​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​Behavioral Health Administrative Integration

What does each phase of Behavioral Health Administrative Integration entail?

To achieve statewide Behavioral Health Administrative Integration in 2027, DHCS will work with counties using a three-phased approach under which different components will be integrated to different degrees at different times. The phased implementation plan was developed to account for the fact that some components can be integrated under existing authorities and counties may already have taken steps to do so, while other components may require action on the part of DHCS, changes to state authorities, or federal approval.

• ​Phase 1 is focused on voluntary integration of county functions under existing contracts over calendar years 2023 and 2024. 
• Phase 2 will focus on voluntary contract integration over calendar years 2025 and 2026 for the counties that volunteer to adopt integrated contracts early, effective January 1, 2025. 
  
• In Phase 3, all counties will be required to adopt integrated contracts effective January 1, 2027, as specified in CalAIM statute (AB 133). 

For additional information about each phase of implementation, please see the Behavioral Health Administrative Integration Concept Paper​.

Can DHCS provide more detail on the proposal to align integrated DHCS-County contracts with the Calendar Year as opposed to the Fiscal Year?

Currently, DHCS-County behavioral health contracts are aligned with the State Fiscal Year, which runs from July 1 to June 30. In AB 133, however, the Legislature directed DHCS and counties to execute integrated behavioral health contracts effective January 1, 2027. Having the integrated behavioral health contracts take effect at the beginning of the calendar year would align with the renewal of DHCS' existing 1915(b) waiver and with Managed Care Plan (MCP) contract cycles, both of which already follow the calendar year. DHCS will work closely with counties and other key stakeholders to assess the implications of shifting the behavioral health contract cycle to the calendar year, and to ensure a successful transition to calendar year contract cycles.

How will DHCS support counties to achieve compliance with Behavioral Health Administrative Integration by January 1, 2027?

DHCS acknowledges that county staff time is limited and that counties are implementing other CalAIM policy reforms. DHCS developed the phased implementation approach for Behavioral Health Administrative Integration with these capacity constraints in mind, including coordination with other CalAIM reforms. DHCS will continue to conduct extensive stakeholder engagement and technical assistance to ensure that counties have the information, resources, and technical assistance they need to successfully implement Behavioral Health Administrative Integration. Engagement will include stakeholder workgroups, informational webinars, targeted outreach, and the release of clear guidance and other resources, as appropriate.

What are the benefits for counties that volunteer for early contract integration?

​What will Behavioral Health Administrative Integration look like for counties that do not volunteer for early contract integration?​

​During Phase 2 (1/1/25-12/31/26: Voluntary Contract Integration), counties that do not opt into early contract integration can continue integrating components that do not require additional guidance from DHCS, such as processes related to the 24/7 access line, screening, assessment, and treatment planning, quality improvement, and cultural competence plans, as well as county data storage and data sharing in preparation for full implementation by January 1, 2027. These counties will not participate in the components that require integrated contract authority, (i.e., External Quality Reviews (EQRs), BH audits, and network adequacy certifications) until 2027.

​DMC Counties

What will Behavioral Health Administrative Integration look like for Drug Medi-Cal (DMC) counties?

DMC counties will continue providing substance use disorder services outside the managed care structure while participating in all other applicable aspects of this initiative, including adopting an integrated Mental Health Plan (MHP) and DMC contract with DHCS that promotes integration goals. Additional information, and opportunities for stakeholder engagement specific to DMC counties, are forthcoming.

DMC-ODS Regional Model​

How will Behavioral Health Administrative Integration be implemented for counties who are in the Drug Medi-Cal-Organized Delivery System (DMC-ODS) Regional Model?

DHCS recognizes that there are unique implementation considerations for DMC-ODS Regional model counties. In Phase 1 (present – 12/31/24: Voluntary Integration of County Functions Under Existing Contracts), DHCS will conduct targeted stakeholder engagement with counties participating in the DMC-ODS Regional Model to inform implementation of Behavioral Health Administrative Integration for participants in this model. Additional information is forthcoming.

Alignment with Other CalAIM Reforms​

Will Behavioral Health Administrative Integration require integrated Memoranda of Understanding (MOU) between MCPs and Behavioral Health Plans (BHPs)?

Behavioral Health Administrative Integration does not require a new MOU between MCPs and Behavioral Health Plans (BHPs). BHPs may submit one integrated MOU template inclusive of MHP and DMC-ODS or DMC requirements that fulfills all requirements outlined in Behavioral Health Information Notice (BHIN) 23-056, 23-057, and 24-016.

