who qualifies as a personal
attendant, as defined in Industry Wage Order 15-2001, issued by the
Industrial Welfare Commission, who provides home care services.
(d) "Home care organization" or "organization" means an
individual, partnership, corporation, limited liability company,
joint venture, association, or other entity that arranges for the
provision of home care services by a home care aide to a client in
the client's residence and that is licensed pursuant to this chapter.
"Home care organization" does not include any county providing
in-home supportive services pursuant to Article 7 (commencing with
Section 12300) of Chapter 3 of Part 3 of Division 9 of the Welfare
and Institutions Code, without regard to whether the county provides
these services as a public authority or through a nonprofit
consortium established pursuant to Section 12301.6 of the Welfare and
Institutions Code.
(e) "Residence" means a temporary or permanent location where a
client receives home care services.
(f) "Transportation" means transportation in a motor vehicle in
good working order provided by a home care aide who is a licensed and
insured driver.
1796.13. (a) For purposes of this chapter, "home care services"
means services provided by a home care aide to a client who, because
of advanced age or physical or mental infirmity, cannot perform these
services for himself or herself. These services include, but are not
limited to, bathing, dressing, feeding, exercising, personal hygiene
and grooming, transferring, ambulating, positioning, toileting and
incontinence care, assisting with medication that the client normally
self-administers, housekeeping, meal planning and preparation,
laundry, transportation, correspondence, making telephone calls,
shopping for personal care items or groceries, and companionship.
This subdivision shall not be construed to authorize a home care aide
to administer medication that would otherwise require administration
or oversight by a licensed healthcare professional.
(b) Home care services shall not include any of the following:
(1) Services authorized to be provided by a licensed home health
agency under Chapter 8 (commencing with Section 1725).
(2) Services authorized to be provided by a licensed hospice
pursuant to Chapter 8.5 (commencing with Section 1745).
(3) Services authorized to be provided by a licensed health
facility pursuant to Chapter 2 (commencing with Section 1250).
(4) In-home supportive services provided pursuant to Article 7
(commencing with Section 12300) of Chapter 3 of Part 3 of Division 9
of the Welfare and Institutions Code.
(c) This chapter shall not be construed to prohibit an individual
from employing a home care aide without the assistance of a home care
organization.
Article 2. Licensure
1796.20. (a) An individual, partnership, corporation, limited
liability company, joint venture, association, or other entity shall
not arrange for the provision of home care services by a home care
aide to a client in this state without first obtaining a license
pursuant to this chapter.
(b) An individual or entity that violates this chapter shall be
liable for a civil penalty not to exceed nine hundred dollars ($900)
per day for each calendar day of each violation.
(c) Upon discovering that an individual or entity is in violation
of this chapter, the department shall send a written notice of
noncompliance to the individual or entity and to the Attorney General
or appropriate district attorney. Upon receiving this notice, the
Attorney General or district attorney shall do any or all of the
following:
(1) Issue a cease and desist order, which shall remain in effect
until the individual or entity has obtained a license pursuant to
this chapter. If the individual or entity fails to comply with the
cease and desist order within 20 calendar days, the Attorney General
or a district attorney shall apply for an injunction.
(2) Impose the civil penalty described in subdivision (b).
(3) Bring an action against the individual or entity under Chapter
5 (commencing with Section 17200) of Part 2 of Division 7 of the
Business and Professions Code.
1796.21. A home care organization that has its principal place of
business in another state, in addition to the other requirements of
this chapter, shall comply with both of the following requirements
before arranging for the provision of home care services by a home
care aide to a client in California:
(a) Have an office in California.
(b) Obtain authorization from the Secretary of State to conduct
business in California.
1796.22. The enactment of this chapter is an exercise of the
police power of the state for the protection of the public welfare,
prosperity, health, safety, and peace of its people. The civil
penalties provided by this chapter are in addition to any other
penalty provided by law.
1796.23. In order to carry out the provisions of this chapter,
the department shall do all of the following:
(a) Adopt rules and regulations to implement this chapter.
(b) Establish procedures for the receipt, investigation, and
resolution of complaints against home care organizations.
