Individual Service Level Encounter
Frequently Asked Questions

What statutory authority or BHIN requires counties to report ISL encounters to DHCS?  

• DHCS’ statutory authority for ISL is Welfare & Institutions Codes §§ 5963.04(a)(2)(H)-(I), 5963.04(b), and 5897(d). ISL is also mandated under the BHSA Policy Manual and the County Performance Contract (effective July 1, 2026).  

What funding is available to support counties with implementing ISL requirements? 

• Counties may claim allowable BHSA administrative expenses for eligible net costs incurred to implement ISL reporting, as outlined in Behavioral Health Information Notice (BHIN) 25-016.  

Will there be sanctions associated with not meeting ISL reporting requirements?

• ISL encounter reporting is a required component of county Behavioral Health Outcomes, Accountability, and Transparency Report (BHOATR) submissions. As outlined in the Oversight and Enforcement chapter of the BHSA County Policy Manual, DHCS has established an oversight and enforcement framework that includes the authority to impose administrative and monetary sanctions for various types of noncompliance with BHSA requirements.  During initial implementation, DHCS intends to emphasize technical assistance and county readiness support to help counties meet the reporting requirements. DHCS may issue guidance regarding ISL-specific monitoring or enforcement guidance, as appropriate in the future. 

What does it mean that ISL reporting becomes required effective January 1, 2027? What specifically is required starting January 1, 2027, since ISL encounters must be submitted annually at minimum? 

• Counties must collect all behavioral health services delivered to an individual that are not claimable to Medi-Cal and are in scope for ISL encounter reporting beginning January 1, 2027. For the first year of ISL reporting, counties are required to report services delivered between January 1, 2027, through June 30, 2027, no later than 90 days after the close of FY 2026-27 (2027 FY Close: June 30, 2027, ISL 1st Year Reporting Deadline: September 28, 2027). For all subsequent years, counties must report the full fiscal year of ISL encounters in accordance with the same due date of 90-days after the end of the Fiscal Year.  

Can counties submit ISL reports more frequently than annually?  

• Counties can submit ISL encounters as frequently as they choose; however, all reportable encounters for a fiscal year must be reported within 90 days of the close of the fiscal year in which the service was rendered. For example, services rendered in May 2027 must be submitted no later than September 28, 2027. 

Are counties expected to account for 100% of non-Medi-Cal-claimable services delivered in ISL reporting? How should counties determine if a service or expense is ISL reportable?   

• ISL is intended to capture the majority of non-Medi-Cal-claimable individual behavioral health services and expenses that counties provide.  
  
  When considering whether a service is reportable through ISL, counties should assess whether the service/expense is: (1) attributable to an individual; (2) not captured through any Medi-Cal claiming system; and (3) within the county’s delivery system or reporting responsibility (i.e., delivered through the county’s provider network or administered/contracted by the county and tied to a county behavioral health–incurred cost).  The answer to all three of these must be yes for an ISL encounter to be submitted.  
  
  Please see ISL Guidance for detailed information on in-scope and out-of-scope ISL services.  

Are unsuccessful contact or outreach attempts in scope for ISL reporting? 

• Generally, no. ISL is intended to capture individual-level behavioral health services and expenses delivered to an identifiable client that are not claimable to Medi-Cal. Consistent with Medi-Cal billing and documentation principles, ISL reporting is intended to capture services that are actually delivered to a client, rather than unsuccessful attempts to provide a service. As a result, unsuccessful contact or outreach attempts that do not result in a service being delivered to the client are generally not reportable in ISL. For example, if a client is not reached by phone, or if staff travel to a location but are unable to make contact with the client, the activity would not be reported as an ISL encounter. 

Is the county responsible for reporting ISL services that are provided to behavioral health clients but not paid for using behavioral health funds (e.g., Sheriff- or Probation-funded services; Low Income Home Energy Assistance Program (LIHEAP))? 

• Counties are responsible for reporting in-scope client-level behavioral health services and expenses that are delivered through the county behavioral health delivery system and have an associated cost. Services delivered entirely outside the behavioral health system (e.g., sheriff/probation-funded services or general assistance like LIHEAP) are not in scope for ISL reporting, even if the recipients are behavioral health clients.

What are the ISL reporting expectations for cities (Berkeley and Tri-Cities) versus counties considering instances when the city may also deliver services under contract with the county behavioral health plan?  