How does Behavioral Health Administrative Integration align with other CalAIM policy reforms like No Wrong Door, Documentation Redesign, and Standardized Screening and Transition Tools?​

​DHCS developed the Behavioral Health Administrative Integration framework and phased implementation approach to align with and create opportunities to support and leverage implementation of existing CalAIM initiatives, clarify existing requirements, and promote best practices at the point of care for screening, assessments, and treatment planning. These CalAIM initiatives already include policy changes that align administrative requirements for Medi-Cal SMHS and Substance Use Disorder (SUD) services. For example, CalAIM included member access criteria updates that clarified that a clinical diagnosis is not a prerequisite to receive behavioral health services in either the SMH or DMC/DMC-ODS delivery systems; individuals with MH or SUD symptoms may receive care while a diagnosis is determined. Many Documentation Redesign policy changes also apply across specialty BH delivery systems, including the elimination of static treatment plans and adoption of problem lists.

How will payment work with Behavioral Health Administrative Integration?​

​Effective July 1, 2023 under the CalAIM Behavioral Health Payment Reform initiative​, county Behavioral Health Plans transitioned from cost-based reimbursement funded via Certified Public Expenditures (CPEs) to fee-for-service reimbursement funded via Intergovernmental Transfers (IGTs), eliminating the need for reconciliation to actual costs.  As part of payment reform, both Specialty Mental Health (SMH) and SUD services transitioned from existing Healthcare Common Procedure Coding System (HCPCS) Level II coding to Level I coding, known as Current Procedural Terminology (CPT) coding, when possible. Behavioral Health Administrative Integration will not change covered Medi-Cal BH benefits or modify the components of payment reform for SMH, DMC, or DMC-ODS.  Behavioral Health Administrative Integration Initiative also does not change the way Medi-Cal SMHS and SUD services are financed in California; in other words, it will not change existing allocation methods or spending requirements for MH and SUD funding sources including 1991 and 2011 Realignment and MHSA. More information about Behavioral Health Payment Reform, including technical assistance materials, is available on the CalAIM BH Webpage. 

Member Experience​

How will Behavioral Health Administrative Integration improve the member experience?​

​DHCS-County Contracts​

How will the Department of Health Care Services (DHCS) navigate the differences in requirements and regulations between specialty mental health services (SMHS) and Drug Medi-Cal (DMC)/Drug Medi-Cal Organized Delivery System (DMC-ODS) programs in the integrated contract?​​

DHCS used the existing Mental Health Plan (MHP) contract boilerplate as a starting point for developing the integrated contract boilerplate and then modified and added content as necessary to capture all of the relevant requirements for DMC-ODS or DMC. Whereas the DMC-ODS/SMHS contract will be structured as a single Prepaid Inpatient Health Plan (PIHP) managed care program, DMC counties will continue to operate an SMHS PIHP and a non-managed-care DMC program. Certain portions of the integrated contract are identified as program-specific (e.g., medical necessity and service definitions) and those sections are generally copied directly from the current contracts for SMHS, DMC-ODS, and/or DMC.  For “integrated” sections of the contract that apply equally to both SMHS and DMC-ODS or DMC programs, DHCS has made modest adjustments as needed to align standards across programs. For DMC counties, certain SMHS managed care functions have been adjusted to require special attention to members with co-occurring behavioral health needs. ​

Does Behavioral Health Administrative Integration mean that counties need to restructure so that the mental health and substance use disorder systems are all under a single Behavioral Health department within the county?

No. Although counties (or regional groups of counties) will operate one integrated Medi-Cal behavioral health program from the perspective of state and federal law, counties may continue to structure their internal operations as they see fit. For example, some counties have opted to consolidate their behavioral health staff under a single county department, while other counties maintain separate departments (or divisions within a department) for specialty mental health and substance use disorder operations.

Will there be an annual spending limit specified in the integrated contracts, similar to the current approach for counties' DMC and DMC-ODS contracts? If not, will the removal of those annual limits affect State General Fund (SGF) contributions for, or any limits that may exist on, specific DMC or DMC-ODS services?

Currently, counties' DMC and DMC-ODS contracts contain an annual spending limit, which must be amended if actual spending exceeds projections.  By contrast, MHP contracts are “zero dollar" contracts with no limit.