(c) Make available on the department's Internet Web site a list of
home care organizations, including, for each organization, the
organization's name, address, license number, effective date of its
license, and a list of all serious violations.
1796.24. (a) The department shall issue a license to a home care
organization that meets all of the following requirements:
(1) Submits an application, on a form prescribed by the
department.
(2) Pays a licensure fee, as prescribed by the department pursuant
to Section 1796.71.
(3) Submits proof of general and professional liability insurance
in the amount of at least one million dollars ($1,000,000) per
occurrence and three million dollars ($3,000,000) in the aggregate.
(4) Submits proof of a valid workers' compensation policy covering
its home care aides. The proof shall consist of the policy number,
the effective and expiration dates of the policy, and the name and
address of the policy carrier.
(5) Passes any background clearance, as required pursuant to
Section 1796.26.
(6) Provides the department with a list of all of its home care
aides and proof that each satisfies the requirements of Section
1796.60.
(7) Complies with the requirements of this chapter.
(b) The term of a license issued under this section is one year.
The license may be renewed upon application to the board and
payment of the renewal fee prescribed by the board pursuant to
Section 1796.71.
(c) Following the receipt of an application for a license or
renewal of a license under this section, the department shall conduct
an onsite inspection of the applicant to ensure compliance with this
chapter.
1796.25. At least 30 days before the expiration of a license, the
department shall mail to the licensee, at the latest address
furnished by the licensee to the department, a notice stating the
amount of the renewal fee and the date on which it is due, and that
failure to pay that fee on or before the date due will result in the
expiration of the license.
1796.26. (a) In order to obtain a license, the following
individual or individuals shall consent to the background clearance
described in subdivision (b) of Section 1796.62:
(1) The owner or owners of a home care organization if the owners
are individuals.
(2) If the owner of a home care organization is a corporation,
limited liability company, joint venture, association, or other
entity, an individual having a 10-percent or greater interest in that
entity.
(b) If the background clearance conducted pursuant to subdivision
(a) discloses a conviction for a felony or a crime that evidences an
unfitness to operate a home care organization, the application for a
license shall be denied. This subdivision shall not be applied to
deny a license if the individual or individuals, as applicable,
present evidence satisfactory to the department that the individual
or individuals, as applicable, have been rehabilitated and presently
are of good character so as to justify the issuance of a license.
Article 3. Complaints, Inspections, and Investigations
1796.40. (a) The department shall investigate complaints filed
against home care organizations.
(b) The department shall verify through annual random, unannounced
inspections that a home care organization meets the requirements of
this chapter and the regulations adopted pursuant thereto.
(c) An investigation or inspection conducted by the department
pursuant to this chapter may include, but is not limited to, the
following:
(1) Inspection of the books, records, and premises of a home care
organization. An organization's refusal to make those records, books,
or premises available shall constitute cause for the revocation of
the organization's license.
(2) Direct observation of the provision of home care services to a
client in the client's residence, if the client's consent is
obtained.
Article 4. Home Care Organization Operating Requirements
1796.40. A home care organization shall do all of the following:
(a) Post its license in its place of business in a conspicuous
location, visible both to clients and to its home care aides.
(b) Operate the organization in a commercial office space that
complies with local zoning ordinances.
(c) Have plans, procedures, and policies in place, including all
of the following:
(1) Plans and procedures to be followed in the event of
emergencies or natural disasters that would result in the
interruption of home care services.
(2) A documented backup staffing plan in the event that a home
care aide scheduled to provide home care services becomes
unavailable.
(3) A written policy regarding advance directives.
(4) A receipt and disbursement policy for expenditures made on
behalf of a client to ensure that financial abuse does not occur.
(d) Maintain a valid workers' compensation policy covering its
home care aides.
(e) Maintain an employee dishonesty bond, including third-party
coverage, with a minimum limit of ten thousand dollars ($10,000).
(f) Comply with the regulations adopted by the department
implementing this chapter.
1796.41. With respect to home care aides employed by a home care
organization, the organization shall do all of the following:
(a) Ensure that each of its home care aides meets the requirements
of Section 1796.61.