• ISL encounter reporting captures individual-level behavioral health services provided directly to clients by city agencies (i.e., Berkeley and Tri City Mental Health) and county behavioral health systems (collectively referred to as “counties”), and county provider networks (collectively referred to as “providers”) that are not reimbursable by DHCS through the behavioral health Medi-Cal benefit package. If a city agency (Berkeley or Tri-City Mental Health) delivers ISL-reportable services under contract with county behavioral health, those ISL encounters should be reported by the county as part of the county’s ISL submission. If the city agency delivers ISL-reportable services outside of a county contract/provider network arrangement, the city is responsible for submitting those ISL encounters directly to DHCS per DHCS guidance.  

If a client has Medi-Cal coverage with a share of cost (SOC), are services provided to the client up to the point they meet their SOC ISL reportable? Additionally, if a client is qualified for Uniform Method to Determine Ability to Pay (UMDAP), are these services ISL reportable?  

• SOC and UMDAP services are not ISL reportable if the client has Medi-Cal coverage and is receiving a Medi-Cal coverable service. If the service is otherwise in scope for ISL reporting, is not reimbursable through Medi-Cal, and meets all applicable ISL reportability criteria, then the service must be reported via ISL.  

Are Medi-Cal services that do not meet the minimum threshold time required for Medi-Cal billing in scope for ISL reporting?  

• In alignment with current Medi-Cal billing guidance, behavioral health services that do not meet an applicable minimum threshold time requirement are not eligible for Medi-Cal claiming and, therefore, are also not in scope for ISL reporting. Minimum threshold time requirements refer to the minimum amount of direct patient care time required to claim a unit of service for specific service codes, as outlined in applicable Medi-Cal billing guidance and service tables. 
  
  The concept of minimum threshold time applies only in the circumstances expressly identified in existing Medi-Cal billing requirements and should not be interpreted as establishing an additional or broader ISL reporting requirement beyond those requirements.   

Centers of Excellence (COEs) are asking clinicians to complete additional tools and document additional information in databases COEs have created for monitoring fidelity requirements for Functional Family Therapy (FFT), Multisystemic Therapy (MST) and Parent-Child Interaction Therapy (PCIT).  Does DHCS consider these tasks/activities that are required to demonstrate Evidence-Based Practice (EBP) fidelity “in scope” for ISL reporting? Additionally, is time spent administering various tools to clients and families under the EBP model claimable to Medi-Cal (whether or not the county has opted in to use the bundled rate), or should these be submitted as ISL encounters (if so, which code should be used)? 

• Administrative and documentation time is captured in established Medi-Cal rates for FFT, MST, and PCIT. Like other Medi-Cal behavioral health outpatient and EBP rates, these are “fully loaded” (as defined by DHCS’ payment reform FAQ) and account for direct service time and staff time spent on documentation, travel, and other direct and indirect costs. Counties should not submit any ISL encounters for time spent doing on documentation/data collection for FFT, MST or PCIT or other EBPs.  

Are grievance-related activities (e.g., time spent resolving the grievance that can be attributed to a specific client) in scope for ISL reporting? 

• Time spent on grievance activities is not ISL reportable since these are covered under Quality Assurance/Utilization Review (QA/UR) activities. Filling out the quarterly QA/UR claim results in funds being directed to the county to support those activities.  

Scenario: County A purchases Psychiatric Health Facility (PHF) beds from County B, and County B bills Medi-Cal for the PHF stay while County A pays County B the non-federal share. Does either county have ISL reporting responsibilities in this scenario? 

• Neither county would be responsible for reporting the Psychiatric Health Facility service through ISL since the service was claimed to Medi-Cal.   

When Department of State Hospital (DSH) bed days are paid through a realignment offset rather than a direct county invoice, are counties required to report these placements through ISL? If so, what data source should counties use to populate the ISL record (e.g., the monthly realignment portal report), and what rate/cost figure should be entered?  

• In general, because Department of State Hospitals (DSH) bed day costs are not captured through Medi-Cal claims, these costs should be reported through ISL.  
  