The integrated behavioral health contracts will be “zero dollar" contracts with no specified limit, similar to the current approach for MHP contracts.  All eligible county claims will be paid in accordance with the contract and applicable law.

A “zero dollar" approach means there is no need for a fiscal amendment if overall spending under the contract is higher than expected. Implementing “zero dollar" does not modify SGF contributions for specific services (e.g., intensive outpatient and residential DMC-ODS services) and populations (e.g., ACA Optional Expansion).

For additional information on funding for various specialty behavioral health services and populations, please see the DMC, DMC-ODS, and Specialty Mental Health billing manuals available at https://www.dhcs.ca.gov/services/MH/Pages/MedCCC-Library.aspx.  Chapter 6 of the current DMC/DMC-ODS manuals contain detailed discussion of funding, including SGF contributions.​

Can the Department of Health Care Services (DHCS) provide additional clarification on the impact and operationalization of “zero dollar" contracts? Specifically, how will “zero dollar" contracts be operationalized between DHCS and counties, and how this could impact county contracts with community-based organizations (CBOs)?

A “zero dollar" approach means there is no need for a fiscal amendment if overall spending as part of the integrated contract is higher than expected. This approach avoids the administrative burden of contract amendments completed by counties and DHCS. The existing Mental Health Plan (MHP) contracts are already “zero dollar" with no issues. Therefore, DHCS does not anticipate any issues with the integrated contracts being zero-dollar. Furthermore, “zero dollar" financing should not have an impact on county contracts with CBOs. All eligible county and provider claims will continue to be paid in accordance with the contract and applicable law.

 Will early contract integration impact State General Funding (SGF)?

 California law specifies how existing funding streams for behavioral health may be used to support mental health and/or substance use disorder services. Implementation of integrated contracts does not modify SGF contributions for specific services and populations.

 Will Block Grant allocations be different for counties that integrate contracts early? If so, can details please be provided on how this will align with an integrated contract?

 Funding allocations and restrictions will not be modified or adjusted through CalAIM Behavioral Health Administrative Integration and will continue to necessitate dual processes for certain fiscal and accounting functions at the county level.​

 Under the integrated contracts, how will counties claim for expenses related to covered Medi-Cal services, quality assurance & utilization review (QA/UR), contract-related administrative activities, and Mental Health Medi-Cal Administrative Activities (MH MAA)?

• Covered Medi-Cal Services for Members. Under the integrated contract, providers will continue to bill Medi-Cal behavioral health services to the appropriate program SMHS, DMC, or DMC-ODS), and counties will continue to use program-specific codes when they submit claims to DHCS for expenses related to those covered services. Adopting an integrated contract under Behavioral Health Administrative Integration does not require counties to make any changes to provider reimbursement rates, nor to the financing approach for the county's share of Medi-Cal expenses.
• QA/UR and Contract-Related Administrative Activities. DHCS will implement integrated claiming for QA/UR and administrative activities. In each category, counties will report total eligible expenses under the integrated contract (although counties may continue to track program-specific subtotals for their own purposes if they so wish). Counties will be required to separately report expenditures that are eligible for state funding under Proposition 30.
• MH MAA. Counties will continue to claim reimbursement through the MH MAA claiming process in the same way they are currently claiming reimbursement.    

24/7 Access Line

For the integrated 24/7 access line, will the Department of Health Care Services (DHCS) require counties to use a local phone number, or can they use a toll-free number?

Under DHCS Behavioral Health Administrative Integration, counties with integrated contracts will operate an integrated 24/7 access line, meaning that members can call a single number to access information about both specialty mental health services (SMHS) and substance use disorder (SUD) services. For voluntary integration in 2025, DHCS is not currently proposing any other changes to access line requirements. Counties may continue to utilize a local phone number or a toll-free number for their integrated 24/7 access lines, consistent with current requirements, as long as they offer a single toll-free number for both SMHS and SUD services.​​​

​Does the integrated 24/7 access line need to be operated by the county, or can counties continue to utilize vendors/subcontractors?​

Counties with integrated contracts will be expected to operate a single, 24-hour access line for all Medi-Cal members seeking behavioral health services, so that they can be appropriately triaged and screened for both mental health and substance use disorder needs, and scheduled for appropriate follow-up appointments as part of the same call, without needing to hang up and dial any additional numbers. Counties may continue to utilize vendors/subcontractors to staff and operate their 24/7 toll free access line.​