(b) Investigate complaints made by a client, or a client's family
member or guardian, against home care aides regarding a service that
is or fails to be furnished. The organization shall document both the
existence and the resolution of those complaints.
(c) Evaluate home care aides as follows:
(1) Conduct an annual assessment of the performance and
effectiveness of each home care aide, including, if client consent is
obtained, at least one observation of the aide providing home care
services in the residence of a client.
(2) Every 62 days, supervise each home care aide providing home
care services in the residence of a client, provided that client
consent is obtained. The supervision required by this paragraph shall
not be billed to the client.
(d) Ensure that a home care aide, when providing services to a
client, has access at all times to a representative of the
organization who is in a supervisory capacity and who does not
regularly render home care services to that client.
(e) Require a home care aide, while providing home care services,
to wear a badge that includes all of the following information in
12-point type or larger:
(1) The aide's name.
(2) A photograph of the aide.
(3) The name of the home care organization.
(4) The expiration date of the license of the home care
organization.
(5) The home care aide's certificate number as issued by the
department.
(f) Require home care aides to demonstrate that they are free of
active tuberculosis, pursuant to Section 1796.63.
(g) Require home care aides to annually complete not less than
eight paid hours of paid department-approved training on job-related
topics.
(h) Prohibit home care aides from accepting money or property from
a client without written permission from the home care organization.
Article 5. Client Rights
1796.50. With respect to clients, a home care organization shall
do all of the following:
(a) Advise a client of any change in the client's plan for home
care services.
(b) Before arranging for the provision of home care services to a
client, do all of the following:
(1) Distribute to the client its advance directive policy, along
with a written summary of applicable state law.
(2) Advise the client of its policy regarding the disclosure of
client records.
(3) Inform the client of the types and hours of available home
care services.
(4) Inform the client, orally and in writing, of the home care
services that are or are not covered by Medi-Cal or Medicare, as
applicable, and the extent to which payment may be expected from the
client, from Medicare or Medi-Cal, and from any other source.
(c) Inform the client, both orally and in writing, of a change to
the information provided in paragraph (4) of subdivision (b) as soon
as possible, but not later than 30 days of becoming aware of that
change.
(d) Have a written agreement with the client that includes, but is
not limited to, the cost of and the hours during which home care
services will be provided to the client and reference to the personal
attendant requirements, if applicable, as referenced in Wage Order
15-2001, issued by the Industrial Welfare Commission.
1796.51. (a) Home care clients are entitled to the following
rights:
(1) The right to have the client's property treated with respect.
(2) The right to voice grievances free from reprisal regarding a
home care service that is or fails to be provided or regarding the
violation of any of the rights listed in this section.
(3) The right to be informed of and to participate in the planning
of the client's home care services.
(4) The right to confidentiality of the client's personal
information.
(b) Before arranging for the provision of home care services to a
client, a home care organization shall provide a written notice to
the client stating that the client has all of the rights enumerated
in subdivision (a).
(c) A home care organization shall maintain written documentation
showing that it has complied with subdivision (a).
(d) If a client lacks the capacity to understand the rights listed
in this section, as determined by a court of competent jurisdiction
or by the client's physician, unless the physician's opinion is
controverted by the client or the client's legal representative, the
client's legal representative shall have those rights.
(e) A home care organization shall protect, and promote the
exercise of, the rights listed in this section.
Article 6. Home Care Aides
1796.60. (a) Beginning January 1, 2012, the department shall
require any person hired as a long-term care worker for the elderly
or persons with disabilities to be certified as a home care aide
within 180 days from the date of being hired.
(b) In order to receive a certificate from the department to
provide home care services for the elderly or persons with
disabilities, a home care aide shall meet the minimum training
requirements in this section. Only training curriculum approved by
the department may be used to fulfill the training requirements
specified in this section.
(c) A prospective home care aide shall complete a minimum of five
hours of entry-level training, as follows:
(1) Two hours of orientation training regarding his or her role as
caregiver and the applicable terms of employment.
