Starting in August 2025, the State Bar began implementing reviews of client trust accounting. Proposed Scope of Client Trust Account Protection Program Compliance Review Procedures, State Bar of California (July 10, 2025), https://www.calbar.ca.gov/About-Us/Our-Mission/Protecting-the-Public/Public-Comment/Public-Comment-Archives/2025-Public-Comment/Proposed-Scope-of-Client-Trust-Account-Protection-Program-Compliance-Review-Procedures. These changes are already greatly impacting attorneys individual practices in California, and it is imperative that all legal professionals educate themselves on the new requirements.

Attorneys selected for compliance reviews will have to pay hefty fees to State Bar approved CPAs to audit their trust accounts, and the audits are not limited to reviewing that the bank statements reflect the account journals maintained by the attorneys. Instead, these audits or compliance reviews will demand on a short turnaround that attorneys provide evidence in the form of client communications to show that they notified clients and third parties of receipt of funds within 14 days and distributed undisputed funds within 45 days as required by Rule of Professional Conduct 1.15(d).
The Client Trust Account Protection Program (CTAPP), approved by the Supreme Court in January of 2023, provides that the State Bar must establish and administer CTAPP, ensuring that “client funds be held in trust by a licensee that facilitates the State Bar’s detection and deterrence of client trust account misconduct.” Cal. Rules of Court, rule 9.8.5. As a result, the State Bar is granted authority to conduct compliance reviews of client trust accounting.

CTAPP reviews are broken up into four phases: Planning, Compliance, Accounting, and Supervision. State Bar of Cal., Proposed Scope of Client Trust Account Protection Program Compliance Review Procedures (July 10, 2025). https://www.calbar.ca.gov/Portals/0/documents/publicComment/2025/Proposed-Scope-of-CTAPP-Compliance-Review-Procedures.pdf Each phase is governed by applicable statutes and rules. Id. As discussed below, Rule 2.6 with respect to compliance reviews and investigatory audits is outlined under the Planning phase of CTAPP.

In February 2025, the State Bar adopted new Rule 2.6, which outlines compliance review and investigative audit procedures. Rules of State Bar of Cal., rule 2.6. Under Rule 2.6, if selected, a licensee must comply with the State Bar and complete a trust account compliance review, investigative audit, and subject to any findings, fulfill any requirements mandatory of a corrective action plan. Id. Licensees are responsible for designating a State Bar approved Certified Public Accountant (CPA) to conduct the review at their own expense and provide any requested trust account records. Id. This expense will likely cost upwards of $10,000 and can even cost up to $25,000. Those attorneys grossing under $150,000 and who qualify for financial relief can request an in-house audit by the auditors on the State Bar’s payroll. If a licensee is selected, it not only affects the individual licensee, as all licensees of their firm may become subject to “requests for information, requests for responses to questions, and must comply with any mandatory corrective action plan.” Rule 2.6.

According to the new rules for CTAPP audit, if selected the licensee will have to submit to a compliance review which will review no less than one year of trust account activity. Rule 2.6. If selected, the licensee must report the name of the State Bar approved CPA selected following State Bar specifications within 30 days of receipt of notice. Id. If the selected individual is not the designated licensee per Rule 2.4, they must provide names, license numbers, and contact information for the designated licensee. Id. If no designated licensee exists, they must provide names, license numbers, and contact information for the account holder or signatory and the individual responsible for monthly trust account reconciliation. Id. Licensees must also fully comply with and respond to all questions and requests for additional documentation from the State Bar and State Bar approved CPA. Id. After all records have been provided, the selected licensee must provide a signed statement of representation on a State Bar provided form. Id. Finally, within 14 days of completion of the compliance review, licensees must submit an acknowledgment of receipt of any findings.

The State Bar has released a short list of four approved CPA firms from which selected attorneys may choose from:
Sensiba, Lisa Graham, CPA, 2700 Camino Ramon, Suite 140
San Ramon, CA 94583 or 45 River Park Place West, Suite 202
Fresno, CA 93720, Phone: 559-437-0700 ext. 3297, Email:
BHH CPAs, Shelton Autry, CPA, 620 West Cromwell Avenue, Suite 106, Fresno, CA 93711, Phone: 559-221-5071, Email:
Gursey Schneider LLP, Gary Krausz, CPA/CFF, 2121 Avenue of the Stars, Suite 1300, Los Angeles, CA 90067, Phone: 310-691-1794, Email:
Weaver, Peter Lee, CPA CGMA, 800 South Figueroa Street, Suite 780, Los Angeles, CA 90017, Phone: 310-382-5390, Email:

The fact that only four CPA firms managed to be approved for the CTAPP audits means that they will be in high demand, with licensees selected for audit to be clamoring for their services.
For those licensees who are selected for investigative audit, based on the results of the compliance review (Rule 2.6), their accounts will be audited for no less than three years of trust account activity. Id. If selected, a licensee has 14 days to submit any requested trust account records following State Bar specifications, cooperate with and respond to all questions and requests for additional information by the State Bar related to the safekeeping of client or third-party funds, produce records related to non-trust accounts if entrusted funds are held in an account other than a trust account, and provide a signed statement of representation on a State Bar provided form after all required records have been submitted.

