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CalAIM Behavioral Health Initiative Frequently Asked Questions 

CalAIM Behavioral Health Initiative

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CalAIM is a multi-year initiative by DHCS to improve the quality of life and health outcomes of our population by implementing a broad delivery system, program and payment reform across the Medi-Cal program. 

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Frequently Asked Questions

DHCS remains committed to assisting stakeholders with the implementation of CalAIM initiatives, which include Criteria for Member Access to Specialty Mental Health Services (SMHS), Code Selection During the Assessment Period Drug Medi-Cal Organized Delivery System (DMC-ODS), Documentation Redesign, and No Wrong Door for Mental Health Services Policy. Below is a list of frequently asked questions that have been collected from technical assistance and informational webinars and submissions to the BHCalAIM@dhcs.ca.gov email. DHCS will update this list on a quarterly basis. 

Collateral

Since family psychotherapy without the patient present (CPT code 90846) can be reported in the Drug Medi-Cal (DMC) Organized Delivery System, should it also be reported in the Specialty Mental Health (SMHS) delivery system?
Can Multiple-Family Group Psychotherapy (CPT code 90849) be used to report a family therapy session when the member is not present in the DMC-ODS delivery system? 
Can counties use HCPCS code H0007 (alcohol and/or drug services; crisis intervention) to report collateral contacts as part of crisis intervention in the DMC-ODS delivery system?
Can counties use HCPCS code H0032 (mental health service plan developed by non-physician) to report a collateral contact in the SMHS delivery system?
Can counties use HCPCS code H0034 (medication training and support) to report collateral contacts in the DMC-ODS and SMHS delivery systems? 
Do HCPCS codes H0038 and H0025 (Peer Support Services) include collateral contacts?
Does Rehabilitation and Recovery include collateral contacts in the SMHS and DMC-ODS delivery systems respectively, and can counties use HCPCS code H2017 to describe those contacts?
Can HCPCS H2021 (Community-based Wrap-around service) be used to describe collateral contacts when the member is not present?
Can Therapeutic Behavioral Services, described by HCPCS code H2019, include collateral to individuals who are not the member’s biological family?
Can an outpatient collateral contact be reported in addition to a Therapeutic Foster Care (TFC) service?
Does targeted case management (HCPCS code T1017) include collateral contacts?
Does the member need to be present when Targeted Case Management (HCPCS code T1017) is provided?
Can a county report H2035 (alcohol and/or other drug treatment service) and, in addition, separately report a collateral service?

Criteria for Member Access to Specialty Mental Health Services (SMHS)

Is a mental health diagnosis required for access to covered SMHS?
How long can SMHS be provided prior to a member receiving a mental health diagnosis?
For members who begin specialty mental health services with Z codes, will they eventually require a mental health diagnosis, or can Z codes be the only diagnosis that is submitted for reimbursement? Can a Z code be the primary diagnosis?
(Added March 2026) What does DHCS mean by “scoring in the high-risk range under a trauma screening tool approved by the department”?
(Added March 2026) Are DHCS-approved youth trauma screening tools required to establish whether a member meets access criteria to the SMHS delivery system?
Which youth trauma screening tools have been approved by DHCS?
(Added March 2026) In what settings may a DHCS-approved youth trauma screening tool be used?
(Added March 2026) Which DHCS-approved youth trauma screening tools included in Enclosure 1 are Medi-Cal reimbursable? Which tools are free to use?
(Added March 2026) How does this access criteria to SMHS policy relate to other policies like the Screening and Transition of Care Tools?
Can a SMHS provider submit a claim for a SMHS provided to a member who also has a substance use disorder (SUD) diagnosis?
How do providers ensure members with a co-occurring substance use disorder (SUD) are referred appropriately to access SUD services?

