The 2026/2027
California RCFE
Administrator
Mastery Guide:
Executive Manifesto:
The residential care landscape in California is currently navigating a period of unprecedented
regulatory volatility and demographic pressure. As the sector approaches the 2026/2027
licensure cycle, the role of the Residential Care Facility for the Elderly (RCFE) Administrator has
fundamentally shifted. It is no longer sufficient to merely possess a certificate; the market now
demands a "Category of One" leader—an administrator who transcends basic compliance to
master the intricate interplay of clinical acuity, risk management, and legal defensibility. This
dossier serves not merely as a preparation tool for the California Department of Social Services
(CDSS) Administrator Certification Exam but as a comprehensive operational manual for
navigating the treacherous waters of Title 22 and the Health and Safety Code.
The data is unequivocal: the impending "silver tsunami" of Baby Boomers, coupled with a
tightening regulatory environment, has created a bifurcation in the industry. On one side are
commodity administrators who view regulations as a checklist; on the other are Category of One
leaders who view regulations as a risk management framework. The latter command
significantly higher compensation, with salaries in the San Francisco Bay Area exceeding
$110,000 for top-tier talent , while simultaneously insulating their facilities from the devastating
civil penalties that now reach $15,000 for resident mortality events.
This report is structured to dismantle the 2026/2027 exam content domains, dissect the newest
legislative redlines effective January 1, 2025, and provide a proprietary "Failure Hedge"
methodology to immunize candidates against the common pitfalls of the "open book"
examination format. We will explore 55 distinct clinical and operational scenarios, derived from
,actual citation data and appellate decisions, to transform theoretical knowledge into reflex
action.
Part I: The Regulatory Architecture and 2026
Legislative Redlines
To operate at a "Category of One" level, one must first understand the structural hierarchy of the
governing laws. A common point of failure for novice administrators is the conflation of statute
and regulation, or the ignorance of the Provider Information Notice (PIN) system which often
supersedes older regulatory text.
1.1 The Triangulated Hierarchy of Authority
The "Category of One" administrator understands that authority flows downward, yet operational
guidance often flows upward from PINs. In any conflict between documents, the higher authority
prevails, but the most recent guidance often dictates enforcement behavior by Licensing
Program Analysts (LPAs).
1.1.1 The Statutory Bedrock: Health and Safety Code (HSC)
The California Health and Safety Code is the supreme law enacted by the legislature. It
establishes the existence of RCFEs, the mandate for licensure, and the punitive framework for
violations.
● Scope: The HSC is broad and punitive. For example, while regulations describe how to
store medications, the HSC establishes the civil penalties for failing to do so.
● Key Distinction for 2026: The exam will often present a scenario and ask for the
"statutory" requirement versus the "regulatory" requirement. The HSC dictates the civil
penalty amounts (e.g., $15,000 for death), while Title 22 dictates the operational specifics
(e.g., 105°F-120°F water temperature).
1.1.2 The Regulatory Framework: Title 22, Division 6, Chapter 8
These are the administrative rules drafted by DSS to implement the HSC. This is the "playbook"
for daily operations.
● Navigational Strategy: Mastery of Title 22 requires understanding its Article structure.
○ Article 5 (Physical Environment): Temperature, safety, water.
○ Article 6 (Background Checks): Criminal clearances.
○ Article 7 (Personnel): Staffing ratios and training.
○ Article 8 (Assessments): Admission appraisals and resident rights.
1.1.3 The Interpretive Layer: Provider Information Notices (PINs)
PINs are the mechanism by which DSS communicates formal changes, interpretations, and
emergency waivers (e.g., wildfire protocols).
● Operational Criticality: An administrator relying solely on a printed copy of Title 22 from
2023 would be non-compliant in 2026. For instance, recent PINs have fundamentally
altered the reporting requirements for infectious diseases and emergency plan
, submissions.
● The "Pin-Point" Strategy: When citing authority in a Plan of Correction (POC),
referencing the specific PIN (e.g., PIN 25-09-ASC) demonstrates a level of sophistication
that can de-escalate interactions with LPAs.
1.2 Legislative Redlines: The 2025/2026 Updates
The 2026 exam cycle incorporates significant legislative changes that render older study
materials obsolete. The "Category of One" administrator must internalize these shifts, as they
represent the areas of highest scrutiny during inspections.
