Adult day programs: administration of intranasal emergency antiseizure medications.

The bill was assigned Chapter 448 and the Governor's approval date of October 7, 2025 was inserted in place of blank fields for the received-by-Governor date.

Page headers changed from 'AB 1172' to 'Ch. 448' and page numbers shifted from 93 to 92 due to reformatting for the chaptered version.

The bill text was reformatted from an official authenticated chaptered document (with page numbers and 'STATE OF CALIFORNIA AUTHENTICATED ELECTRONIC LEGAL MATERIAL' header) into a web page layout with navigation menus, version history list, and publication metadata. The actual legal content of all sections (1528 through 1528.4 and Section 2) is unchanged.

Section 1528.2(d)(1) removed the phrase 'by a regional center or a licensee' from the training provision. Previously, training had to be delivered by a regional center or a licensee; now the bill only requires that training be provided at no cost during regular working hours, without specifying the provider.

Multiple duplicated words and garbled text from prior amendments were cleaned up throughout the bill (e.g., 'omission, omissions' became 'omissions'; 'Section Sections' became 'Sections'; a duplicated sentence in Section 1528.3(d) was consolidated into a single clear reference to specific Title 22 sections).

The enrolled version removed amendment history headers, line numbers, coauthor attributions, and added standard enrolled bill formatting including passage dates (Assembly September 11, Senate September 10) and Governor approval block.

Expanded the group of people authorized to administer emergency antiseizure medication from only 'volunteers' (employees who volunteered) to include 'administrators' as well. Administrators are now defined by reference to Title 22 regulations.

Narrowed the type of medication covered from general 'inhalable emergency antiseizure medication' to specifically 'inhalable intranasal emergency antiseizure medication,' limiting the bill to intranasal delivery devices.

Extended the deadline for the State Department of Social Services to adopt minimum training standards from January 1, 2027 to January 1, 2028, giving regulators an additional year.

Added a new requirement that licensees must maintain with each client's seizure action plan a description of how they will coordinate care for the client when no administrator or authorized volunteer is available to administer the medication.

Changed the seizure action plan requirement from the facility developing the plan to the licensee being 'in receipt of' a plan that was developed by the client or their authorized representative in consultation with a health care provider. This shifts the primary responsibility for plan creation away from the facility.

Changed record retention obligations to apply to both 'licensees and regional centers' (previously only licensed facilities), and changed the storage requirement from compliance with a specific regulation section to keeping materials 'in a readily available manner in a central administrative location.'

Added new definitions for 'Administrator,' 'Authorized representative,' and 'Health Care Provider.' Restructured the 'Licensed facility' definition to also include the term 'licensee' as an alternative. Changed references from 'individual' to 'client' throughout to align with Title 22 regulatory language.

Training must now be provided by 'a regional center or a licensee' at no cost to the administrator or volunteer, adding regional centers as a new source of training and clarifying who bears the cost.

Expanded immunity protections so that a person complying with the article is also protected from liability for 'the actions or omissions of a volunteer,' not just their own actions. This broadens the shield against civil liability and professional review.

The facility no longer must 'designate' specific volunteers for training before authorizing them. The bill now simply requires the facility to 'authorize any volunteer' (as defined) to administer medication upon request, removing a separate designation step and simplifying the process.

The seizure action plan previously required two separate written authorizations: one for the medication to be administered and another verifying a nonmedical professional may respond to seizures. These are now consolidated into a single authorization that covers both purposes.

Post-seizure care protocols in the seizure action plan must now include BOTH rest/return-to-activity instructions AND direct observation time requirements, rather than just one of the two as before.

The definition of 'volunteer' changed from someone who 'has been designated by the facility' to someone who 'has been authorized by the facility,' aligning with the removal of the separate designation requirement.

The criminal liability exception was narrowed. The old version stated immunity does not apply to crimes 'not specifically authorized by this article,' implying acts authorized by the bill could be shielded from criminal charges. The new version removes that carve-out, stating clearly that the protection does not affect culpability for any act constituting a crime.

The language confirming that a paid employee volunteering to administer medication is not deemed to be providing care 'for compensation' was strengthened from 'is not deemed' to 'shall not be deemed,' making it a mandatory rule rather than a declarative statement.