(2) Three hours of safety training, including basic safety
precautions, emergency procedures, and infection control.
(3) Other training related to core competencies and
population-specific competencies as required by regulation.
(d) The department shall only approve a training curriculum that
satisfies both of the following conditions:
(1) The training curriculum has been developed with input from
consumer and worker representatives.
(2) The training curriculum requires comprehensive instruction by
qualified instructors on the competencies and training topics
identified in this section.
(e) The department shall issue a home care aide certificate to
each individual who meets the requirements of this section.
(f) The department shall maintain on its Internet Web site a list
of, and contact information for, each holder of a home care aide
certificate in good standing.
(g) The department shall set a fee for certification under this
section that shall be paid for by the employer.
(h) An individual who wishes, independent of an employer-employee
relationship, to obtain a certificate to provide home care aide
services, shall pay for his or her own certification.
1796.61. (a) On and after January 1, 2012, a home care
organization shall not hire an individual as a home care aide unless
the individual complies with all of the following requirements:
(1) Completes an individual interview, to the satisfaction of the
organization.
(2) Provides at least two work- or school-related references or,
for an individual with no previous work experience, at least two
character references from nonrelatives. The organization shall verify
the references before hiring the individual.
(3) Demonstrates that he or she possesses sufficient language
skills to read and understand instructions, prepare and maintain
written reports and records, and communicate with a client.
(b) A home care organization that hires an individual pursuant to
subdivision (a) shall ensure that the individual, within the first 18
days of employment, satisfactorily completes the home care
certification training in Section 1796.60.
1796.62. (a) A home care organization shall conduct and pay for a
background clearance on an individual hired as a home care aide,
unless the individual holds a valid, unexpired license or
registration in a health-related field that requires a background
check as a condition of the license or registration.
(b) The background clearance shall consist of a livescan criminal
history record check conducted by the Department of Justice.
(c) If the background check required by subdivision (b) discloses
a conviction or incarceration for a conviction of any of the
following provisions of the Penal Code within 10 years, the
organization shall deny or terminate, as applicable, the employment
of that individual:
(1) Fraud against a government health care or supportive services
program, including Medicare, Medicaid, or services provided under
Title V, Title XX, or Title XXI of the federal Social Security Act,
or a violation of subdivision (a) of Section 273a of the Penal Code,
or Section 368 of the Penal Code, or similar violations in another
jurisdiction.
(2) A violent or serious felony, as specified in subdivision (c)
of Section 667.5 of the Penal Code and subdivision (c) of Section
1192.7 of the Penal Code.
(3) A felony offense for which a person is required to register
under subdivision (c) of Section 290 of the Penal Code. For purposes
of this subparagraph, the 10-year time period specified in this
section shall commence with the date of conviction for, or
incarceration following a conviction for, the underlying offense, and
not the date of registration.
(4) A felony offense described in paragraph (2) of subdivision (c)
or paragraph (2) of subdivision (g) of Section 10980.
(d) Notwithstanding subdivision (c), a certification shall not be
denied under this section if the applicant has obtained a certificate
of rehabilitation under Chapter 3.5 (commencing with Section
4852.01) of Title 6 of Part 3 of the Penal Code or the information or
accusation against him or her has been dismissed pursuant to Section
1203.4 of the Penal Code.
(e) The organization shall complete and pay for the background
clearance specified in subdivision (b) on home care aides whose
employment began before January 1, 2012, within 180 days of the
effective date of this section.
(f) A home care aide hired on or after January 1, 2012, shall not
be permitted to provide home care services until he or she passes the
background clearance pursuant to this section.
1796.63. (a) An individual hired as a home care aide on or after
January 1, 2012, shall be terminated from employment unless the
individual submitted to an examination within six months prior to
employment or submits to an examination within 14 days after
employment to determine that the individual is free of active
tuberculosis. For purposes of this section, "examination" consists of
a tuberculin skin test and, if that test is positive, an X-ray of
the lungs.
(b) A health care aide whose employment with a home care
organization began before January 1, 2012, within 14 days of the
effective date of this section, shall submit to the examination
described in subdivision (a).