1.2.1 Dementia Care Modernization (Effective Jan 1, 2025)
Perhaps the most substantial overhaul in a decade involves the integration of dementia care
standards. Previously, dementia regulations were siloed in specific sections (formerly Section
87705-87707). The new package effective January 1, 2025, integrates these standards
throughout the general regulations to support "aging in place".
● Integrated Standards: The regulation package removes the segregation of dementia
standards. This implies that every resident appraisal must now view behavioral
expressions through a dementia-competent lens, regardless of a formal diagnosis. The
administrator can no longer claim "we are not a dementia facility" to avoid these standards
if they retain residents exhibiting cognitive decline.
● Semantic Shift - "Behavioral Expressions": The terminology has shifted from "problem
behaviors" to "behavioral expressions." This is not merely semantic; it shifts the burden of
management from the resident to the facility. The administrator must interpret the
behavior as a communication of unmet needs rather than a disciplinary issue.
● Individualized Item Access: Regulations now mandate that access to dangerous items
(cleaning solutions, sharps) be determined by individual assessment rather than a blanket
facility-wide ban. This requires a nuanced, resident-specific appraisal (LIC 602A) to
determine if a resident can safely possess these items, moving away from institutional
restrictions toward homelike environments.
1.2.2 The "Death Penalty": Civil Penalty Escalation
The financial stakes for non-compliance have escalated drastically. Under the updated penalty
schedules for 2025/2026, the cost of negligence has effectively tripled in specific categories.
Violation Type Penalty Structure (2025/2026) Context/Implication
Death of Resident $15,000 Assessed if the violation
resulted in death. This is often
applied as a strict liability
standard.
Serious Physical Harm $10,000 Assessed for violations
resulting in serious bodily injury
(e.g., fractures, burns).
Physical Abuse $1,000 - $2,500 Per incident, plus potential
criminal liability.
Repeat Violation $1,000 + $100/day Immediate assessment for
,Violation Type Penalty Structure (2025/2026) Context/Implication
repeating a citation within 12
months.
Interference $100 - $2,500 Immediate penalty for refusing
entry to LPA or Ombudsman.
Insight: The $15,000 penalty for death fundamentally changes the risk profile of hospice care in
RCFEs. Administrators must now ensure that the coordination with hospice agencies is
seamless, as any lapse in care during the dying process that contributes to a negative outcome
(e.g., unmanaged pain leading to cardiac stress) could trigger this penalty.
1.2.3 Eviction Protocols (SB 434 and Tenant Protections)
Legislation regarding evictions (specifically SB 434) has introduced complexity regarding notice
periods. The trend is toward extended notice periods based on length of residency, mirroring
standard tenant-landlord law protections.
● Residency < 1 Year: Requires a 30-day written notice.
● Residency > 1 Year: Requires a 60-day written notice (per general tenant law and
proposed RCFE updates).
● Safe Discharge Planning: A mere notice to quit is no longer sufficient. Eviction notices
must now be accompanied by a "safe discharge plan," documenting the licensee's efforts
to mitigate homelessness or transfer trauma. This plan must include a list of discharge
locations that meet the resident's needs and financial capacity.
● Rights of Return: The legislation creates stronger protections against facilities refusing
to readmit residents after temporary hospitalizations, closing the "hospital dump" loophole.
1.2.4 Emergency Preparedness (SB 582)
In response to increasing wildfire threats, SB 582 mandates tighter integration with local
emergency services.
● MHOAC Coordination: RCFEs are now encouraged (and largely expected) to provide a
copy of their emergency and disaster plan to the Medical Health Operational Area
Coordinator (MHOAC). This ensures that in a mass evacuation event, county emergency
services are aware of the facility's existence and bed count.
● Annual Review: The emergency plan is no longer a static document. It must be reviewed
and updated annually, with specific attention to lessons learned from recent disasters.
Part II: The Failure Hedge — A Proprietary Exam
Strategy
The "Failure Hedge" is a strategic protocol designed to mitigate the specific cognitive risks
associated with the California Administrator Certification Exam. The primary cause of failure is
not a lack of knowledge, but a mismanagement of the "open book" dynamic.
2.1 The Open Book Fallacy
The Trap: Candidates often believe, "The exam is open book; I can just look up the answers."
