Below are the answers to most of the questions that the Department of Health Care Services (DHCS) received during the stakeholder hearing on March 14th. If you do not see an answer to your question, please send an email to the appropriate email address(es) listed below:
Reporting Individuals, Roster Template, and National Provider Identifier (NPI)
1. Will DHCS require all three tiers of QAS behavioral health treatment providers (i.e., providers, professionals, and paraprofessionals) to enroll with the Provider Application and Validation for Enrollment (PAVE) or is the requirement solely for the provider organization and individuals are linked to the organization via a roster, unless a sole proprietor?
QAS provider organizations and individuals (referred to as QAS applicants) must report all QAS providers, QAS professionals, and QAS paraprofessionals to the DHCS in their enrollment application and must also attest that all QAS providers, QAS professionals, and QAS paraprofessionals for whom they will bill meet the qualifications and follow supervision requirements listed in accordance with the State Plan for Behavioral Health Treatment Services. The QAS applicant must report the NPI, first and last name, and any applicable professional license number or certification number or registration number of the individuals providing behavioral health treatment services. These individuals are not required to separately enroll.
2. If we setup as an organization, we do not have to register each individual, but attest that our QAS providers, professionals, and paraprofessionals meet the qualifications, and our documentation may be subject to audit. Is that correct?
Yes, QAS provider organizations and individuals (referred to as QAS applicants) must report all QAS providers, QAS professionals, and QAS paraprofessionals to the DHCS and must also attest that all QAS providers, QAS professionals, and QAS paraprofessionals for whom they will bill meet the qualifications and follow supervision requirements listed in accordance with the State Plan* for Behavioral Health Treatment Services. Additionally, the QAS applicant must attest that they understand that DHCS may audit to verify the QAS provider, QAS professional, and QAS paraprofessional qualifications and the services provided, and that the QAS organization or individual provider must supply documentation upon request of DHCS. This attestation does not supersede any of DHCS' authority to audit or request records from the provider pursuant to state and federal law and the provider agreement.
3. Is there any roster and attestation process for large providers that have hundreds of Board Certified Behavior Analysts (BCBAs) and Registered Behavior Technicians (RBTs) or do we have to manually enter each one in PAVE?
The attestation and reporting of individuals providing behavioral health treatment services will occur as part of the enrollment application via the PAVE portal. The QAS applicant must report the NPI, first and last name, and any applicable professional license number or certification number or registration number of the individuals providing behavioral health treatment services within the PAVE application. These individuals are not required to separately enroll, however, any QAS providers, QAS professionals, and QAS paraprofessionals for whom they will bill must be reported in the application.
4. How will updates (e.g., new hires, terms, changes) be handled? Will we have to enter it all in PAVE or can we submit an Excel document quarterly? Is there any flexibility in frequency and format?
Yes, the QAS applicant must report the NPI, first and last name, and any applicable professional license number or certification number or registration number of the individuals providing behavioral health treatment services. These individuals are not required to separately enroll. Any changes to previously reported information are required to be reported to DHCS within 35 days of the change by submitting a PAVE supplemental application, in accordance with California Code of Regulations, Title 22, Section 51000.40. The addition or removal of QAS providers, QAS professionals, and QAS paraprofessionals are examples of changes that would need to be reported within 35 days. There is no flexibility on this requirement. Moreover, an Excel spreadsheet would not be an acceptable format to report this information. It must be reported within the application.
5. When enrolling as a QAS organization, do all QAS providers, professionals, paraprofessionals need to register for a Type 1 NPI? Would the QAS organization’s NPI be used to enroll?
All providers need to have a Type 1 (individual) NPI. The QAS applicant must report the NPI, first and last name, and any applicable professional license number or certification number or registration number of the individuals providing behavioral health treatment services. These individuals are not required to separately enroll.
6. Is there any way to extend the deadline date, since we have over 500 professionals to enter into this system?
No, there is no deadline to enroll. Effective May 5, 2025, QAS provider organizations and individuals offering behavioral health treatment services
may apply for enrollment in the Fee-For-Service (FFS) Medi-Cal program, however, providers are not required to do so. Please note, if you are contracted with or intend to contract with a Medi-Cal managed care plan (MCP), the plan may require you to enroll in FFS Medi-Cal through PAVE. Please direct questions regarding credentialing requirements from the plans directly to the plan(s) for which you are contracted with or intend to contract with. The
Medi-Cal Managed Care Plan directory contains contact information for each plan.