​Data Sharing & Privacy​

Under integrated contracts, will 42 Code of Federal Regulations (CFR) Part 2 protections for substance use disorder (SUD) data apply to the entire Behavioral Health Plan (BHP)?​

1. The integrated Behavioral Health Plan (BHP) contract does not require the county's entire BHP to comply with 42 CFR Part 2 (“Part 2") protections for SUD data. Counties have the ability to designate a “Part 2 Component" within their integrated BHP, just as counties currently designate Part 2 and non-Part-2 Components within the overall county government. Only the Part 2 Component must comply with Part 2 requirements for patient consent, over and above baseline requirements under the Health Insurance Portability and Accountability Act (HIPAA) privacy rule.

   • Under an integrated BHP contract, the Part 2 Component must include, at a minimum, county-operated and county-employed SUD providers, and any others who meet the federal definition of a “Part 2 Program" (e.g., people or entities that hold themselves out as providing, and provide, SUD diagnosis, treatment, or referral for treatment.) See below for the complete definition. If a large provider offers a mix of SUD and non-SUD services, it may be possible to designate specific individuals or units within that provider in the Part 2 Component, without making the entire provider subject to Part 2.
   • At county option, counties could choose to include county SMHS providers in their Part 2 Component. Counties may wish to weigh factors such as the following:
   • Including SMHS providers in the Part 2 Component would facilitate data sharing among SMHS and SUD systems of care. This could eliminate the need for additional patient consents and firewalls in Electronic Health Records (EHRs) because Part 2 consent requirements do not apply to data sharing within a Part 2 Component for purposes of diagnosis, treatment, or referral for treatment.
   • Including SMHS providers in the Part 2 Component subjects them to Part 2 requirements when sharing data with individuals or entities outside the Part 2 Component.
   • The Part 2 Program definition does not include the administrative functions performed by health plans. Therefore, as counties decide which individuals, entities, and functions to include under their Part 2 Components, they are likely not required to include county staff activities that relate to administration of the Medi-Cal BHP (as opposed to activities performed by county-operated providers that relate to SUD diagnosis, treatment, or referral).
   • Part 2 governs the flow of information. Therefore, counties are not required to maintain physical separation between individuals and entities that are/aren't subject to Part 2, as long as the county has implemented appropriate firewalls to ensure that individuals outside the Part 2 Component are not able to access protected Part 2 information without the necessary member consent.
   • California Health and Safety Code (H&S) section 11845.5 still applies to SUD services that are not provided through Medi-Cal. Welfare and Institutions Code section 14184.102(j) exempts CalAIM from H&S 11845.5. CalAIM captures substantially all of Medi-Cal. ​
     
     

   Definition of a “Part 2 Program"

   Part 2 does not apply to all SUD information. Rather, Part 2 requirements apply to records that (1) reveal information about a patient's SUD conditions or treatment, and (2) are held by a “Part 2 Program." A Part 2 Program is defined as any of the following people/entities who receive federal funding (including Medicaid reimbursement):¹

   1. An individual or entity (other than a general medical facility) who holds itself out as providing and provides SUD diagnosis, treatment, or referral for treatment; or
   2. Within a general medical facility:
   1. An identified subunit that holds itself out as providing and provides SUD diagnosis, treatment, or referral; or
   2. Medical personnel or other staff in a general medical facility whose primary function is the provision of SUD diagnosis, treatment, or referral and who are identified as such providers. 
      
      According to Substance Abuse and Mental Health Services Administration (SAMHSA), a provider may “hold itself out" as providing SUD services if it, among other activities, obtains a state license specifically to provide SUD services, advertises SUD services, has a certification in addiction medicine, or posts statements on its website about the SUD services it provides.² 
      
      1 42 C.F.R. § 2.11
      
      ² SAMHSA, Substance Use and Confidentiality Regulations (October 27, 2023), https://www.samhsa.gov/about-us/who-we-are/laws-regulations/confidentiality-regulations-faqs
      

   ​
   

Under integrated contracts, will 42 Code of Federal Regulations (CFR) Part 2 data protections impact a county's ability to co-locate specialty mental health services (SMHS) and substance use disorder (SUD) programs?