The Mathematical Reality: You have 120 minutes for 100 questions. That equates to 1.2
,minutes (72 seconds) per question. It is physically impossible to look up every answer. If you
attempt to look up more than 30% of the questions, you will run out of time.
2.2 The Tiered Knowledge Protocol
To pass, the candidate must categorize knowledge into three tiers and apply a distinct strategy
for each.
Tier 1: Instant Recall (The "No-Look" Zone) — 60% of Exam
These are facts that must be memorized cold. Attempting to look these up is a waste of
precious time.
● Temperature Ranges: Heating (68°F minimum), Cooling (78°F-85°F or 30°F below
outside), Hot Water (105°F-120°F).
● Reporting Timelines: Death (24 hours verbal / 7 days written), Epidemic (Immediate),
Fire (Immediate).
● Staffing Training: 40 hours total for staff (20 hours pre-work, 20 hours post-work).
● Food Storage: 2 days perishable, 7 days non-perishable.
● Civil Penalties: $15,000 for death, $150/day for immediate serious violations.
Tier 2: Indexed Verification (The "Check" Zone) — 20% of Exam
These are questions requiring specific numerical precision or obscure regulatory details. You
should know exactly where to find them (Article number) to confirm in under 45 seconds.
● Square Footage: 110 sq ft for single rooms, 160 sq ft for double rooms (Article 5).
● Toilet Ratios: 1 toilet per 6 residents (Article 5).
● License Expiration: 2 years (Article 2).
Tier 3: Critical Synthesis (The "Think" Zone) — 20% of Exam
These are "Best Answer" scenarios where no single regulation explicitly states the answer. You
must synthesize the intent of the law (Safety, Dignity, Independence) to select the correct course
of action.
● Strategy: Apply the "Safety First, Dignity Second, Documentation Third" filter. If a resident
is in danger, safety overrides dignity (e.g., preventing elopement). If safety is neutral,
dignity prevails (e.g., right to refuse food).
2.3 The Blackboard Interface Strategy
The exam is administered via Blackboard.
● Navigation: You cannot skip questions and return easily in all configurations. You must
answer sequentially.
● Search Function: Do not rely on Ctrl+F in a PDF if the system is locked down or if the
PDF is unsearchable. You must be adept at using the Table of Contents of your physical
Title 22 copy.
, Part III: The 7 Domains of Mastery
The 80-hour Initial Certification Training Program (ICTP) and the exam are structured around
specific domains. A "Category of One" administrator does not just pass these domains; they
operationalize them.
Domain 1: Laws, Regulations, and Administrative Requirements (20%)
● Core Concept: The license is non-transferable. It belongs to the licensee and the specific
address. Moving the facility voids the license.
● Administrator Recertification: Requires 40 hours of CE every two years. Crucially, 8
hours must be in Dementia Care and 4 hours in Laws/Regulations.
● The "Designated" Administrator: Every facility must have one designated administrator.
If that person leaves, the licensee has 30 days to hire a replacement.
Domain 2: Business Operations (15%)
● Admission Agreements: This is a contract. It must be signed prior to or at the time of
admission. It must explicitly state the basic rate, optional services, and eviction policies.
● Financial Solvency: The facility must demonstrate the ability to operate for 3 months
without revenue during the application phase.
● Resident Funds: If the facility handles resident money, a surety bond is required. Funds
must be kept separate from facility funds—commingling is a major violation punishable by
fines and potential criminal action.
Domain 3: Management and Supervision of Staff (15%)
● Training Timelines:
○ Direct Care Staff: 40 hours total. 20 hours must be completed before working
independently with residents. The remaining 20 hours must be completed within the
first 4 weeks of employment.
○ Dementia Training: 12 hours total. 6 hours before working with residents, 6 hours
within 4 weeks.
● First Aid/CPR: A strict requirement: At least one staff member with valid CPR/First Aid
certification must be on duty and on the premises at all times. If the only CPR-certified
staff member goes on a lunch break off-site, the facility is non-compliant.
Domain 4: Psychosocial Needs (10%)
● Activity Programming: Facilities of 7+ residents must have organized activity programs
posted. Facilities of 50+ residents must have a full-time, designated Activity Director with
specific qualifications.
● Religious Freedom: Residents have the right to attend religious services of their choice.
The facility must facilitate this attendance (e.g., transportation arrangement) but is not
required to pay for it.