  With respect to data sources and cost attribution, the current county-facing DSH portal does not reflect costs at the individual client level. CalMHSA, in coordination with DSH through the State Hospital Bed Program, is working to address this limitation. The goal of this effort is to enable counties to access client-level statements that identify bed days utilized by individual and by bed type. In the interim, counties should rely on the bed rates specified in their MOUs with DSH and align those rates with internal placement records and DSH bed utilization statements. This information should be used to populate ISL records in accordance with forthcoming DHCS submission guidance and technical specifications. Please note that updated DSH bed rates will take effect on July 1, 2026 (FY 2026–27).    

Can counties report ISL encounters for clients without names (e.g., allow counties to submit a pseudonym like Jane Doe/John Doe)? 

• ISL encounters must be attributable to an identifiable individual and must include the client identifiers required by the ISL Encounter Fields and validation rules. If a service or expense cannot be associated with an identifiable individual, it should not be reported through ISL. Counties should instead report those costs through the BHOATR, as applicable. Counties should not create placeholder client records or use pseudonyms solely for purposes of ISL reporting. 

Are ISL encounters entered in the Electronic Health Record (EHR) considered a part of the designated record set? In other words, are ISL encounters considered releasable or non-releasable for medical records requests? 

• Generally, ISL encounters can be part of the designated record set, but it depends on how the records are used and maintained. Under HIPAA, the designated record set includes: 
  • Medical records and billing records maintained by or for a covered entity 
  • Enrollment, payment, claims adjudication, and case management records 
  • Any other records used to make decisions about the individual. 
    
    Organizations should consult with their legal counsel and review the Office of Civil Rights guidance which outlines the specific uses for which govern if the ISL encounter is considered part of the designated record set and generally subject to access by the client. 

How should counties understand and apply ISL modifiers, including the hierarchy and limits on modifier usage? 

• Consistent with current Medi-Cal requirements, ISL does not establish a modifier hierarchy or additional modifier usage requirements. Unlike Medi-Cal claiming, ISL does not impose limitations on the number of modifiers that can be reported for a service. 
  
  Counties should continue applying modifiers based on clinical appropriateness and existing coding and billing requirements for the underlying service. This includes applicable Medi-Cal claiming requirements, as described in the appropriate Short Doyle Medi-Cal Billing Manuals, as well as the ISL Guidance and ISL Code Library. 

What are the New Medi-Cal and ISL modifiers? Will DHCS be updating the MedCCC Medi-Cal billing manuals, service tables, and related claiming guidance? When will use of these modifiers for Medi-Cal claiming become required?

• The “Medi-Cal and ISL Modifiers” tab in the ISL Code Library outlines modifiers developed by DHCS for BHSA reporting. Counties will be required to use these modifiers for both Medi-Cal claims and ISL encounter reporting for applicable services. DHCS is currently working to activate all modifiers within the Short Doyle Medi-Cal claiming system by January 1, 2027, and anticipates requiring their use for all Medi-Cal claims with dates of service on or after that date. Additional and updated DHCS guidance on the use of these modifiers and these new requirements for both Medi-Cal claiming and ISL submissions is forthcoming.  

Will DHCS provide a code or coding guidance for assertive field-based Substance Use Disorder (SUD) initiation services?

• Codes and coding guidance for Assertive Field Based SUD Initiation, and other Full Service Partnership (FSP) and Evidence Based Practice (EBP) services, can be found in the ISL Code Library and the ISL Guidance in the “ISL Code Library – Special Instructions” section.  

Are the expense and minute-based non-Medi-Cal ISL codes limited to specific practitioner types / taxonomies?  

• The expense and minute-based non-Medi-Cal ISL codes are practitioner agnostic; these ISL codes can be used by any practitioner taxonomy or a staff without a taxonomy code.  

When should counties report activities, costs, or supports through ISL (e.g. the use of the ISL Travel & Transportation code ISL401) that are covered within Medi-Cal provider reimbursement rates?

• When a service is claimable to Medi-Cal, the activities and costs necessary to provide that service – such as documentation time, travel time, mileage, and other routine service-delivery costs – are generally considered included in the Medi-Cal reimbursement rate. These costs should not be separately reported as ISL encounters. ISL is not intended to function as a mechanism for separately capturing cost components already captured within a Medi-Cal claim. 
• For example: counties must use ISL401 (Travel & Transportation) only when providing a distinct client-level transportation support that is not claimable to Medi-Cal and can be attributed to a specific individual. Examples include a taxi or rideshare service, bus pass, gas voucher, temporary car rental, or vehicle repair assistance provided to support an individual’s access to services or supports. 
• Counties must not use ISL401 to report staff travel time, mileage, or other routine transportation costs associated with delivering a Medi-Cal-claimable service, as those costs are generally accounted for through Medi-Cal reimbursement rates and should not be separately reported through ISL. 