Part 2 compliance focuses on flows of information, not physical barriers. Therefore, Part 2 does not prevent co-location of providers as long as minimum Part 2 requirements are met (e.g., firewalls between staff or electronic health record (EHR) systems that are/aren't part of the Part 2 Component).​

As counties implement Behavioral Health Administrative Integration, what resources can DHCS provide to support counties in maintaining compliance with 42 CFR Part 2 regulations around substance use disorder data privacy?​

​DHCS is committed to ensuring that behavioral health data are shared and stored as efficiently as possible while maintaining privacy protections for members, including the federal “Part 2" confidentiality rules for substance use disorder-related information. To support county programs and behavioral health providers in maintaining compliance with 42 CFR Part 2 and other privacy laws as they advance data sharing capabilities and practices, DHCS is exploring opportunities for developing a template “universal release" form (the ASCMI form, see question below) that can be used to obtain individual authorizations for data sharing, including sharing with MCPs and other service providers. DHCS will also consider other opportunities for guidance, and potentially shared learning or other technical assistance, throughout the implementation period.

How does the Authorization to Share Confidential Medi-Cal Information (ASCMI) Pilot currently underway align with Behavioral Health Administrative Integration?

DHCS is piloting the ASCMI Form in early 2023. The ASCMI form is a voluntary universal release of information that supports the sharing of Medi-Cal members' physical, mental, and social health information through a standard consent process and a consent management service, with an electronic platform to store and manage Medi-Cal members' consent. Providers will be able to access the consent management service online and/or via their existing electronic health record (her) system. Medi-Cal members will also be able to access the consent management service through the web to amend their consent. Lessons learned from the ASCMI pilot should enable more seamless data sharing under Behavioral Health Administrative Integration.

How does the Comprehensive Behavioral Health Data Systems Project align with Behavioral Health Administrative Integration?

The Comprehensive Behavioral Health Data Systems Project is intended to identify technology solutions to modernize and streamline data collection and reporting, analysis, and other data-related functions, and develop a consolidated reporting and analysis platform that integrates data from 12 existing behavioral health data systems. DHCS will coordinate internally and with stakeholders to ensure alignment between the implementation of the Comprehensive Behavioral Health Data Systems Project and Behavioral Health Administrative Integration.

Cultural Competence Plans​

Will counties receive templates or guidance to help develop consistent and impactful cultural competency plans?

Yes. DHCS is developing integrated Cultural Competence Plan templates for county use.

External Quality Reviews (EQR)​

How will External Quality Reviews (EQRs) work under integrated contracts?

Under integrated contracts, Drug Medi-Cal Organized Delivery System (DMC-ODS) counties will undergo a single, integrated EQR that addresses both Specialty Mental Health Services (SMHS) and DMC-ODS programs. Drug Medi-Cal (DMC) counties will continue to receive EQR solely for their SMHS activities.

​How will DHCS ensure that the integrated EQR process includes adequate focus on both mental health and substance use disorder priorities aren't lost in the aim to have an integrated EQR?

​Compliance Reviews (or "BH Audits")

What will counties' compliance reviews look like under Behavioral Health Administrative Integration?

As part of Behavioral Health Administrative Integration, DHCS will develop a streamlined compliance review for both SMHS and SUD. Adopting integrated reviews will be one of several policy changes that DHCS will implement to restructure and refocus SMHS and DMC/DMC-ODS compliance reviews (or “BH audits") to support CalAIM goals. DHCS will continue to release guidance on these policy updates and will seek feedback on options for streamlining or integrating compliance monitoring during stakeholder engagement for BH Administrative Integration.

How will Behavioral Health (BH) audits work under integrated contracts in terms of structure and frequency?

Counties with integrated contracts will receive an annual integrated BH audit that assesses compliance with the integrated contract, including the elements specific to specialty mental health services (SMHS) and substance use disorder (SUD) services. This integrated process will apply to both Drug Medi-Cal Organized Delivery System (DMC-ODS) and Drug Medi-Cal (DMC) counties and will continue to follow the state fiscal year (SFY) in terms of both scheduling and review periods. Integrated BH audits will follow the systemic approach that is county-specific as described in BHIN 23-044.​

Will the integrated Behavioral Health (BH) audits include a review of Substance Use Prevention, Treatment and Recovery Services Block Grant (SUBG) services in addition to Specialty Mental Health Services (SMHS) and Drug Medi-Cal (DMC)/Drug Medi-Cal Organized Delivery System (DMC-ODS) services?

