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1000.02164 – Other

Applying the test articulated in International Assn. of Fire Fighters, Local 188, AFL-CIO v. Public Employment Relations Bd. (2011) 51 Cal.4th 259, 272-273, PERB determined that the County had a decision bargaining obligation with respect to medical practice privileges. First, from the perspective of reasonable employees, changes that make it more difficult to earn and maintain practice privileges have a significant and adverse impact, potentially even causing them to lose their employment altogether. And the County does not have a need for unencumbered decision-making that outweighs the benefit to employer-employee relations of bargaining, as patient safety would not be at risk if the County had to bargain before its Board of Supervisors voted on bylaws that changed practice privilege standards. Moreover, qualifications for practice privileges fall within the ambit of a traditionally bargainable subject, because they focus on an employment-related issue and primarily operated on County employees. (pp. 17-18 & fn. 8.)