When should counties use the ISL Translation/Interpreter Services code (ISL405) versus the Medi-Cal supplemental code for sign language or oral interpretive services (T1013)? 

• T1013 is a Medi-Cal supplemental service code and must be reported, alongside the applicable primary Medi-Cal service code, when interpreter services are furnished in connection with a Medi-Cal claimable service – even if the service is reported through ISL and not submitted to Medi-Cal for reimbursement. ISL405 must be used when interpreter services are provided in connection with a non-Medi-Cal claimable service or as a standalone service not associated with a Medi-Cal claimable service.   

Should counties use ISL406 instead of the other expense codes (ISL400-ISL405) if those expenses are being provided to a youth receiving HFW services? Or, should any of these other expense codes (ISL400-ISL405) be used instead of ISL406 for youth receiving HFW services?

• Counties should use ISL406 for any services, goods and expenses delivered by a HFW provider that are not captured in the HFW Medi-Cal monthly rate, including expenses such as food, clothing, travel, and employment expenses. Counties should not use ISL400-405 for services, goods, and expenses delivered as part of HFW. 

For group services where non-Medi-Cal clients are participating, which code should be used to report these services?  

• Counties must report services for each individual participating in a group service and select the code that most accurately reflects the service delivered. If the group service is Medi-Cal claimable (e.g., a Medi-Cal reimbursable group therapy service), counties must use the appropriate Medi-Cal group Current Procedural Terminology (CPT)/Healthcare Common Procedure Coding System (HCPCS) code and submit the claim to Medi-Cal in accordance with existing billing requirements. If the group service is not Medi-Cal claimable (e.g., due to the individual not being Medi-Cal eligible), counties must report the service in ISL using the most appropriate Medi-Cal CPT/HCPCS code that accurately describes the service. If no such code is appropriate, counties should instead use the applicable non-Medi-Cal ISL code (e.g., an early intervention ISL code) that best represents the service provided.  

How should counties report Board & Care Patch levels 1 through 5 (ISL200-ISL204) in ISL when local provider contracts do not have five different rate levels for these services? 

• If Board and Care contracts do not have five rate levels, counties should select the ISL Board and Care Patch level code that best describes the care level/intensity based on the code descriptions.  

How is “permanent” defined for ISL212 (Recovery Residence/Sober Living Environment-Permanent Setting)?  

• For purposes of ISL212, “permanent” recovery housing refers to a setting in which the individual has tenant rights, typically established through a lease or similar tenancy agreement, and where there is no defined limit on length of stay.  
• In contrast, recovery residences that operate under program agreements* (rather than leases) and impose defined or time-limited lengths of stay are considered interim housing.  
• Accordingly, selection between “permanent” and “interim” recovery residence codes must be based on the underlying housing structure, specifically whether the setting is non-time-limited and includes tenant protections (permanent) versus time-limited and program-based (interim).  
• *A program agreement is a document that a client signs that establishes participation in a time-limited, program-based setting; housing is tied to participation in the program and does not create the same tenancy rights as a lease or similar tenancy agreement. 

How should counties use the operating subsidy ISL codes (ISL 220 and ISL 221) for client-level reporting?  

• ISL220 and ISL221 are used when operating costs can be reasonably attributed to individual clients, even when there is no direct per diem or per client payment structure. This typically occurs in operating subsidy arrangements, where the county pays a lump sum to a provider for costs associated with the day-to-day physical operation of housing projects and then allocates those costs to clients using a documented methodology.  
• For example, if a county pays a provider $10,000 in a month for operating costs and 10 clients are served, the county may reasonably allocate $1,000 per client for that month and report those amounts using ISL220 or ISL221.  
• Counties should not use the operating subsidy codes if those same costs are already built into a bundled per-day housing rate to avoid double counting.  Instead, counties should use the appropriate rental subsidy or specific setting ISL code for the full bundled rate.  

What ISL code should counties use when the county pays a patch for an adult residential facility that is not an IMD or a SNF?  