How will integrated network adequacy certifications work?  Will the Department of Health Care Services (DHCS) require counties to submit both the annual Network Adequacy Certification Tool (NACT) and timely access data in addition to the monthly 274 Electronic Data Interchange (274 standard) provider network data?

For counties with integrated contracts, DHCS will conduct annual network adequacy certification through a single, integrated reporting process. Counties will complete a single, integrated submission for network adequacy (using the 274 standard described in BHIN 23-042) and timely access reporting. These submissions will continue to follow the state fiscal year (SFY). For voluntary integration in 2025, DHCS is not currently proposing any substantive changes to the standards for network adequacy or timely access. 

Will the Department of Health Care Services (DHCS) adjust or change the methodology used to evaluate network adequacy under integrated contracts?

DHCS will not change the methodology used to determine network adequacy compliance for Drug Medi-Cal Organized Delivery System (DMC-ODS) counties that voluntarily choose to implement integrated contracts effective January 1, 2025. DHCS is open to feedback from counties and other stakeholders on the merits of potential substantive revisions to the network adequacy standards currently outlined in BHIN 23-041​, such as aligning the capacity methodologies across specialty mental health services (SMHS) and substance use disorder (SUD) services, as well as additional alignment with the network adequacy methodologies for Medi-Cal managed care plans.​​​

If counties do not meet network adequacy requirements, will the Department of Health Care Services (DHCS) issue Corrective Action Plans (CAPs)? Will reporting and potential CAPs be singular, or will one be required for both the Mental Health Plan (MHP) and Drug Medi-Cal Organized Delivery System (DMC-ODS) separately?

For counties with integrated contracts that do not meet compliance with one or more network adequacy requirements, DHCS will approve a single, integrated CAP that addresses deficiencies for both specialty mental health services (SMHS) and substance use disorder (SUD) programs, as applicable. Depending on the approved CAP, DHCS may require subsequent submission(s) of additional documentation to demonstrate compliance. The county will remain on a CAP until all deficiencies are cleared. 

If a Drug Medi-Cal Organized Delivery System (DMC-ODS) county has not fully implemented monthly 274 Electronic Data Interchange (274 standard) provider network data submissions, would that exclude them from participating in Phase 2 voluntary contract integration?

DMC-ODS counties participating in Phase 2 voluntary contract integration will be expected to submit monthly 274 Electronic Data Interchange (274 standard) provider network data for both specialty mental health (SMHS) and DMC-ODS programs starting January 1, 2025. If the county is working through implementation challenges but anticipates being ready by 2025, then the county would be eligible for participation in Phase 2 contract integration. If the county is unable to submit monthly 274 data as of 2025, that would exclude the county from participating in Phase 2.

​The Department of Health Care Services (DHCS) specified that early implementer workgroup counties must fulfill all Drug Medi-Cal Organized Delivery System (DMC-ODS) and specialty mental health services (SMHS) 274 requirements to opt into an integrated contract. Does this mean that counties should have error-free data submissions for both plans?

Counties participating in early voluntary contract integration will be expected to submit monthly 274 Electronic Data Interchange (274 standard) provider network data for both specialty mental health services (SMHS) and DMC-ODS programs starting January 1, 2025. If the county is working through implementation challenges (such as significant data errors) but anticipates being ready by January 1, 2025, the county would be eligible for participation in early contract integration. If the county is unable to submit monthly 274 data as of January 1, 2025, the county would be excluded from participating in early voluntary contract integration effective January 1, 2025.

​How will DHCS ensure that the new Network Adequacy process still ensures adequate focus on both substance use disorder and mental health priorities?

When counties adopt integrated contracts under Behavioral Health Administrative Integration, they will remain subject to the same network adequacy standards that govern existing Mental Health Plans and DMC-ODS programs, which require that plans have a sufficient and robust network of, respectively, mental health or substance use disorder providers. Existing network adequacy methodologies incorporate estimated mental health and substance use disorder prevalence rates in their evaluation of network capacities. DHCS will work with stakeholders to monitor concerns to ensure mental health and substance use disorder services retain adequate networks while also enabling the provision of treatment for co-occurring conditions.

Provider Oversight​​​

How will Behavioral Health Administrative Integration impact providers?