Drug Medi-Cal Organized Delivery System (DMC-ODS) Policy Improvements

Can Clinician Consultations occur between licensed agency staff within the same agency, or must this consultation occur between licensed agency staff and external consultants that are contracted by the county?
How are Clinician Consultation services billed under Drug Medi-Cal Organized Delivery System (DMC-ODS)?
Is the consultation between a Licensed Professional of the Healing Arts (LPHA) and a Licensed Professional Clinical Counselor (LPCC) for determination of diagnosis and medical necessity billable using assessment codes?
When would a Residential Treatment Services provider bill for Recovery Services under Drug Medi-Cal Organized Delivery System (DMC-ODS)?
How should a provider bill for the Residential Treatment Services bundled rate for a day in which no residential covered services were provided on the date of the claim?
Can the Brief Questionnaire for Initial Placement (BQuIP) tool be used to complete the multidimensional level of care (LOC) assessment?
Can Z-codes be used as the primary diagnosis for Drug Medi-Cal Organized Delivery System (DMC-ODS) services?
What type of assessment is required when authorizing Drug Medi-Cal Organized Delivery System (DMC-ODS) clients for American Society of Addiction Medicine (ASAM) 3.1 and 3.5 Levels of Care?
Is prior authorization required for Drug Medi-Cal Organized Delivery System (DMC-ODS) Residential Treatment and Inpatient Services?
Is a comprehensive American Society of Addiction Medicine (ASAM) Criteria assessment required for members to receive Recovery Services?
What are the length of stay requirements for Medi-Cal members in residential substance use disorder (SUD) treatment programs? Do these requirements differ for pregnant and postpartum members?
If a member is stepping down from residential to outpatient Drug Medi-Cal Organized Delivery System (DMC-ODS) services, can the outpatient provider and the residential provider bill for Care Coordination while the member is still technically enrolled in residential services?
For Drug Medi-Cal Organized Delivery System (DMC-ODS), are discharge plans and discharge summaries still required?
Can homelessness be a justification for extending substance use disorder (SUD) treatment or even increased level of care (LOC)?
Can the requirement to offer naloxone at a Narcotic Treatment Program (NTP) / Opioid Treatment Program (OTP) be met by offering a form of buprenorphine (Suboxone®) that contains both buprenorphine and naloxone?
How should a provider bill for Narcotic Treatment Program (NTP) dosing when a member temporarily receives services in a county that they do not reside in, and the member’s home NTP does not have a contract with that county? – September 17, 2024
How can Drug Medi-Cal Organized Delivery System (DMC-ODS) providers leverage Medi-Cal for prescribing and dispensing naloxone to patients?
How can Medi-Cal members access Medications for Addiction Treatment (MAT)?
How are collateral services covered under Drug Medi-Cal Organized Delivery System (DMC-ODS)?
To offer partial hospitalization services through the Drug Medi-Cal Organized Delivery System (DMC-ODS) program, what certification requirements must be met by the DMC-ODS plan?
What are the Drug Medi-Cal Organized Delivery System (DMC-ODS) plan documentation requirements relating to grievances?
What are the Drug Medi-Cal Organized Delivery System (DMC-ODS) plan requirements for appeals?
What are the Drug Medi-Cal Organized Delivery System (DMC-ODS) plan requirements and timeframes for State Hearings?
Where can Drug Medi-Cal Organized Delivery System (DMC-ODS) plans and providers find guidance on Notice of Adverse Benefit Determination (NOABD) grievance and appeals requirements?
What grievance and appeal information must be in the Drug Medi-Cal Organized Delivery System (DMC-ODS) plan’s Quality Improvement (QI) Plan?
If a Drug Medi-Cal Organized Delivery System (DMC-ODS) plan has an integrated behavioral health department, can it use the same Quality Improvement (QI) Committee required by the Mental Health Plan contract to fulfill the DMC-ODS QI Committee requirements?
Are student interns or trainees considered Licensed Practitioners of the Healing Arts (LPHAs)?
Can a non-perinatal provider serve a pregnant Drug Medi-Cal Organized Delivery System (DMC-ODS) member? What is the process to claim for these services?
How is billing for Drug Medi-Cal Organized Delivery System (DMC-ODS) group counseling services calculated?
Can you submit a claim for a member’s “room and board” during residential treatment if the member received no residential treatment covered services on the date of service for the claim?
Are revenues other than 2011 realignment funds eligible for federal match?

