SB 1368 amends California Business and Professions Code Sections 2538.33 and 2538.34 to change how hearing-aid dispensers register locations with the state and how multi-site practice is licensed. The bill replaces loose references to a 'place of business' with requirements tied to address(es), requires a branch office license when a dispenser practices at more than one location, and formalizes an exception for short-term or visiting practice.
For compliance teams and dispensers that split time across clinics, retail locations, or temporary facilities, the statute raises new registration and application steps. It also gives the Board clearer tools to track where services occur — a shift that matters for inspections, consumer complaints, and recordkeeping — while adding definitional language about what counts as 'temporary' practice.
At a Glance
What It Does
The bill requires dispensers to notify the Speech-Language Pathology and Audiology and Hearing Aid Dispensers Board in writing of the street address or addresses where they will practice, and to register mailing addresses if different. It replaces the previous 'duplicate license' approach with an explicit branch office license requirement for practice at multiple locations, and it keeps a narrowly drawn temporary-practice exception that requires advance written notice to the Board.
Who It Affects
Individual hearing-aid dispensers who work at more than one physical location, clinics and retail outlets that host visiting dispensers, and the Board that licenses and inspects dispensers. Compliance officers at multi-location providers and small itinerant practitioners will be the most directly affected.
Why It Matters
The measure tightens location-level oversight and recordkeeping, reducing ambiguity about where licensed services are delivered. That matters for consumer protection, complaint handling, and enforcement — but it also creates additional procedural and potentially financial burdens for multi-site and mobile providers.
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What This Bill Actually Does
SB 1368 rewrites how hearing-aid dispensers disclose where they practice. Instead of focusing on a generic 'place of business,' the bill requires written notification to the Board of the specific street address or addresses where a dispenser will fit or sell hearing aids, and a separate mailing address when mail goes to a different location.
That notification must occur before the dispenser engages in practice at those addresses, and changes must be reported within a short window tied to the start of practice.
Where a dispenser operates at more than one location inside California, the bill mandates a branch office license for each additional address. The application for a branch office license must identify the person and list the location address for the branch.
This removes the older terminology of a 'duplicate license' and replaces it with a dedicated branch-office licensing regime, which will require dispensers and their employers to add licensing steps when opening new sites or deploying staff across multiple storefronts or clinics.The bill preserves a practical exception: a dispenser may work at another licensee's primary or branch location, or at another temporary facility, without obtaining a branch license so long as they provide the Board advance written notice of the dates and addresses where they will practice. SB 1368 defines 'temporary basis' as a limited and short period not intended to occur repeatedly — language that aims to differentiate one-off or emergency coverage from recurring multi-site practice.
In short, frequent multi-site work triggers branch licensing; genuinely sporadic visiting shifts do not, provided they are notified in advance.
The Five Things You Need to Know
Section 2538.33 requires dispensers to notify the Board in writing of the street address or addresses where they will engage in practice before they start at those locations.
If a dispenser’s mailing address differs from the registered street address, the bill requires the dispenser to submit that mailing address in writing as well.
Section 2538.34 requires a branch office license when a hearing-aid dispenser practices at more than one place of business within California, and the branch application must state the person’s name and the branch location address.
The statute replaces language authorizing a 'duplicate license' with a precise branch-office licensing scheme, changing the administrative label and the application requirement.
The bill preserves a temporary-practice exception but requires advance written notice to the Board of the dates and addresses where the visiting dispenser will work, and defines 'temporary basis' as a short, limited period not intended to occur repeatedly.
Section-by-Section Breakdown
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Address notification and mailing-address reporting
This section requires each hearing-aid dispenser to give the Board written notice of the street address or addresses where they will fit or sell hearing aids and to report any changes within the statutory window tied to commencing practice. If the street address is not where the licensee receives mail, the dispenser must also provide a mailing address for each registered location. Practically, this raises recordkeeping needs: dispensers must track and timely report multiple physical and mailing addresses, and the Board will receive location-level contact points for enforcement and consumer outreach.