7. How will Managed Care Organization (MCOs) know who has been rostered with Medi-Cal so as not to disrupt services and payment for services?
Providers will receive an approval letter within PAVE when their application is approved. Approved FFS providers will also be included on the
Medi-Cal Open Data Portal.
Provider Enrollment
1. If we are currently enrolled as a Behavioral Health Provider on the PAVE portal, do these bulletins change my current Medi-Cal enrollment?
No, QAS providers who currently have an enrollment pathway, including physician and surgeons, psychologists, physical therapists, occupational therapists, licensed marriage and family therapists, licensed clinical social workers, licensed professional clinical counselors, speech-language pathologists, and audiologists, do not need to enroll as a QAS provider to provide and bill for behavioral health treatment.
2. What is the difference between a CBO versus a QAS applicant? Would an Applied Behavior Analysis (ABA) group be considered a QAS provider organization? Is it correct that for-profit organizations who are not eligible to enroll as a CBO for behavioral health treatment services can enroll as a QAS provider organization?
CBO provider must be a public or private non-profit organization with a 501(c)(3) status or a fiscally sponsored entity of a 501(c)(3) non-profit organization. CBOs that provide community health worker (CHW), asthma preventive (AP), justice-involved (JI) or behavioral health treatment services may enroll in the Medi-Cal program.
ABA groups and for-profit organizations who are not eligible to enroll as a CBO may be eligible to enroll as a QAS provider organization as long as the group/for-profit organization meets the program, enrollment, and attestation requirements set forth in the regulatory provider bulletin titled, “
Medi-Cal Enrollment Requirements and Procedures for Qualified Autism Service Provider Organizations and Individuals Offering Behavioral Health Treatment Services.” Please note, QAS provider organizations
will not enroll as groups, but as Healthcare Businesses in PAVE. When beginning the application in PAVE, be sure to select the “I am a Healthcare Business” option (do not select the options for Group or Mixed Group). The QAS provider organization will report information about the QAS providers, QAS professionals, and QAS paraprofessionals for whom they will bill for behavior health treatment services within the Healthcare Business application.
3. Which QAS provider types need to use an application, and which can be added to the applicant’s Medi-Cal enrollment?
QAS provider organization or individual may submit a Medi-Cal application for enrollment to provide behavioral health treatment services. The QAS provider organizations and individuals (referred to as QAS applicants) must report all QAS providers, QAS professionals, and QAS paraprofessionals to the DHCS in their enrollment application and must also attest that all QAS providers, QAS professionals, and QAS paraprofessionals for whom they will bill meet the qualifications and follow supervision requirements listed in accordance with the State Plan for Behavioral Health Treatment Services.
4. Since enrollment is now required for QAS providers/professionals, will enrollment be accepted in lieu of credentialing with MCO’s?
Please direct any questions related to contracting with an MCO to the appropriate plan(s).
5. Can you confirm that physicians and surgeons, psychologists, physical therapists, licensed marriage and family therapists, licensed clinical social workers, licensed professional clinical counselors, speech-language pathologists, and audiologists do not need to enroll?
Yes, QAS providers who currently have an enrollment pathway, including physician and surgeons, psychologists, physical therapists, occupational therapists, licensed marriage and family therapists, licensed clinical social workers, licensed professional clinical counselors, speech-language pathologists, and audiologists, do not need to separately enroll as a QAS provider to provide and bill for behavioral health treatment.
6. Is the FFS enrollment process the same as the process to contract with an MCO?
No, enrolling via PAVE fulfills the Fee-for-Service enrollment requirement but a provider will then need to contract directly with the MCO. An MCO may allow a provider to participate in its network for up to 120 calendar days, pending the outcome of the screening process, in accordance with
All Plan Letter 22-013 and Title 42 of the Code of Federal Regulations (CFR) Section 438.602(b)(2). While Welfare and Institutions (W&I) Code Section 14043.26 allows DHCS up to 180 calendar days to act on an enrollment application if the provider applies directly to DHCS, the provider still may only participate in the network for 120 days, even if DHCS has yet to act upon the application by that time. Please direct any questions related to contracting with an MCO to the appropriate plan.
