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SPONSOR: |
Papen |
DATE TYPED: |
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HB |
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SHORT TITLE: |
Personal Care Attendant Vicarious Liability |
SB |
823 |
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ANALYST: |
Geisler |
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APPROPRIATION
Appropriation
Contained |
Estimated
Additional Impact |
Recurring or
Non-Rec |
Fund Affected |
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FY03 |
FY04 |
FY03 |
FY04 |
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NFI |
NFI |
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(Parenthesis
( ) Indicate Expenditure Decreases)
Responses
Received From
Department
of Health (DOH)
State
Agency on Aging (SAOA)
Human
Services Department (HSD)
Governor’s
Committee on Concerns of the Handicapped (GCCH)
Attorney
General (AG)
SUMMARY
Synopsis
of Bill
Senate
Bill 823 would enact a new section of the Public Assistance Act to exempt
health care providers who function as fiscal intermediaries from vicarious
liability as an employer or principal for a wrongful act committed by a
personal care attendant if the attendant: 1) is not a current or former
employee of the fiscal intermediary; 2) has not received training or
instruction from the fiscal intermediary regarding the provision of personal
care services to a person with a disability (not including administrative
work); 3) has been hired by and received training from the consumer or his
authorized representative; and 4) provides basic assistance with activities of
daily living that do not require the education, training, or a certification of
a licensed health care practitioner.
SB
823 would require that a fiscal intermediary identify a personal care attendant
as a covered employee with the fiscal intermediary’s workers’ compensation
carrier solely to provide workers’ compensation coverage in the event of a
work-related injury. SB 823 would not
create an employer-employee relationship between the fiscal intermediary and
the personal care attendant. SB 823
would not hold the fiscal intermediary immune from a claim for a wrongful act
committed by the fiscal intermediary or its employees. SB 823 has the support of DOH, HSD, SAOA, and
GCCH. The AG has concerns about the
workers compensation provision of this bill.
See discussion below under the conflict section.
Significant
Issues
Following the ruling
of the U.S. Supreme Court in Olmstead v. L.C. ex rel. Zimring, 119 S.Ct.
2176 (1999), New Mexico and almost all other states have developed plans to
increase the availability of community-based services to persons with
disabilities (hereafter “Consumers”). In
2002, the
Under
consumer-directed personal care plans, persons with disabilities (or their
authorized representative) hire, train, and supervise persons to assist with
simple activities of daily living such as bathing, dressing, eating, and
shopping. The fiscal intermediary performs administrative tasks for the
consumer such as processing payment for service to the personal care attendant.
This bill proposes to further the policy of
expanding the availability of consumer directed personal care in two ways. First, it seeks to encourage home care
providers and others to serve as fiscal intermediaries by removing the threat
of vicarious liability for the actions of attendants that are hired, trained,
and supervised by consumers. Second, the
bill seeks to make workers’ compensation coverage for attendants more available
by permitting fiscal intermediaries to describe attendants as covered employees
under their workers’ compensations policy without creating an employer-employee
relationship.
FISCAL IMPLICATIONS
The
GCCH provided that the Medicaid Personal Care Option program (PCO) should be
able to significantly serve more people due to the lower per-individual average
cost of service delivery. Currently, the
PCO serves over 6,000 with in-home services.
It would also allow people living in nursing homes or institutions, who
are Medicaid eligible for PCO, to choose to live in the community, with a
potential reduction in long-term services cost.
Nursing homes, on average, cost about $40,000 per person as opposed to
the $27,000 per person average cost of the PCO, which again would allow the
State to serve more people with the same amount of dollars.
CONFLICT
The AG provides that the provisions of
subsection 1B (page 2, lines 12-18) of the bill conflict with the Workers’
Compensation Act. Employers who employ
less than three employees, or employ only domestic servants are exempted from
the requirements of the Workers’ Compensation Act. Section 56-1-6A NMSA 1978 (Repl. Pamp.
1991). Accordingly, under current law
consumers who employ personal care attendants as part of consumer-directed
personal care programs are not required to provide workers’ compensation
coverage for a personal care attendant they employ. The consumer may elect to provide coverage
under Section 56-1-6B of the Act, but as a practical matter, workers’
compensation policies for a single employee under such circumstances are
difficult to find and very expensive.
As noted above, subsection 1B of this bill
provides that a fiscal intermediary may list personal care attendants employed
by a consumer as a “covered employee” under the fiscal intermediary’s workers’
compensation policy without creating an employment relationship. This language creates a contradiction,
however, because a person cannot be a“covered employee” under an employer’s
worker’s compensation policy unless there is an employment relationship between
the two. Workers’ compensation coverage
is predicated on the existence of an employer/employee relationship. Perea v.
The Act creates a set of rules that govern
claims by the employee against his or her employee that arise out of an injury
sustained in the course and scope of the employment. See sections 52-1-2, -6C, -9 NMSA
1978. By its own terms, subsection 1B of
the bill appears to refer to circumstances in which the employer/employee
relationship does not exist, but one party seeks workers’ compensation insurance
coverage for the other. Neither the act nor cases interpreting the Act
recognize the “quasi-employer” /
“quasi-employee” relationship contemplated by this subsection of the bill. Even if the Act were expressly amended to
authorize this type of coverage, the absence of an actual employer/employee
relationship in fact raises questions as to whether there is a legitimate
insurable risk that can be covered by a
Per the AG, in light
of the apparent conflicts with the Worker’s Compensation Act, it may be
simplest to amend the bill to delete the workers’ compensations coverage issue
in subsection 1B. Another option could
be to amend the Workers’ Compensation Act to authorize the coverage included in
this bill.
GG/njw