• For adult residential facility patches (not SNF or MHRC), counties can use the Board & Care Patch Level codes (ISL200-ISL204).  

What ISL code should counties use to report client placements in non-state, non-PHF hospitals when the county pays full cost out of pocket and cannot bill Medi-Cal? 

• Counties should use the code from the ISL Code Library that best describes the service. In this scenario there is no appropriate non-Medi-Cal code; counties should select the most appropriate Medi-Cal specialty mental health 24-hour/inpatient service code (e.g., psychiatric inpatient day), and report the encounter value, consistent with DHCS ISL submission specifications outlined in the ISL Guidance.  

Does the Shelter Plus Programming ISL code (ISL215) apply to the housing costs, supportive services, or both? Does the supportive services component qualify as an allowable use of BHSA Housing Intervention funds?  

• ISL215 is intended to capture housing costs and housing-related supports that are not covered by Medi-Cal. It is not intended to capture behavioral health services, which are not an allowable use of BHSA Housing Interventions. Please see the BHSA Housing Interventions Policy Manual Housing Interventions Chapter C.9.4. Other Housing Supports for more detail on allowable housing-related supports.  

Does ISL reporting impact/decrease reporting requirements under ECCO for SUD primary prevention services?  

• DHCS is reviewing systems used for county reporting, including ECCO. DHCS aims to streamline county reporting and recently announced (see BHIN 26-016) it is eliminating the requirement that counties report on MHSA Full-Service Partnership (FSP) outcomes via the DCR system. DHCS will communicate with counties in advance of implementing changes to reporting requirements and systems while continuing to ensure compliance with federal reporting requirements.  

Are counties required to complete CSI, CalOMS, and/or 274 provider directory reporting for providers that are not part of the county’s Medi-Cal provider network and only deliver ISL-reportable services? 

• Counties must continue to comply with all applicable state and federal reporting requirements, including CSI, CalOMS, and 274 provider directory reporting. ISL reporting does not replace or eliminate existing reporting obligations. Counties must continue submitting information for Substance Use Prevention, Treatment, and Recovery Services Block Grant (SUBG)-funded services through CalOMS and Mental Health Block Grant (MHBG)-funded services through CSI. 
  
  Provider directory (274) reporting requirements continue to apply to a county’s Medi-Cal provider network. Providers that are not part of the county’s Medi-Cal provider network and only deliver ISL-reportable services are not required to be included in 274 provider directory reporting solely because they furnish those services. However, counties must continue to ensure that providers required to enroll in Medi-Cal (e.g., Behavioral Health Services and Supports (BHSS) and Full Service Partnership (FSP) providers) are enrolled in accordance with applicable DHCS requirements and timelines. 
  
  As counties implement ISL reporting, DHCS anticipates future opportunities to streamline state and federal reporting requirements and will provide additional guidance as it becomes available. 

Does DHCS expect ISL implementation to impact counties’ abilities to meet the 60% productivity rate (i.e., time spent on direct billable services) used for network adequacy standards in BHIN 26-015? 

• No. ISL is a reporting requirement to capture the individual-level, non-Medi-Cal-claimable services and expenses counties are already providing – it is not a requirement to deliver new, non-billable services. ISL does not change existing Medi-Cal billing rules. Counties are encouraged to implement ISL data collection workflows in ways that minimize added burden on direct service staff (e.g., leveraging existing workflows, administrative entry for expense-only items).  

How will ISL data be used in BHT performance measures? Specifically, will DHCS publish specifications for how Medi-Cal and non-Medi-Cal ISL procedure codes will be reflected in performance measure numerators and denominators?  

• DHCS will not use ISL data from FY 26-27 in performance measures and will not use ISL data in the first Annual Update. DHCS will incorporate FY 27-28 encounter data into relevant performance measures to capture additional services for Medi-Cal members as well as to include non-Medi-Cal services in measures and non-Medi-Cal recipients of county behavioral health services in the eligible population for those measures. DHCS anticipates that the first public release of measure rates inclusive of ISL data will be in 2029 and is currently developing a plan to identify which measures will utilize ISL data. Once the measures are identified, DHCS will update measure specifications to include the corresponding ISL procedure codes within the measure logic. The updated measure specifications will be shared with counties and MCPs as well as released publicly.