Established retail address and branch-office licensure for multi-site practice
Subdivision (a) keeps the requirement that a dispenser maintain an established retail address that is routinely open to customers and ties that address to the registration requirement under Section 2538.33. Subdivision (b) now requires a branch office license when a dispenser practices at more than one location. The branch-license application must list the person's name and each branch location address, which formalizes a multi-site licensing pathway and replaces the older 'duplicate license' concept. For compliance teams, the consequence is procedural: opening or staffing a new physical site will typically trigger a license application and associated administrative steps.
Temporary-practice exception with advance notice
The bill preserves an exception allowing a dispenser to practice temporarily at another licensee’s primary or branch location, or at a temporary facility, without securing a branch license. That exception is conditional: the dispenser must notify the Board in advance in writing of the dates and addresses where they will practice. The statute defines 'temporary basis' as a short, limited period not intended to occur repeatedly, creating a bright-line aim but leaving room for factual disputes about whether repeated or routine coverage falls outside the exception.
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Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Consumers and patients — They gain clearer, address-level registration for where licensed services occur, which can improve complaint routing, inspection targeting, and the ability to confirm a dispenser’s authorized practice locations.
- The Speech-Language Pathology and Audiology and Hearing Aid Dispensers Board — The Board gets more precise location data and an explicit branch-licensing pathway, which helps inspections, complaint investigations, and enforcement.
- Clinics and retailers that host visiting dispensers — The temporary-practice exception with an advance-notice requirement reduces uncertainty for hosts about whether a visiting clinician can operate without a branch license, streamlining occasional coverage arrangements.
- Compliance officers at multi-site providers — The statute’s branch-license process clarifies the administrative steps required when adding sites, allowing compliance teams to plan licensure workflows rather than manage ad-hoc 'duplicate license' interpretations.
Who Bears the Cost
- Individual dispensers who operate at multiple locations — They will need to apply for and maintain branch office licenses, increasing paperwork and potentially licensing costs for each additional site.
- Small and itinerant providers serving rural or underserved areas — The new branch-licensing requirement may discourage frequent short stops or create a higher administrative burden for providers who rotate among sites.
- The Board — The agency will likely face increased administrative workload to process address updates, branch-license applications, and advance-notice filings, but the bill does not specify additional staffing or fee authority.
- Host facilities and multi-service clinics — While temporary visits remain allowed, hosts may need to verify that visiting dispensers have provided the required advance notice to the Board to avoid regulatory uncertainty.
Key Issues
The Core Tension
The central dilemma is between stronger, address-level oversight that protects consumers and supports enforcement, and preserving flexibility for small, itinerant, or part-time dispensers who provide access in multiple locations; stricter licensure and reporting improves traceability but raises compliance costs and may shrink flexible service delivery models.
The bill tightens location reporting but leaves some operationally important questions open. 'Temporary basis' is defined as 'a limited and short period of time that is not intended to occur repeatedly,' which is conceptually clear but fact-sensitive: the statute does not set numeric limits (days, hours, or occurrences), so disputes about whether a provider’s pattern of visits qualifies as temporary are likely. That creates room for inconsistent enforcement and places the burden on dispensers and the Board to develop interpretive guidance.
Another implementation challenge is mobile and nontraditional practice. The text moves from the old phrase 'place of business' to 'address or addresses,' which helps pin down fixed sites but does not directly address mobile clinics, home visits, or telepractice models where a singular street address may not capture where services occur.
The statute also increases the Board’s administrative workload—processing branch-office applications, recording multiple mailing and street addresses, and logging advance-notice filings—without authorizing additional fees or resources in the text. Finally, the bill’s draft contains some inconsistent language and formatting (for example, stray words and sentence fragments) that could benefit from cleanup to avoid interpretive disputes over timing and the precise obligations to notify.
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