Removed the 'developmentally disabled' limitation throughout the bill. The law now applies to any individual diagnosed with seizures, a seizure disorder, or epilepsy who has been prescribed inhalable emergency antiseizure medication, not just those with developmental disabilities.

The definition of 'licensed facility' no longer requires the facility to serve adults with developmental disabilities. It now simply means an adult day program or adult residential facility as defined in Section 1502.

Changed terminology from 'designate' to 'authorize' for volunteers throughout the bill, including in the volunteer definition and facility obligations.

Added a new requirement (Section 1528.1(d)) that licensed facilities must adopt policies to implement the article, ensuring that any administration of medication complies with the conditions in the individual's seizure action plan.

The written authorization in the seizure action plan now must be signed by the individual or their authorized representative and must specifically verify that a seizure may be responded to at the facility by a nonmedical professional who has received training under Section 1528.2, including through administration of emergency antiseizure medication.

The post-seizure protocol in the seizure action plan was expanded from 'a protocol for observing the individual after a seizure' to 'protocols for observing and caring for the individual after a seizure, and after the administration of inhalable emergency antiseizure medication.' The requirement changed from 'either of the following' to 'both of the following,' making both rest/return instructions and observation time mandatory.

The notice provided to volunteers must now include an explanation of the liability protections and indemnification requirements described in Section 1528.4, in addition to informing them of their right to rescind without penalty or retaliation.

Liability protections were expanded to cover not just volunteers who administer medication, but also any person who provides training to a volunteer and any person who otherwise complies with the article's requirements, in good faith and not for compensation.

Added a new exception (paragraph D) clarifying that Section 1799.102 (the Good Samaritan statute) still applies to any person who renders medical or nonmedical care at the scene of an emergency in good faith and not for compensation, regardless of training and licensure.

Changed the compensation clarification from 'is not providing inhalable emergency medical care for compensation' to 'shall not be deemed to be providing inhalable emergency medical care for compensation,' making the legal determination more explicit.

Changed 'shall align with' to 'may align with' regarding alignment of training standards with Education Code requirements, making alignment optional rather than mandatory.

Added a record retention requirement that written training materials be retained 'in a manner consistent with state law, including Section 56730 of Title 17 of the California Code of Regulations.'

The bill's scope was expanded from applying only to developmentally disabled individuals to any individual diagnosed with seizures, a seizure disorder, or epilepsy who has been prescribed inhalable emergency antiseizure medication. The definition of 'seizure action plan' and the operative language in Section 1528.1 were changed from 'developmentally disabled individual' to simply 'individual.'

The person who can request that a facility designate volunteers was expanded. Previously only 'the authorized representative of a developmentally disabled individual' could make the request; now 'an individual, or the authorized representative of a developmentally disabled individual an individual' can make the request, allowing the person themselves to initiate the process.

A deadline of January 1, 2027 was added for the State Department of Social Services to adopt minimum training standards for recognizing and responding to seizures.

The department is now required to consult with organizations and providers with expertise in epilepsy, administering emergency anti-seizure medication, and administering medication in a school environment, specifically naming the Epilepsy Foundation, Epilepsy Foundations in California, and the California Medical Association.

The training standards alignment requirement was softened from 'shall align' to 'may align' with Education Code requirements, with the added qualifier 'when appropriate to the setting, age, and ability of residents and participants described in this article.'

A new subdivision was added specifying that training standards must include: recognition of seizure signs and symptoms and response steps; administering or assisting with self-administration of inhalable emergency antiseizure medication; basic emergency follow-up procedures; and written materials covering the required information.

The seizure action plan must now be 'approved by the individual or the individual's authorized representative,' adding an explicit approval step that was not in the introduced version.

A new item (4) was added to the seizure action plan requirements: a signed authorization by the individual or their authorized representative verifying that a seizure may be responded to by a nonmedical professional who has received training, including administration of emergency antiseizure medication prescribed to the individual.

When no volunteers are available at the facility, the notification requirement was expanded from notifying only 'the requesting individual's regional center service coordinator' to notifying 'the requesting individual, the individual's authorized representative, or their regional center service coordinator.'