California RCFE
Administrator
Mastery Guide:
Executive Manifesto:
The residential care landscape in California is currently navigating a period of unprecedented
regulatory volatility and demographic pressure. As the sector approaches the 2026/2027
licensure cycle, the role of the Residential Care Facility for the Elderly (RCFE) Administrator has
fundamentally shifted. It is no longer sufficient to merely possess a certificate; the market now
demands a "Category of One" leader—an administrator who transcends basic compliance to
master the intricate interplay of clinical acuity, risk management, and legal defensibility. This
dossier serves not merely as a preparation tool for the California Department of Social Services
(CDSS) Administrator Certification Exam but as a comprehensive operational manual for
navigating the treacherous waters of Title 22 and the Health and Safety Code.
The data is unequivocal: the impending "silver tsunami" of Baby Boomers, coupled with a
tightening regulatory environment, has created a bifurcation in the industry. On one side are
commodity administrators who view regulations as a checklist; on the other are Category of One
leaders who view regulations as a risk management framework. The latter command
significantly higher compensation, with salaries in the San Francisco Bay Area exceeding
$110,000 for top-tier talent , while simultaneously insulating their facilities from the devastating
civil penalties that now reach $15,000 for resident mortality events.
This report is structured to dismantle the 2026/2027 exam content domains, dissect the newest
legislative redlines effective January 1, 2025, and provide a proprietary "Failure Hedge"
methodology to immunize candidates against the common pitfalls of the "open book"
examination format. We will explore 55 distinct clinical and operational scenarios, derived from
,actual citation data and appellate decisions, to transform theoretical knowledge into reflex
action.
Part I: The Regulatory Architecture and 2026
Legislative Redlines
To operate at a "Category of One" level, one must first understand the structural hierarchy of the
governing laws. A common point of failure for novice administrators is the conflation of statute
and regulation, or the ignorance of the Provider Information Notice (PIN) system which often
supersedes older regulatory text.
1.1 The Triangulated Hierarchy of Authority
The "Category of One" administrator understands that authority flows downward, yet operational
guidance often flows upward from PINs. In any conflict between documents, the higher authority
prevails, but the most recent guidance often dictates enforcement behavior by Licensing
Program Analysts (LPAs).
1.1.1 The Statutory Bedrock: Health and Safety Code (HSC)
The California Health and Safety Code is the supreme law enacted by the legislature. It
establishes the existence of RCFEs, the mandate for licensure, and the punitive framework for
violations.
● Scope: The HSC is broad and punitive. For example, while regulations describe how to
store medications, the HSC establishes the civil penalties for failing to do so.
● Key Distinction for 2026: The exam will often present a scenario and ask for the
"statutory" requirement versus the "regulatory" requirement. The HSC dictates the civil
penalty amounts (e.g., $15,000 for death), while Title 22 dictates the operational specifics
(e.g., 105°F-120°F water temperature).
1.1.2 The Regulatory Framework: Title 22, Division 6, Chapter 8
These are the administrative rules drafted by DSS to implement the HSC. This is the "playbook"
for daily operations.
● Navigational Strategy: Mastery of Title 22 requires understanding its Article structure.
○ Article 5 (Physical Environment): Temperature, safety, water.
○ Article 6 (Background Checks): Criminal clearances.
○ Article 7 (Personnel): Staffing ratios and training.
○ Article 8 (Assessments): Admission appraisals and resident rights.
1.1.3 The Interpretive Layer: Provider Information Notices (PINs)
PINs are the mechanism by which DSS communicates formal changes, interpretations, and
emergency waivers (e.g., wildfire protocols).
● Operational Criticality: An administrator relying solely on a printed copy of Title 22 from
2023 would be non-compliant in 2026. For instance, recent PINs have fundamentally
altered the reporting requirements for infectious diseases and emergency plan
, submissions.
● The "Pin-Point" Strategy: When citing authority in a Plan of Correction (POC),
referencing the specific PIN (e.g., PIN 25-09-ASC) demonstrates a level of sophistication
that can de-escalate interactions with LPAs.
1.2 Legislative Redlines: The 2025/2026 Updates
The 2026 exam cycle incorporates significant legislative changes that render older study
materials obsolete. The "Category of One" administrator must internalize these shifts, as they
represent the areas of highest scrutiny during inspections.