Behavioral Health Documentation Requirements for DMC, DMC-ODS, & SMHS

Assessments

Can the American Society of Addiction Medicine (ASAM) Criteria® be used to assess youth and adolescents? Is there an approved ASAM assessment tool for youth and adolescents? 
Will the Department of Health Care Services (DHCS) approve additional American Society of Addiction Medicine (ASAM) assessment tools? 
Will the American Society of Addiction Medicine (ASAM) Criteria updates be reflected in future Department of Health Care Services (DHCS) guidance? 
BHIN 23-054 specifies that a Medications for Addictions Treatment (MAT) assessment must be provided within 24 hours of admission to a licensed and/or certified substance use disorder recovery or treatment facility. How does that guidance align with BHIN 23-068, which eliminates the previous 30/60 timeframe for completing ASAM Level of Care assessments? 
Part 1 Page 4 of Behavioral Health Information Notice (BHIN) 23-068 discusses existing guidance on Department of Health Care Services (DHCS) Level of Care (LOC) designations that requires providers of residential treatment services to ensure members receive multidimensional level of care assessments. Are these requirements new? Are they duplicative of the comprehensive ASAM assessment requirements described in BHIN 23-068? 
Part 2 Does this mean that two different assessments are required? Should residential providers instead be required to complete the comprehensive ASAM within 72 hours? 
Are seven-domain assessments as specified in Behavioral Health Information Notice (BHIN) 23-068 required for Specialty Mental Health Services (SMHS) crisis intervention or crisis stabilization services? What about Specialty Mental Health Services (SMHS) or Drug Medi-Cal (DMC)/Drug Medi-Cal Organized Delivery System (DMC-ODS) mobile crisis services?
Do the changes to assessment timelines for Specialty Mental Health Services impact Child and Adolescent Needs and Strengths (CANS) assessment and Pediatric Symptom Checklist (PSC)-35 requirements? What about the Adult Needs and Strengths Assessment (ANSA) (for adults)?
If a Mental Health Plan (MHP) has a current assessment template within their electronic health record that captures all seven (7) Specialty Mental Health Services (SMHS) assessment domains, will the MHP be required to re-structure their assessment, so it is categorized by the new domains?
Are the seven (7) domains for a Specialty Mental Health Services assessment required for psychiatric diagnostic evaluations?
Should providers document a reason for taking more time than usual to complete an assessment?

Care Plans

Problem Lists

Progress Notes

How should a provider document a progress note for a member who is receiving more than one service activity during a single service encounter? 
Historically, stakeholders have raised concerns regarding burdensome requirements for progress note documentation. What sources did the Department of Health Care Services (DHCS) review to ensure DHCS’ progress note documentation requirements outlined in Behavioral Health Information Notice (BHIN) 23-068 align with current industry standards? 
How should progress notes be completed for group services if two providers conduct the group session? 
Do digital signatures meet the signature requirements for completing progress notes? 
Will the Department of Health Care Services (DHCS) be adjusting the progress note timeframes outlined in Behavioral Health Information Notice (BHIN) 23-068? How does this timeframe apply when notes are completed by providers practicing under supervision?
How do the progress note requirements in Behavioral Health Information Notice (BHIN) 23-068 apply to bundled services such as per diem rates for residential treatment?
How should providers document a group service if it is provided as a component of a bundled service? For example, members receiving residential treatment may participate in group services as well as other services or activities during the course of a single day.
Can a group participant list substitute for an individual group progress note in the member record?
Are the progress note requirements stated in Behavioral Health Information Notice (BHIN) 23-068 what is minimally required by DHCS?
Do progress notes need to include the Diagnostic and Statistical Manual of Mental Disorders (DSM–5) descriptor in addition to the International Classification of Diseases, Tenth Revision (ICD-10) code?
Are member signatures required for group service progress notes?

