At the June 21, 2015 meeting, the Commission approved amendments to Commission Regulations 1001, 1014, 1015, and Section E in the POST Administrative Manual (PAM) that pertained to reimbursements.  These amendments clarified the language and brought these regulations into alignment with current practices and were submitted to the Office of Administrative Law (OAL) for the rulemaking review process on September 29, 2015.  During this review, OAL found some of the language required more clarity.

Commission Regulation 1014 addresses reimbursement for training attended by non-sworn personnel of POST-participating agencies and Commission Regulation 1015 addresses reimbursement for training attended by peace officers and public safety dispatchers of POST-participating agencies and POST-approved Training Presenters. 

The majority of the changes were to clarify and simplify language, and to incorporate the procedures in Section E into regulations to improve accessibility of information related to reimbursements.

Commission Regulation 1001 was amended to change the reference to Section E to Regulations 1014 and 1015, where the information was relocated.

A substantive change was to add the language clarifying the reimbursement for the Regular Basic Course – Modular Format (Intensive).

At the October 2014 Commission meeting, staff informed the Commission of a pilot program to reimburse for agency-sponsored attendees in the Regular Basic Course – Modular Format (Intensive).  Commission Regulation 1015 had authorized reimbursement for agency-sponsored students attending a Regular Basic Course, without specifying between the Regular Basic Course Standard Format, and the Regular Basic Course – Modular Format. POST's internal policy had been to deny reimbursement for attendance at the Regular Basic Course, Modular Format.  The new internal policy was not supported by Commission Regulations.  Business rules were added to the POST Electronic Data Interchange (EDI) to facilitate reimbursement pursuant to the pilot program.

The Commission was advised that the addition of reimbursement for agency-sponsored attendees at the Regular Basic Course – Modular Format (Intensive) would have minimal financial impact.  The Commission supported amending Commission  Regulations as needed to address the addition of reimbursement for attendance at the Regular Basic Course – Modular Format (Intensive).  The changes proposed to Regulation 1015 in the agenda item from the June 21, 2015 meeting, reflected this amendment. 

Reimbursement requests are submitted to POST by agencies participating in the POST Reimbursable Program through utilization of a Training Reimbursement Request (TRR) form POST 2-273 (Rev 04/2015) and by POST-approved training presenters through utilization of a Presenter Reimbursement Request (PRR) form POST 2-243.  Both forms were revised to be consistent with the amendments to the regulations and to improve functionality.

The original changes to Commission Regulations 1001, 1014, and 1015, as well as incorporating Section E of the POST Administrative Manual and modifying pertinent POST forms related to reimbursement for training costs (Attachments A through C) were approved by the Commission at the June 21, 2015 meeting.

The definition of "Reimbursement Plans" was changed in Regulation 1001 to reflect reference to Regulation 1015(c)(2), as opposed to Section E.

The original approved amendments to Regulation 1014: Reimbursement for Training of Non-Sworn Personnel clarified language.  Additional amendments to Regulation 1014 section (a)(8) require clarity and a revision to the effective date of the incorporation of PAM Section E into regulation due to the new approval date.

The original approved amendments to Regulation 1015 Reimbursement for Training included the following:

• Authorizes reimbursement for partial completion of the Regular Basic Course, Motorcycle Training Courses, and Instructor Training Courses.  However, actual practice and the EDI does not permit reimbursement for partial completion of instructor training courses.  Allowance for partial completion of Instructor Training Courses was deleted from regulation to adhere to actual practice.
• Deletes reference to a Drug Asset Forfeiture Account that directed drug and asset forfeiture funds to be provided to POST through the Peace Officers' Training Fund.   Previous legislation removed POST as a recipient of those funds.
• Revises language to distinguish between reimbursement to agencies participating in the POST Program and POST-approved Training Course Presenters, who are reimbursed pursuant to Plan V certification as approved by the Commission in June 2013.
• Adds reimbursement for attendance at the Regular Basic Course – Modular Format (Intensive) by agency-sponsored attendees.

The additional amendments, required by the Office of Administrative Law, to Regulation 1015 require the maximum reimbursement rates showing dollar amounts for each expense category and the adoption and amended dates for PAM Section D-2.

The original date for the TRR form POST 2-273 requires an earlier adoption date.

It was found that the PRR form 2-243 had never been submitted for OAL approval and therefore is a new form which requires Commission approval.  The original text must be revised throughout the regulations to reflect the correct date of the PRR form 2-243.

The additional amendments were reviewed by Administrative Services Bureau.

This program is supported by Strategic Plan Objective B.1, POST regulations are relevant, comprehensible, and consistently applied.