7. Are BCBA providers required to enroll if they do not provide services to Medi-Cal FFS members?
See answer above to question 8.
8. Does enrollment in the Medi-Cal program through PAVE only apply for QAS provider organizations and individuals offering behavioral health treatment services for patients in the FFS program?
No, once this enrollment pathway is established, providers must enroll even if they only intend on continuing to contract with MCOs and not serve FFS Medi-Cal members. Please refer to the
All Plan Letter 22-013 for more information about Medi-Cal Managed Care Screening and Enrollment Requirements.
9. We are a for-profit business, does our organization qualify if we do not currently have an 501(c)(3)? Or does our organization have to be a non-profit?
If you are enrolling as a CBO offering behavioral health treatment services provided by QAS providers, QAS professionals, and QAS paraprofessionals then the CBO must be a public or private non-profit organization with a 501(c)(3) status or a fiscally sponsored entity of a 501(c)(3) non-profit organization.
However, if you are enrolling as a QAS provider organization or individual, then the QAS provider organization or individual does not have to be a non-profit with a 501(c)(3) status.
10. As an ABA Group, will we need to Medi-Cal enroll two rendering QAS providers (e.g., BCBAs) under the ABA Group in order to enroll as an ABA Group or can the ABA Group enroll in Medi-Cal by completing the attestation mentioned in the stakeholder hearing?
QAS provider organizations will not enroll as groups, but as Healthcare Businesses in PAVE. When beginning the application in PAVE, be sure to select the “I am a Healthcare Business” option (do not select the options for Group or Mixed Group). The QAS provider organization will report information about the QAS providers, QAS professionals, and QAS paraprofessionals for whom they will bill for behavior health treatment services within the Healthcare Business application. BCBAs will not submit separate applications and will not individually enroll.
11. What were the dates that the QAS application is available in PAVE? What is the due date?
There is no deadline to enroll. Effective May 5, 2025, QAS provider organizations and individuals offering behavioral health treatment services may apply for enrollment in the Fee-For-Service (FFS) Medi-Cal program, however, providers are not required to do so. Effective May 5, 2025, CBO applicants may submit their application to enroll for behavioral health treatment services provided by QAS providers, QAS professionals, and QAS paraprofessionals. Enrolled CBO providers may submit a Supplemental Form to add QAS professionals and QAS paraprofessionals.
Applications received between May 5-June 30, 2025, will receive an effective date of enrollment of July 1, 2025. Supplemental Forms submitted by CBO providers to add behavioral health treatment services received between May 5-June 30, 2025, will receive an effective date for behavioral health treatment services of July 1, 2025.
All other applications or Supplemental Forms received after June 30, 2025, will have an effective date of enrollment based on the date their application is received if all program requirements are met at the time of submission.
12. How long would the application take to process?
State law generally requires DHCS to take an action on an application for provider enrollment within 180 days. If an application is returned to a provider to make corrections, the provider has 60 days to resubmit the application. DHCS will have an additional 60 days to review the application once it has been resubmitted. If the application is referred for a comprehensive review, the review timeframe will be extended. Submitting a complete and correct application will reduce DHCS’ overall application processing time.
13. Where would we find the exact Medi-Cal provider enrollment list?
14. Where would we find the state plans for behavioral health treatment services?
Below are the two state plans for behavioral health treatment services:
- SPA 14-026: Adds Behavioral Health Treatment
- SPA 18-011: Technical correction which proposes to provide behavioral health treatment for all individuals under 21 when determined to be medically necessary by a physician or psychologist.
15. If a BCBA works for a QAS provider organization, we assume that the organization would list them as providers and they would not need to enroll. Is that correct?
Correct, if the BCBA does not intend to directly bill Medi-Cal, then yes, any BCBA’s working for the QAS organization would not need to enroll and just be listed within the application as a provider.
16. Assuming that a QAS provider who works for a QAS provider organization does not need to separately enroll, are they treated the same as QAS professionals and QAS paraprofessionals – the organization lists their rendering providers?