1.2.1 Dementia Care Modernization (Effective Jan 1, 2025)
Perhaps the most substantial overhaul in a decade involves the integration of dementia care
standards. Previously, dementia regulations were siloed in specific sections (formerly Section
87705-87707). The new package effective January 1, 2025, integrates these standards
throughout the general regulations to support "aging in place".
● Integrated Standards: The regulation package removes the segregation of dementia
standards. This implies that every resident appraisal must now view behavioral
expressions through a dementia-competent lens, regardless of a formal diagnosis. The
administrator can no longer claim "we are not a dementia facility" to avoid these standards
if they retain residents exhibiting cognitive decline.
● Semantic Shift - "Behavioral Expressions": The terminology has shifted from "problem
behaviors" to "behavioral expressions." This is not merely semantic; it shifts the burden of
management from the resident to the facility. The administrator must interpret the
behavior as a communication of unmet needs rather than a disciplinary issue.
● Individualized Item Access: Regulations now mandate that access to dangerous items
(cleaning solutions, sharps) be determined by individual assessment rather than a blanket
facility-wide ban. This requires a nuanced, resident-specific appraisal (LIC 602A) to
determine if a resident can safely possess these items, moving away from institutional
restrictions toward homelike environments.
1.2.2 The "Death Penalty": Civil Penalty Escalation
The financial stakes for non-compliance have escalated drastically. Under the updated penalty
schedules for 2025/2026, the cost of negligence has effectively tripled in specific categories.
Violation Type Penalty Structure (2025/2026) Context/Implication
Death of Resident $15,000 Assessed if the violation
resulted in death. This is often
applied as a strict liability
standard.
Serious Physical Harm $10,000 Assessed for violations
resulting in serious bodily injury
(e.g., fractures, burns).
Physical Abuse $1,000 - $2,500 Per incident, plus potential
criminal liability.
Repeat Violation $1,000 + $100/day Immediate assessment for
,Violation Type Penalty Structure (2025/2026) Context/Implication
repeating a citation within 12
months.
Interference $100 - $2,500 Immediate penalty for refusing
entry to LPA or Ombudsman.
Insight: The $15,000 penalty for death fundamentally changes the risk profile of hospice care in
RCFEs. Administrators must now ensure that the coordination with hospice agencies is
seamless, as any lapse in care during the dying process that contributes to a negative outcome
(e.g., unmanaged pain leading to cardiac stress) could trigger this penalty.
1.2.3 Eviction Protocols (SB 434 and Tenant Protections)
Legislation regarding evictions (specifically SB 434) has introduced complexity regarding notice
periods. The trend is toward extended notice periods based on length of residency, mirroring
standard tenant-landlord law protections.
● Residency < 1 Year: Requires a 30-day written notice.
● Residency > 1 Year: Requires a 60-day written notice (per general tenant law and
proposed RCFE updates).
● Safe Discharge Planning: A mere notice to quit is no longer sufficient. Eviction notices
must now be accompanied by a "safe discharge plan," documenting the licensee's efforts
to mitigate homelessness or transfer trauma. This plan must include a list of discharge
locations that meet the resident's needs and financial capacity.
● Rights of Return: The legislation creates stronger protections against facilities refusing
to readmit residents after temporary hospitalizations, closing the "hospital dump" loophole.
1.2.4 Emergency Preparedness (SB 582)
In response to increasing wildfire threats, SB 582 mandates tighter integration with local
emergency services.
● MHOAC Coordination: RCFEs are now encouraged (and largely expected) to provide a
copy of their emergency and disaster plan to the Medical Health Operational Area
Coordinator (MHOAC). This ensures that in a mass evacuation event, county emergency
services are aware of the facility's existence and bed count.
● Annual Review: The emergency plan is no longer a static document. It must be reviewed
and updated annually, with specific attention to lessons learned from recent disasters.
Part II: The Failure Hedge — A Proprietary Exam
Strategy
The "Failure Hedge" is a strategic protocol designed to mitigate the specific cognitive risks
associated with the California Administrator Certification Exam. The primary cause of failure is
not a lack of knowledge, but a mismanagement of the "open book" dynamic.
2.1 The Open Book Fallacy
The Trap: Candidates often believe, "The exam is open book; I can just look up the answers."