The requirement for licensees to provide evidence that notice of receipt of funds has been provided to clients and third parties within 14 days and that undisputed funds for identified clients be distributed within 45 days goes beyond ensuring trust records are in accordance with bank records. These communications will necessarily invade attorney client privilege communications, and the rule changes attempt to abrogate the confidentiality and privileged status of such communications if the State Bar is to make such requests.
Additionally, there is a valid concern of the unlawful practice of law for a CPA to provide expert legal opinions as to whether a lawyer has complied with a rule of professional conduct by notifying clients within 14 days without any rules or regulations as to the scope of work that the CPA is retained to do. Without any parameters governing CPA conduct, there is a potential for abuse and overreach.
Starting the last week of September, the State Bar launched its five-week mandatory CTAPP compliance review program. State Bar Launches Mandatory Client Trust Account Compliance Reviews, State Bar of California (September 29, 2025), State Bar Launches Mandatory Client Trust Account Compliance Reviews - The State Bar of California - News Releases. 100 attorneys statewide will be chosen at random to participate in evaluations of their trust account recordkeeping with 20 attorneys notified each week between September 29, 2025- October 31, 2025. Id. Special Counsel in the Division of Regulation, Steven Moaward released a statement praising the progression of mandatory reviews a step towards “strengthening client trust account practices statewide and deterring public harm before it occurs.” Id.
The proposed set of rules on CTAPP compliance will disproportionally affect small firms and solo practitioners. It is highly recommended that all attorneys seek resources to help ensure they have a solid understanding of their CTAPP obligations, including keeping up with reporting deadlines and changes in requirements. Both the Solo and Small Firm Summit as well as the State Bar are offering courses to provide guidance for attorneys when navigating CTAPP requirements. The Solo and Small Firm Summit offers a course on Client Trust Accounting for 1.25 hours of MCLE credit. The State Bar currently offers a training course on Practical Trust Account Reconciliation for 1 hour general and 1 hour ethics MCLE credit. More information on these resources can be found on the State Bar of California’s website: https://www.calbar.ca.gov/Attorneys/Conduct-Discipline/Client-Trust-Accounting-IOLTA/CTAPP-Training#:~:text=Improve%20your%20client%20trust%20accounting,Additional%20MCLE%20courses. Taking the time to solidify your understanding of what these changes will mean in your individual practice is key to avoiding a difficult audit or being found out of compliance with the new CTAPP rules.  

Traumatic brain injury (TBI) is often called the “invisible injury,” yet its effects can be profound, lasting, and life-altering. For many survivors, timely diagnosis and access to rehabilitation and community-based services are critical for recovery and quality of life. Unfortunately, disparities in access to TBI care continue to pose a significant policy challenge, leaving some individuals underdiagnosed, misattributed, or without the resources they need.

Across the United States, access to TBI services varies widely by geography, socioeconomic status, and cultural background. Rural communities often face shortages of specialized rehabilitation centers and trained providers, while urban areas may have facilities but still encounter barriers such as long wait times, transportation challenges, or high costs. Even within well-resourced regions, underserved populations—including people of color, non-English speakers, and low-income families—may struggle to navigate complex healthcare and social service systems.

New York State provides a case study in both the challenges and potential solutions. Advocates have long highlighted the need for coordinated systems to streamline access to rehabilitation, neuro-resource facilitation, and community support services. Coordination ensures that survivors are not lost in fragmented systems and that each patient receives individualized care plans that reflect their functional, cognitive, and social needs. Efforts in New York aim to connect hospitals, outpatient providers, and community organizations, reducing delays and ensuring continuity of care.

Equity in TBI services also requires attention to cultural competence. Patients from diverse cultural and linguistic backgrounds may face barriers related to communication, trust, or understanding of available services. Programs that prioritize cultural competence—through multilingual resources, culturally informed care practices, and training for providers—can improve engagement, adherence to rehabilitation, and long-term outcomes. Advocates emphasize that culturally competent systems are not optional; they are essential to ensuring that all survivors receive care that respects their backgrounds and meets their needs.