This initiative will not mandate changes in care models at the provider level, and providers will still be able to choose whether to offer SMHS, DMC/DMC-ODS services, or both. DHCS anticipates that the administrative simplifications implemented as part of this initiative will create efficiencies for providers that can make it easier to participate in both SMH and DMC/DMC-ODS programs and offer co-occurring specialty behavioral health services if a provider chooses to do so.​​

How will Behavioral Health Administrative Integration impact auditing or monitoring for Medi-Cal programs providers contracted with specialty mental health services (SMHS) and substance use disorder (SUD) programs?

Under existing contracts, Drug Medi-Cal Organized Delivery System (DMC-ODS) and Drug Medi-Cal (DMC) programs – but not Mental Health Plans (MHPs) – are required to perform annual on-site review of their contracted providers. Under integrated contracts, counties will be required to do the following for all contracted providers across all delivery systems (except for out-of-network providers serving specialty mental health services (SMHS) or DMC-ODS members):

• Perform annual compliance review (desk or on-site)
• Perform on-site compliance review at least once every 3 years for organizational providers (but not for individual SMHS practitioners who contract directly with the county)
• Submit a copy of monitoring and audit reports to DHCS within two weeks of issuance
• Comply with standardized procedures for:
• Counties Corrective Ac​tion Plan (CAP) procedures for provider deficiencies (based largely on current DMC-ODS/DMC procedures)
• For SUD providers, California Outcomes Measurement System (CalOMS) and Drug and Alcohol Treatment Access Report (DATAR) requirements (now standardized across DMC and DMC-ODS programs).​
  

To meet provider oversight requirements, can counties accept Specialty Mental Health Services (SMHS) compliance reviews completed by another county?

Yes. Under the integrated contract, counties must conduct annual compliance reviews and triennial on-site reviews for most network providers. Currently, for Drug Medi-Cal (DMC) providers, counties are able to accept a compliance review conducted by another county. This avoids duplicative reviews for providers that participate in multiple counties' Medi-Cal programs. DHCS is extending this same flexibility to SMHS provider reviews: a county may accept a compliance review completed by another county for a SMHS provider contracted with both counties. DHCS will clarify this policy in a future amendment to the integrated contract.​​

Standards for Specific Behavioral Health Provider Types and Services

​What is a Clinical Trainee?​

Supplements 3 and 7 to Attachment 3.1-A of the Medicaid State Plan defines Clinical Trainee as an unlicensed individual who is enrolled in a post-secondary educational program that is required for the individual to obtain licensure as a Licensed Mental Health Professional or Licensed Practitioner of the Healing Arts; is participating in a practicum, clerkship, or internship approved by the individual’s program; and meets all relevant requirements of the program and/or applicable licensing board to participate in the practicum, clerkship or internship and provides rehabilitative mental health services or substance use disorder treatment services, including, but not limited to, all coursework and supervised practice requirements. 

Can Clinical Trainees on leave of absence from their program provide specialty behavioral health services?   

Clinical Trainees who are on leave of absence from their program may be reimbursed for providing Medi-Cal specialty behavioral health services if the following conditions are met: 

• They are still enrolled in a post-secondary educational program, such as those offered by a university, community college, or vocational school, that is required for the individual to obtain licensure as a Licensed Mental Health Professional (LMHP) or Licensed Practitioner of the Healing Arts (LPHA) 
• ​They are providing services as part of a practicum, clerkship, or internship approved by the individual’s program; and  
• They meet all relevant program requirements and/or applicable licensing board requirements to participate in the practicum, clerkship, or internship, including all coursework and supervised practice requirements. ​​

​Please refer to Supplements 3 and 7 to Attachment 3.1-A of the Medicaid State Plan and Behavioral Health Information Notice (BHIN) 24-023 for additional information on Clinical Trainees. 

Can individuals who are working towards Clinical Social Worker (CSW), Marriage and Family Therapist (MFT), or Professional Clinical Counselor (PCC) licensure provide specialty behavioral health services while their associate application is pending?  

Yes. Behavioral Health Information Notice (BHIN) 24-023 clarifies that behavioral health plans may allow CSW, MFT, and PCC candidates who have graduated from a master’s program to provide and bill for specialty behavioral health services as an Associate CSW, Associate MFT, or Associate PCC if they have submitted their application for associate registration to the California Board of Behavioral Sciences (BBS) within 90-days of their degree award date and are completing supervised experience toward licensure. Department of Health Care Services (DHCS) will reimburse for services rendered while their BBS application is pending, regardless of the number of days it takes for BBS to approve the application. 