The Mathematical Reality: You have 120 minutes for 100 questions. That equates to 1.2
,minutes (72 seconds) per question. It is physically impossible to look up every answer. If you
attempt to look up more than 30% of the questions, you will run out of time.
2.2 The Tiered Knowledge Protocol
To pass, the candidate must categorize knowledge into three tiers and apply a distinct strategy
for each.
Tier 1: Instant Recall (The "No-Look" Zone) — 60% of Exam
These are facts that must be memorized cold. Attempting to look these up is a waste of
precious time.
● Temperature Ranges: Heating (68°F minimum), Cooling (78°F-85°F or 30°F below
outside), Hot Water (105°F-120°F).
● Reporting Timelines: Death (24 hours verbal / 7 days written), Epidemic (Immediate),
Fire (Immediate).
● Staffing Training: 40 hours total for staff (20 hours pre-work, 20 hours post-work).
● Food Storage: 2 days perishable, 7 days non-perishable.
● Civil Penalties: $15,000 for death, $150/day for immediate serious violations.
Tier 2: Indexed Verification (The "Check" Zone) — 20% of Exam
These are questions requiring specific numerical precision or obscure regulatory details. You
should know exactly where to find them (Article number) to confirm in under 45 seconds.
● Square Footage: 110 sq ft for single rooms, 160 sq ft for double rooms (Article 5).
● Toilet Ratios: 1 toilet per 6 residents (Article 5).
● License Expiration: 2 years (Article 2).
Tier 3: Critical Synthesis (The "Think" Zone) — 20% of Exam
These are "Best Answer" scenarios where no single regulation explicitly states the answer. You
must synthesize the intent of the law (Safety, Dignity, Independence) to select the correct course
of action.
● Strategy: Apply the "Safety First, Dignity Second, Documentation Third" filter. If a resident
is in danger, safety overrides dignity (e.g., preventing elopement). If safety is neutral,
dignity prevails (e.g., right to refuse food).
2.3 The Blackboard Interface Strategy
The exam is administered via Blackboard.
● Navigation: You cannot skip questions and return easily in all configurations. You must
answer sequentially.
● Search Function: Do not rely on Ctrl+F in a PDF if the system is locked down or if the
PDF is unsearchable. You must be adept at using the Table of Contents of your physical
Title 22 copy.
, Part III: The 7 Domains of Mastery
The 80-hour Initial Certification Training Program (ICTP) and the exam are structured around
specific domains. A "Category of One" administrator does not just pass these domains; they
operationalize them.
Domain 1: Laws, Regulations, and Administrative Requirements (20%)
● Core Concept: The license is non-transferable. It belongs to the licensee and the specific
address. Moving the facility voids the license.
● Administrator Recertification: Requires 40 hours of CE every two years. Crucially, 8
hours must be in Dementia Care and 4 hours in Laws/Regulations.
● The "Designated" Administrator: Every facility must have one designated administrator.
If that person leaves, the licensee has 30 days to hire a replacement.
Domain 2: Business Operations (15%)
● Admission Agreements: This is a contract. It must be signed prior to or at the time of
admission. It must explicitly state the basic rate, optional services, and eviction policies.
● Financial Solvency: The facility must demonstrate the ability to operate for 3 months
without revenue during the application phase.
● Resident Funds: If the facility handles resident money, a surety bond is required. Funds
must be kept separate from facility funds—commingling is a major violation punishable by
fines and potential criminal action.
Domain 3: Management and Supervision of Staff (15%)
● Training Timelines:
○ Direct Care Staff: 40 hours total. 20 hours must be completed before working
independently with residents. The remaining 20 hours must be completed within the
first 4 weeks of employment.
○ Dementia Training: 12 hours total. 6 hours before working with residents, 6 hours
within 4 weeks.
● First Aid/CPR: A strict requirement: At least one staff member with valid CPR/First Aid
certification must be on duty and on the premises at all times. If the only CPR-certified
staff member goes on a lunch break off-site, the facility is non-compliant.
Domain 4: Psychosocial Needs (10%)
● Activity Programming: Facilities of 7+ residents must have organized activity programs
posted. Facilities of 50+ residents must have a full-time, designated Activity Director with
specific qualifications.
● Religious Freedom: Residents have the right to attend religious services of their choice.
The facility must facilitate this attendance (e.g., transportation arrangement) but is not
required to pay for it.
