In total these will deter local governments from submitting test claims and add additional costs to the process.
Local governments in recent years have faced a series of mandate deferrals, suspensions, and modifications at the state level. In concert with this trend, the commission is proposing new regulations
which will create even more barriers for local agencies seeking to obtain reimbursement for mandated services.
Notably, the proposed regulations amend the filing period requirements for reimbursement claims, making the requirements much more difficult for local governments to meet. Under the proposed regulations, test claims must be filed within 365 days of incurring increased costs, regardless of where it lands in the fiscal year. Currently, the submission deadline is by June 30 of the fiscal year following the fiscal year in which increased costs were first incurred. The proposed change hinders a local government’s ability to adequately track associated costs and submit accurate claims. The League and other local government organizations are requesting that the commission retain current filing period requirements.
The proposed regulations also contain concerning modifications as they relate to the standard of evidence required for test claims as well as the joint test claim single representative requirement.
The written comments
submitted jointly by the League, CSAC and CSDA contain additional details.
The commission considered the proposed regulations at a public hearing today, July 28 at 10 a.m. (Item 6 on the hearing agenda
). Representatives from the local government coalition will be there to testify. League members will be kept apprised of updates on this matter.