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Behavioral Health Network Adequacy Oversight Branch

The Behavioral Health Network Adequacy Oversight Branch (BHNAOB) is structurally within the Behavioral Health Oversight and Monitoring Division (BHOMD), which is a part of the Behavioral Health program of the Department of Health Care Services. Information about BHOMD can be found via the Behavioral Health Services homepage link at the top of this document. BHNAOB is responsible for the Medi-Cal Behavioral Health network adequacy program, the Behavioral Health Services Act network adequacy program, and formerly had administrative responsibility for the Behavioral Health Quality Improvement Program (BHQIP), which was sunset on June 30, 2024. The Network Adequacy Oversight Sections are responsible for the oversight and monitoring all behavioral health components of the Specialty Mental Health Services (SMHS) and Drug Medi-Cal Organized Delivery System (DMC-ODS) program, as well as timely access requirements for Drug Medi-Cal state plans due to parity requirements

Network Adequacy Oversight Section

The Network Adequacy Oversight Section (NAOS) is found within the BHNAOB. BHNAOB is found within BHOMD and is a part of the Behavioral Health program of DHCS. 

DHCS contracts with counties that either provide, or arrange for the provision of, specialty mental health services and substance use treatment services to eligible Medi-Cal members. 

NAOS performs compliance oversight and monitoring of the MHPs and DMC-ODS programs to ensure compliance with the network adequacy requirements set forth in Title 42 of the Code of Federal Regulations (CFR) and the network adequacy requirements of the Behavioral Health Services Act. NAOS primarily assesses the compliance of MHPs and DMC-ODS programs through its reviews of required submissions from these entities as part of an annual network certification process. NAOS, as necessary to ensure the adequacy of each provider network, identifies any deficiencies with current standards, including timely access standards as prescribed by WIC 14197 and provides technical assistance to the MHPs and DMC-ODS programs to resolve compliance issues. Where technical assistance is not effective, NAOS implements corrective measures such as corrective action plans and administrative or monetary sanctions. 

NAOS also performs oversight, technical assistance, and monitoring related to improving access to care, which includes timely access requirements as defined in Welfare and Institutions Code 14197. These requirements include an initial request for first appointment or first specialty mental health service for new members, non-urgent follow-up appointments, and ensuring language assistance services are coordinated with scheduled appointments for health care services. 

The network adequacy compliance and monitoring activities identified here are specific to MHPs, DMC-ODS programs, and DMC state plans specifically for timely access requirements. The Managed Care Quality and Monitoring Division monitors network adequacy requirements for Managed Care Plans. Please refer to the Department of Health Care Service Network Adequacy webpage for more information related to network adequacy, including Annual Certification Reports, approved Alternative Access Standards, and Corrective Action Plans. 

Provided below are some federal and state laws applicable to NAOS. These laws are found within the CFR, and Welfare and Institutions Code (WIC). 

Applicable Laws 

Federal: 

  • 42 CFR 438.206 Availability of Services 

  • 42 CFR 438.207 Assurance of Adequate Capacity and Services 

  • 42 CFR 438.68 Network Adequacy Standards 

State (Statutes): 

  • HSC Section 1367.03 

  • WIC Section 14197 

State (Regulations): 

  • 28 CCR Section 1300.67.04 

  • 28 CCR Section 1300.67.2.2 


​​Additional Resources

California Advancing and Innovation Medi-Cal (CalAIM):

Medicaid and Medi-Cal General:

Contact Information

General Division:
BHOMD@dhcs.ca.gov
County Support:    
CountySupport@dhcs.ca.gov
​NAOS
NAOS@dhcs.ca.gov​
BH CalAIM BHCalAIM@dhcs.ca.gov

Last modified date: 1/23/2025 2:35 PM