Yes, this is correct.
QAS Qualifications
1. Is Title 17 no longer applicable to meeting staff requirements? In other words, are the standards changed to require QAS paraprofessionals to be RBT and have 6 months of experience?
The California State Medicaid Plan and all State Plan Amendments can be viewed on the
DHCS Medicaid State Plan webpage. For State Plan Amendments regarding behavioral health treatment benefits, please review SPA 14-026 and SPA 18-011 for more information.
2. Do QAS paraprofessionals need to be certified (e.g., Board Certified Autism Technician, RBT certified) in order to provide services under this model? What are the requirements for the paraprofessional position? Are paraprofessionals required to be certified to be eligible to render services?
Please refer to the SPA 14-026 and SPA 18-011 for the requirements to be a QAS paraprofessional.
3. If the QAS providers (e.g., BCBAs) need to be credentialed, can we use an attestation for the QAS organization to credential the QAS providers? What are the credentialing requirements? Specific clarity around the credentialing process by role is needed and will delegate credentialing to the QAS Organization be an option to eliminate access to services issues that tend to happen with longer credentialing timelines.
The California State Medicaid Plan and all State Plan Amendments can be viewed on the
DHCS Medicaid State Plan webpage. For State Plan Amendments regarding behavioral health treatment benefits, please review SPA 14-026 and SPA 18-011 for more information on specific definitions and requirements for QAS providers, professionals, and paraprofessionals.
Administrative Location
1. The bulletin indicates a requirement for at least one administrative location within the state. For organizations with multiple locations, does PAVE require each possible business location be submitted and approved?
They must report at least one administrative location. They may submit separate applications for each location. For the purpose of this provider bulletin, an “administrative location” is defined as the physical location associated with the provider’s operations, which can include where services are dispatched or based. DHCS recognizes that the actual services may occur at administrative locations but may also occur solely in “community settings,” which do not have to be separately enrolled.
2. Do individuals and organizations enrolling as QAS applicants have to report an “administrative location” that is not a post office (P.O.) box or residence address?
Any QAS applicant, whether an individual or organization, must have at least one administrative location. The administrative location reported on the application must not be a private residence, virtual office, or mailbox and may not be reported using a P.O. box.
Implementation and Continuity of Care
1. Should organizations expect any interruption or delay in prior authorized care while going through the PAVE enrollment process? If so, how will you ensure there is no disruption in care for vulnerable individuals who rely on these services?
Yes, MCPs typically allow several months from the date the enrollment option opens before they need to be an approved as a Medi-Cal provider.
2. If we do not enroll as a QAS Organization through PAVE, will there be disruption in services to our clients/families receiving ABA services under our various CA MCO contracts?
Once the FFS enrollment pathway opens for BCBA individuals and organizations as well as educational psychologists, QAS Providers will need to enroll through PAVE in order to continue to provide behavioral health treatment services to children who are members of a managed care plan (MCP) or in FFS. Please see the response to Question #1 under the Implementation and Continuity of Care Section regarding a grace period once the application opens.
3. Is there policy guidance on the implementation of this benefit?
Medi-Cal’s behavioral health treatment policy is not changing. However, starting July 1, 2025, enrolled QAS providers will be able to provide services to children enrolled in FFS and bill DHCS. The DHCS Benefits Division will publish a Provider Manual in July for behavioral health treatment services, including billing codes providers should use to bill DHCS.
4. How would we receive referrals for potential clients?
Either a physician or psychologists would first need to determine that behavioral health treatment services are medically necessary for a child. MCP will continue to refer children who need services to behavioral health treatment providers within their network. DHCS will work with stakeholders on how to connect children with enrolled providers who accept children FFS.
5. Is this restricted to Autism related care? What about talk therapy and Attention-Deficit/Hyperactivity Disorder (ADHD) testing?
No. Behavioral health treatment is not restricted to children with autism and is available to all Medi-Cal children under 21 years of for whom a physician or psychologist determines it is medically necessary. ADHD testing is not part of the behavioral health treatment benefit.
6. Are there certain counties or regions where the availability of Medi-Cal-covered ABA services is expected to be disproportionately impacted?
No. Behavioral health treatment services are available in every county in California.