Policy efforts are increasingly focused on addressing these disparities at both state and federal levels. Federal grants supporting state TBI programs provide funding for case management, outreach, and rehabilitation services, while state initiatives can allocate resources to underserved regions or populations. However, funding alone is not enough; the structure and delivery of services must prioritize equity. Integrated care models, centralized referral systems, and community partnerships are emerging as effective strategies to close gaps in access.

Equity in access to TBI services is not only a matter of fairness—it also has practical consequences. Undiagnosed or misattributed injuries can result in delayed treatment, worsening cognitive and physical deficits, and increased reliance on emergency or institutional care. By ensuring that all survivors have timely, appropriate, and culturally competent care, states can improve recovery outcomes, reduce long-term healthcare costs, and support survivors’ participation in work, school, and community life.

In conclusion, disparities in TBI care remain a pressing policy challenge. Coordinated systems, culturally competent practices, and targeted policy initiatives are essential to bridging the gap in access. As advocates push for reforms in New York and nationwide, the goal is clear: every individual with a traumatic brain injury should have the opportunity to access the services they need, regardless of geography, income, or background. Ensuring equity in TBI care is not just a matter of policy—it is a matter of justice and public health.

In January 2025, the Centers for Medicare & Medicaid Services (CMS) officially recognized traumatic brain injury (TBI) as a chronic health condition under Medicare Advantage Chronic Condition Special Needs Plans (C-SNPs). This milestone represents a significant shift in how TBI is viewed within the healthcare system and has important implications for coverage, reimbursement, and long-term care planning.

The designation of TBI as a chronic health condition acknowledges that the effects of brain injury often persist for months or years, requiring ongoing medical, rehabilitative, and supportive services. Survivors frequently face long-term cognitive, physical, and emotional challenges, including memory deficits, mobility limitations, mood disorders, and difficulties with employment and independent living. Recognition as a chronic condition ensures that these needs are formally addressed within care planning and benefits structures.

One immediate impact of CMS recognition is the potential for enhanced coverage under Medicare Advantage C-SNPs. These specialized plans are designed for individuals with specific chronic conditions, providing tailored care coordination, targeted preventive services, and comprehensive management of ongoing health needs. For TBI survivors, this could mean access to long-term rehabilitation, assistive technologies, home-based care, and caregiver support services that were previously inconsistent or difficult to obtain.

The recognition also affects reimbursement models. Providers delivering long-term TBI care—such as neurorehabilitation clinics, home health agencies, and specialized therapists—may now be reimbursed through chronic care management mechanisms, improving financial sustainability and incentivizing high-quality, continuous care. This aligns with broader healthcare goals of reducing hospital readmissions, preventing secondary complications, and promoting functional independence among patients with complex needs.

Policy experts highlight that CMS’s decision could also influence state and federal program planning. Programs funded by federal TBI grants or state health agencies may now have additional justification to prioritize long-term support services, integrate chronic care management strategies, and strengthen partnerships with healthcare systems. Furthermore, insurers beyond Medicare may adopt similar approaches, standardizing coverage for TBI as a chronic condition and improving consistency across payers.

Advocacy organizations, including the Brain Injury Association of America, emphasize that formal recognition validates the lifelong impact of TBI. It supports advocacy efforts for increased funding, comprehensive rehabilitation, caregiver resources, and policies that address disparities in access to care. Recognition as a chronic health condition also underscores the need for ongoing research into effective interventions, long-term outcomes, and quality-of-life measures.

In conclusion, CMS’s recognition of TBI as a chronic health condition represents a critical step toward improving care, coverage, and policy for individuals living with brain injuries. By integrating TBI into chronic care frameworks, the healthcare system can better address the long-term needs of survivors, enhance reimbursement and service delivery, and prioritize access to essential rehabilitative and supportive services. This policy shift lays the groundwork for more consistent, sustainable, and patient-centered TBI care nationwide.

Federal funding plays a critical role in sustaining state programs that provide services to individuals with traumatic brain injuries (TBI). These grants, administered through the Department of Health and Human Services, enable states to deliver rehabilitation, community-based care, and advocacy services that are often not covered by private insurance or other funding sources.

State TBI programs rely on federal grants to fund a wide range of essential services. These include cognitive and physical rehabilitation, counseling for survivors and caregivers, vocational training, and community reintegration programs. In addition, programs provide case management and coordination services that help individuals navigate complex medical and social systems. Without federal support, many of these services would be limited or unavailable, particularly in rural or underserved areas.