(c) After submitting to an examination, a home care aide whose
tuberculin skin test is negative shall be required to undergo an
examination at least once every two years. Once a home care aide has
a documented positive skin test that has been followed by an X-ray,
the examination is no longer required.
(d) After the examination, a home care aide shall submit, and the
organization shall keep on file, a certificate from the examining
practitioner showing that the home care aide was examined and found
free from active tuberculosis.
(e) The examination is a condition of initial and continuing
employment with the home care organization. The home care aide shall
pay the cost of the examination.
(f) A home care aide who transfers employment from one
organization to another shall be deemed to meet the requirements of
subdivision (a) or (b) if that individual can produce a certificate
showing that he or she submitted to the examination within the past
two years and was found to be free of communicable tuberculosis, or
if it is verified by the organization previously employing him or her
that it has a certificate on file which contains that showing.
(g) Notwithstanding the results of an examination, a home care
aide shall annually complete a tuberculosis survey that includes, but
is not limited to, all of the following information:
(1) The individual's name, address, and telephone number.
(2) The date and result of all previous tuberculin skin tests and,
where applicable, all X-ray examinations.
(3) Answers to questions concerning whether the individual has
recently experienced any of the following symptoms:
(A) A chronic cough for a period exceeding two weeks.
(B) Chronic fatigue or listlessness for a period exceeding two
weeks.
(C) Fever for a period exceeding one week.
(D) Night sweats.
(E) Unexplained weight loss of eight pounds or more.
Article 7. Revenues
1796.70. (a) There is in the State Treasury the Home Care
Organization and Home Care Aide Certification Fund. Notwithstanding
Section 13340 of the Government Code, and except as provided in
subdivision (b), all money in the fund is continuously appropriated
to the department for the purpose of carrying out and enforcing this
chapter.
(b) Fines and penalties collected pursuant to this chapter shall
be deposited into a separable penalty account in the fund and shall
be expended, upon appropriation by the Legislature, for the purpose
of carrying out and enforcing this chapter.
1796.71. (a) The department shall assess licensure, renewal,
background check, and other fees for each location of a home care
organization in
amounts sufficient to cover the costs of administering this chapter.
The department shall also assess from the employer of each home care
aid a fee in an amount sufficient to pay the cost of providing
certification of home care aides.
(b) The department may periodically adjust these fees for
inflation. The fees collected pursuant to this chapter shall be
deposited in the fund.
Article 8. Enforcement and Penalties
1796.80. (a) A home care organization operating in violation of
this chapter or any rule adopted hereunder may be subject to the
penalties or fines levied or licensure action taken by the department
as specified in this section.
(b) When the department determines that a home care organization
is in violation of this chapter or any rules promulgated hereunder, a
notice of violation shall be served upon the licensee. Each notice
of violation shall be prepared in writing and shall specify the
nature of the violation and the statutory provision or rule alleged
to have been violated. The notice shall inform the licensee of any
action the department may take under this chapter, including the
requirement of an agency plan of correction, assessment of a penalty,
or action to suspend, revoke, or deny renewal of the license. The
director or his or her designee shall also inform the licensee of
rights to a hearing under this chapter.
(c) The department may impose a fine of up to nine hundred dollars
($900) per violation per day commencing on the date the violation
was identified and ending on the date each violation is corrected, or
action is taken to suspend, revoke, or deny renewal of the license,
whichever comes first.
(d) In determining the penalty or licensure action, the director
shall consider all of the following factors:
(1) The gravity of the violation, including the probability that
death or serious physical or mental harm to a client will result or
has resulted, the severity of the actual or potential harm, and the
extent to which the provisions of the applicable statutes or
regulations were violated.
(2) The reasonable diligence exercised by the licensee and efforts
to correct violations.
(3) Any previous violation committed by the licensee.
(4) The financial benefit to the home care organization of
committing or continuing the violation.
(e) The department shall adopt regulations establishing procedures
for notices, correction plans, appeals, and hearings. In developing
the procedures, the department shall convene and consult with a
working group of affected stakeholders.