Please refer to Business and Professions Code (BPC) for CSWs (BPC 4996.23), MFTs (BPC 4980.43), and PCCs (BPC 4999.46), as well as guidance published by BBS for additional information regarding requirements of the “90 Day Rule.” 

Are county behavioral health plans (BHPs) required to allow Clinical Trainees or Clinical Social Worker (CSW), Marriage and Family Therapist (MFT), or Professional Clinical Counselor (PCC) candidates to provide specialty behavioral health services? ​​​

Department of Health Care Services (DHCS) encourages county behavioral health plans (BHPs) to utilize provider types that meet the needs of their Medi-Cal members. DHCS allows counties to use Clinical Trainees and individuals who have submitted their application for associate registration to the Board of Behavioral Sciences (BBS) within 90-days of their degree award date to provide certain Specialty Mental Health Services (SMHS) and Drug Medi-Cal-Organized Delivery System (DMC-ODS) services as outlined in Behavioral Health Information Notice (BHIN) 24-023. DHCS does not require counties to use Clinical Trainees or individuals who are in the process of registration but have not yet received confirmation of associate registration from BBS. BHPs have discretion to determine their provider networks and specify contract terms.  

Please refer to Supplements 3 and 7 to Attachment 3.1-A of the Medicaid State Plan and BHIN 24-023 for additional information on Clinical Trainees and individuals who are in the process of obtaining their associate registration through BBS. 

​What is the difference between Licensed Mental Health Professional (LMHP) and Licensed Practitioner of the Healing Arts (LPHA)? 

​Use of Licensed Mental Health Professional (LMHP) and Licensed Practitioner of the Healing Arts (LPHA) varies by behavioral health delivery system.  ​

LMHP is a term used in the Specialty Mental Health (SMH) delivery system to identify a select group of provider types that provide rehabilitative mental health services. An LMHP includes the following providers:  

• Licensed Physicians
  
• Licensed Psychologists (includes Waivered Psychologists),  
• Licensed Clinical Social Workers (includes Waivered or Registered Clinical Social Workers),  
  
• Licensed Professional Clinical Counselors (includes Waivered or Registered Professional Clinical Counselors),  
• Licensed Marriage and Family Therapists (includes Waivered or Registered Marriage and Family Therapists), 
• Registered Nurses (includes Certified Nurse Specialists and Nurse Practitioners), 
• Licensed Vocational Nurses,   
  
• Licensed Psychiatric Technicians, and  
• Licensed Occupational Therapists. 
  

LPHA is a term used in the Drug Medi-Cal (DMC) and Drug Medi-Cal Organized Delivery System (DMC-ODS) to identify a select group of provider types that provide substance use disorder (SUD) and expanded SUD treatment services, respectively. An LPHA includes the following providers: 

• Physician, 
• ​Nurse Practitioner,
• Physician Assistant,
• Registered Nurse,  
• Registered Pharmacist,
• Licensed Clinical Psychologist,  
• Licensed or Registered Clinical Social Worker, 
• Licensed or Registered Professional Clinical Counselor, 
• ​Licensed or Registered Marriage and Family Therapist,
• Licensed Vocational Nurse, 
• Licensed Occupational Therapist, and  
  
• Licensed Psychiatric Technician. 
  

Please refer to Supplements 3 and 7 to Attachment 3.1-A of the Medicaid State Plan for additional information on LMHPs and LPHAs.  

When does the “90 Day Rule” begin for Clinical Social Worker (CSW), Marriage and Family Therapist (MFT), and Professional Clinical Counselor (PCC) candidates?  

The “90 Day Rule” set by the California Board of Behavioral Sciences (BBS) allows candidates to count supervised experience toward licensure when gained during the window of time between the degree award date and the issue date of the associate registration number. To be eligible for the 90 Day Rule, a Clinical Social Worker (CSW), Marriage Family Therapist (MFT), or Professional Clinical Counselor (PCC) candidate must submit their application for associate registration to the BBS within 90-days of their degree award date. Degree award date may vary by educational program but is typically defined as the final day of the term in which the student completes all requirements to graduate from their program.  

Please refer to Business and Professions Code (BPC) for CSWs (BPC 4996.23), MFTs (BPC 4980.43), and PCCs (BPC 4999.46), as well as guidance published by BBS for additional information regarding requirements of the “90 Day Rule.” ​​