One of the primary federal funding sources is the TBI State Partnership Grant program, which supports initiatives to expand access to care, enhance public awareness, and improve long-term outcomes for survivors. Another critical source is the Protection & Advocacy (P&A) program, which funds legal advocacy and rights protection for individuals with brain injuries, helping them secure necessary services and accommodations. Both programs are dependent on periodic congressional reauthorization, making sustained federal support vital for continuity of care.

Federal funding also allows states to implement evidence-based practices and monitor outcomes. Through grant-supported data collection and research, programs track functional improvements, reductions in hospital readmissions, and overall quality-of-life measures. This data informs policy decisions, identifies gaps in services, and ensures resources are directed to the populations most in need.

The impact of federal funding extends beyond individual survivors. It strengthens statewide infrastructure, supports training for medical and social service professionals, and enables collaboration among hospitals, rehabilitation centers, and community organizations. Additionally, consistent funding reduces long-term costs by preventing secondary health complications and supporting individuals in returning to productive roles in their communities.

Advocacy organizations consistently highlight the importance of federal funding for state TBI programs. They emphasize that the loss of funding would not only disrupt care for survivors but also place additional burdens on hospitals, emergency services, and social support systems. Sustained federal investment ensures that survivors receive comprehensive, lifelong support and that states can maintain and expand services to meet growing needs.

In conclusion, federal funding for state TBI programs is a cornerstone of national efforts to support individuals living with traumatic brain injuries. These grants enable states to provide essential rehabilitation and advocacy services, enhance community integration, and improve long-term outcomes. Continued federal support is essential to maintain the accessibility, quality, and sustainability of TBI programs, ensuring that survivors and their families receive the resources they need to rebuild their lives.

In 2025, Congress reintroduced the Traumatic Brain Injury (TBI) Program Reauthorization Act—a crucial piece of legislation that aims to secure continued support for Americans affected by brain injury. Originally enacted in 1996, the TBI Act authorizes federal programs through the Department of Health and Human Services (HHS) to promote prevention, data collection, rehabilitation, and advocacy.

Why Reauthorization Matters

The prior authorization for the TBI program expired on September 30, 2024. Without reauthorization, key grant programs risk losing momentum or funding, including state-based rehabilitation services and legal advocacy systems for TBI survivors. The Brain Injury Association of America (BIAA) has strongly backed the renewal, citing persistent needs for long-term support, data collection, and education.

What the 2025 Bill Proposes

Senators Markwayne Mullin (R-OK) and Catherine Cortez Masto (D-NV), along with other bipartisan members, introduced S. 2898, the Dennis John Benigno Traumatic Brain Injury Program Reauthorization Act of 2025. The bill would reauthorize multiple core grant programs through 2030, including:

• TBI State Partnership Grants — to expand access to community-based rehabilitation and support services.
• Protection & Advocacy (P&A) Grants — to fund legal and self-advocacy services for TBI survivors.
• CDC TBI Program — to support public health efforts, research, and national data collection on TBIs.

Key Improvements in the New Legislation

One of the most significant updates in the 2025 reauthorization is an expanded definition of TBI. For the first time, the legislation would include all acquired brain injuries (ABI)—not just injuries from external trauma—to recognize conditions caused by anoxia, infections, surgery, or vascular incidents. This broader scope helps ensure more survivors can access services under the TBI program.

Additionally, the bill requires a report on whether brain injury should be formally designated a chronic health condition. Within two years of enactment, HHS must review existing evidence and make recommendations to Congress, increasing the visibility of long-term TBI impacts. The legislation also strengthens surveillance, calling for better data collection on brain injury incidence, prevalence, and risk factors.

The Stakes for the TBI Community

Advocacy groups, survivors, and caregivers emphasize that this reauthorization is not just about preserving existing programs—it’s about scaling them to meet growing needs. The BIAA has called for increased federal funding, reduced state-matching burdens, and more inclusive eligibility criteria so that underrepresented populations (like those with non-traumatic brain injuries) are not left behind.

Without this legislation, state-based services for TBI survivors could become fragmented or underfunded, making it harder for people with brain injuries to access long-term support. With reauthorization, the federal government affirms its commitment to prevention, patient advocacy, and evidence-based care.

Conclusion

The reauthorization of the TBI Act represents a critical opportunity for bipartisan collaboration, public health investment, and long-term support for people living with brain injury. By broadening definitions, reinforcing data systems, and securing grant funding through 2030, the 2025 bill could significantly strengthen the national infrastructure for TBI prevention, treatment, and advocacy.