Service, Program, & Facility Requirements

Other

How are “business days” defined under Section (d)(5) on page 10 of BHIN 23-068? – December 3, 2024
Do I still need to follow documentation requirements for specific Healthcare Common Procedure Coding System (HCPCS)/Current Procedural Terminology® (CPT) codes, such as Evaluation and Management (E/M) CPT codes? 
Is the justification for continuing services still a requirement for substance use disorder (SUD) services still in effect? 
Are physical exams required for outpatient and residential substance use disorder (SUD) programs?
Are member sign in sheets required for group services? What about member signatures? 
Why are Narcotic Treatment Programs (NTPs) exempt from the guidance in Behavioral Health Information Notice 23-068?
Have the requirements for medication consents changed? This section was removed from the Specialty Mental Health Services (SMHS) Triennial Protocol and the Mental Health Plan (MHP) Contract and Behavioral Health Information Notice (BHIN) 23-068 doesn’t touch on medication consent requirements. 
If Mental Health Plan (MHP) providers can now deliver co-occurring treatment and focus on a member’s substance use disorder (SUD) needs as clinically appropriate, does that mean the member’s clinical record with the MHP will now be governed by 42 CFR Part 2?
Are Medicare requirements being taken into consideration since counties must bill to Medicare first? Do members who have Medicare and Medi-Cal need treatment plans?
To reduce documentation time, is it acceptable to use checkboxes except where “narrative” is required?
(Added December 2022) Is there still a Drug Medi-Cal Organized Delivery System (DMC-ODS) requirement to document the diagnosis as a narrative summary based on the Diagnostic and Statistical Manual of Mental Disorders (DSM-)5 criteria?
How may providers document the member’s involvement in the treatment process?

No Wrong Door & Co-Occurring Treatment

Standardized Screening and Transition Tools

(Added February 2023) Why are Screening and Transition of Care Tools for Medi-Cal Mental Health Services being implemented?
(Added February 2023) What is the purpose of the Adult and Youth Screening Tools for Medi-Cal Mental Health Services?
(Added February 2023) Are the Screening Tools intended to function as assessments to determine medically necessary services?
(Added February 2023) Do the Screening Tools address substance use disorder service needs?
(Added February 2023) What is the purpose of the Transition of Care Tool for Medi-Cal Mental Health Services?
(Added February 2023) Is the Transition of Care Tool intended to function as an assessment to determine medically necessary services?
(Added February 2023) Are the Screening Tools and Transition of Care Tool intended to be used together?
(Added May 2023) Will DHCS make updates to the tools? If so, when?
(Added February 2023) Who is required to use the Screening Tools?
(Added February 2023) Are MCPs and MHPs required to use the Screening Tools with everyone who contacts them for any purpose?
(Updated July 2023) Are the Screening Tools required when individuals are referred by a provider to an MCP for NSMHS or an MHP for SMHS?
(Added July 2023) Are MCPs/MHPs required to use the Screening and Transition of Care Tools with uninsured and/or privately insured individuals?
(Added February 2023) Who is required to use the Transition of Care Tool?
(Added July 2023) Who can determine if an individual that is currently receiving mental health services covered by either the MCP or MHP needs to receive additional services covered by the other Medi-Cal mental health delivery system (i.e., MCP or MHP) or needs to have their care transitioned to the other Medi-Cal mental health delivery system (i.e., MCP or MHP)?
(Added May 2023) How will providers know if they are supposed to use the Transition of Care Tool?
(Added February 2023) Is the Transition of Care Tool required for use when an individual is being referred within the same delivery system?
(Added May 2023) Is the Transition of Care Tool required if an individual screens into the MCP or MHP but their clinical assessment indicates that they belong in the other system?
(Added February 2023) Can questions/fields be added to the Screening and Transition of Care Tools and/or can the tools be integrated with existing tools?
(Added May 2023) Can additional demographic fields be added to the Screening Tools?
(Added May 2023) Can additional information be provided as notes or attachments to the Screening Tools?
(Added February 2023) Are those administering the Screening Tools able to deviate from the specific wording if they are asked to clarify a question?
(Added February 2023) Is deviation from the specific wording in the Screening Tools allowable as part of translation?
(Added May 2023) When an individual answers yes to questions 6, 7, or 9 on the Youth Screening Tool, why do the instructions require the screener to stop the screening? Can the screener still ask the remaining screening questions?
(Added February 2023) Are MCPs and MHPs required to build the Screening and Transition of Care Tools into their electronic health record systems?
(Added July 2023) How should MHPs claim for activities completed as part of Screening and Transition of Care Tools?
(Added February 2023) What does the Screening Tools score determine?
(Added May 2023) If an individual has a total screening score of “0” does that mean they do not require mental health services in either delivery system?
(Added February 2023) What if the person administering the Screening Tool disagrees with the screening score? Are MCPs and MHPs required to adhere to the delivery system referral indicated by the screening score?
(Added February 2023) Is there a scoring methodology for the Transition of Care Tool?
(Added July 2023) Are MCPs/MHPs required to issue a Notice of Action (NOA)/Notice of Adverse Benefit Determination (NOABD) if an individual is referred to the other Medi-Cal mental health delivery system based on their screening score?
(Added July 2023) What should MCPs/MHPs do if an individual declines the referral based on their screening score?
(Added February 2023) Are MCPs and MHPs allowed to re-screen individuals if they feel they were not scored appropriately?
(Added February 2023) How soon after receiving a referral from the other delivery system must MCPs and MHPs offer an appointment for clinical assessment?
(Added February 2023) What if an individual is referred to the MCP or MHP based on their screening score, but their subsequent clinical assessment indicates that they belong in the other delivery system?
(Added July 2023) What should MCPs/MHPs do if they are having difficulty making contact with an individual who has been referred for MCP or MHP services?
(Added February 2023) Will DHCS be providing translated versions of the Screening Tools?
(Added February 2023) Are there reporting requirements for the Screening and Transition of Care Tools?
(Added February 2023) How do the Screening Tools align with No Wrong Door policy?

