CALA News & Views | Issue 57 | Impact

Advocacy in Action: Driving Clarity, Consistency and Common-Sense Regulation

A key part of CALA’s advocacy extends beyond legislation and into the day-to-day regulatory issues that directly impact providers’ ability to serve residents. Through ongoing engagement with DSS and other state agencies, CALA continues to push for clear, consistent and practical regulatory policies that reflect the realities of operating senior living communities. This year, CALA secured important clarifications, advanced long-needed regulatory updates and successfully advocated for changes that reduce confusion, improve consistency in enforcement and support fair accountability for providers and administrators. The following updates highlight how CALA’s advocacy is helping shape a more workable regulatory environment for RCFEs across California. Administrator Accountability CALA raised concerns with DSS leadership about whether RCFE administrators were being held responsible for employee misconduct under a “respondeat superior” or “captain of the ship” standard, based on recent administrator revocation cases. In response to CALA’s advocacy, DSS formally stated that it is not applying that standard in administrator revocation actions and instead evaluates each case on its individual facts and circumstances. While CALA remains concerned about how some recent cases have been handled, securing this clarification establishes an important benchmark for accountability and consistency moving forward. CALA will continue to monitor this issue and advocate for fair treatment of administrators. Modernizing Medication Disposal Requirements At CALA’s urging, DSS agreed to take a phased approach to updating Title 22 § 87465 Incidental Medical and Dental Care Services and begin with long-overdue changes to medication disposal requirements. Current regulations requiring an administrator and a second adult that is not a resident to witness on-site medication destruction are outdated and can conflict with other state and federal laws. To support regulatory modernization, CALA engaged DSS, the Department of Toxic Substances Control (DTSC) and the California Department of Public Health (CDPH) to clarify how medication disposal requirements apply in RCFEs. DTSC regulates RCRA

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