Behavioral Health Payment Reform

Behavioral Health Administrative Integration

(Added May 2023) Can DHCS provide more detail on the proposal to align integrated DHCS-County contracts with the Calendar Year as opposed to the Fiscal Year?
(Added May 2023) How will DHCS support counties to achieve compliance with Behavioral Health Administrative Integration by January 1, 2027?
(Added May 2023) What are the benefits for counties that volunteer for early contract integration?
(Added May 2023) What will Behavioral Health Administrative Integration look like for counties that do not volunteer for early contract integration?
(Added May 2023) What will Behavioral Health Administrative Integration look like for Drug Medi-Cal (DMC) counties?
(Added May 2023) How will Behavioral Health Administrative Integration be implemented for counties who are in the Drug Medi-Cal-Organized Delivery System (DMC-ODS) Regional Model?
(Added May 2023) Will Behavioral Health Administrative Integration require integrated Memoranda of Understanding (MOU) between MCPs and Behavioral Health Plans?
(Added May 2023) How does Behavioral Health Administrative Integration align with other CalAIM policy reforms like No Wrong Door, Documentation Redesign, and Standardized Screening and Transition Tools?
(Added May 2023) How will payment work with Behavioral Health Administrative Integration?
(Added May 2023) How will Behavioral Health Administrative Integration improve the member experience?
(Added May 2023) 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?
(Added May 2023) 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?
(Added May 2023) How does the Authorization to Share Confidential Medi-Cal Information (ASCMI) Pilot currently underway align with Behavioral Health Administrative Integration?
(Added May 2023) How does the Comprehensive Behavioral Health Data Systems Project align with Behavioral Health Administrative Integration?
(Added May 2023) Will counties receive templates or guidance to help develop consistent and impactful cultural competency plans?
(Added May 2023) 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?
(Added May 2023) What will counties’ compliance reviews look like under Behavioral Health Administrative Integration?
(Added May 2023) How will DHCS ensure that the new Network Adequacy process still ensures adequate focus on both substance use disorder and mental health priorities?
(Added May 2023) How will Behavioral Health Administrative Integration impact providers?
(Added November 2023) Does the integrated 24/7 access line need to be operated by the county, or can counties continue to utilize vendors/subcontractors?
(Added November 2023) What does each phase of Behavioral Health Administrative Integration entail?
(Added November 2023) 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?
(Added November 2023) 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)?
(Added April 2024) 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?
(Added April 2024) 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?
(Added April 2024) How will External Quality Reviews (EQRs) work under integrated contracts?
(Added April 2024) How will Behavioral Health (BH) audits work under integrated contracts in terms of structure and frequency?
(Added April 2024) 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?
(Added April 2024) 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?
(Added April 2024) 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?
(Added April 2024) Will the Department of Health Care Services (DHCS) adjust or change the methodology used to evaluate network adequacy under integrated contracts?

Coding During Assessment

Compliance

Claiming

Memorandum of Understanding (MOU)