Updated Medi-Cal Enrollment Requirements and Procedures for Qualified Autism Service Provider Organizations and Individuals Offering Behavioral Health Treatment Services
Frequently Asked Questions from Stakeholder Hearing on
September 30, 2025
Below are the answers to most of the questions that the Department of Health Care Services (DHCS) received during the stakeholder hearing on September 30, 2025. If you do not see an answer to your question, please send an email to the appropriate email address(es) listed below:
Provider Enrollment
1. Is there any change for Qualified Autism Service (QAS) provider organizations who only have an administrative location and do not see patients in a center/clinic, and only in the community?
There are no changes to the requirements for QAS provider organizations that are comprised of more than one individual QAS provider and intend to bill on behalf of QAS professionals and paraprofessionals. Effective November 17, 2025, DHCS is only updating Medi-Cal provider enrollment requirements and procedures specifically for QAS applicants comprised of an individual Board-Certified Behavioral Analyst (BCBA) who will only bill the Medi-Cal program for themselves.
2. If I am a new QAS sole BCBA provider, do I need to wait until November 17, 2025 to register myself or can I get credentialed prior to November 17, 2025?
Providers that are not currently enrolled and do not currently have a pathway to enroll, such as individual BCBAs who do not provide in-person services at their service address, will be eligible to enroll once the bulletin goes into effect November 17, 2025. If an individual BCBA provides services at a clinic or other location that does meet all established place of business requirements, they would be eligible to enroll prior to November 17, 2025.
3. Should we remove all QAS professionals that we already submitted in PAVE?
No, DHCS does not recommend removing all previously reported QAS professionals and paraprofessionals from your previously submitted enrollment application. Please also note that effective November 17, 2025, you will no longer be required to report or update this information every 35 days in accordance with California Code of Regulations (CCR), Title 22, Section 51000.40.
4. Are Medi-Cal Health Plans expected to validate Medi-Cal enrollment for QAS providers providing behavioral health treatment services? If yes, how will DHCS expect plans to validate if QAS providers are no longer added to the E-form application?
Providers will receive an approval letter within PAVE when their application is approved. Enrolled fee-for-service (FFS) providers will also be included on the Medi-Cal Open Data Portal. When a QAS provider organization enrolls to bill on behalf of QAS providers, QAS professionals, and QAS paraprofessionals, these individuals themselves are not enrolled in Medi-Cal to bill directly and would thus not be validated as an enrolled Medi-Cal provider. Only the enrolling QAS provider organization would be enrolled. Prior to this bulletin, managed care plans were only able to validate that the QAS organization was successfully enrolled in Medi-Cal - that is unchanged.
5. Effective November 17, 2025, for organizational QAS enrollments, we will no longer be required to roster any of our QAS providers, professionals, or paraprofessionals?
Effective November 17, 2025, QAS provider applicants will no longer be required to report each individual QAS provider, professional, or paraprofessional for whom they intend to bill in their Medi-Cal enrollment application. Instead, QAS provider organizations will be allowed to attest to the qualifications of these individuals. They must maintain an up-to-date internal roster that includes:
- National Provider Identifier (NPI)
- Full name
- Any applicable license, certification, or registration numbers
This roster must be made available to DHCS upon request or during audits and will not need to be submitted through the PAVE system as part of the enrollment process.6. Do QAS professionals & paraprofessionals providing services need anything submitted when they join a group that is already enrolled?
No, however, QAS provider organizations are required to maintain certain information for each provider for which they intend to bill the Medi-Cal program. Please see response to question #5 for more information.
7. The presentation slide stated that you need to provide BCBA information upon request. When are those requests made? Does something specific trigger that?
The QAS provider organization must maintain, at a minimum, and make available the following information for DHCS' review upon request for each QAS provider, QAS professional, and QAS paraprofessional: NPI, first and last name, and any applicable professional license number, certification number, or registration number of the QAS providers providing behavioral health treatment services. DHCS reserves the right to audit or request records from the provider pursuant to state and federal law and the provider agreement.
8. Can you confirm that Medi-Cal MCPs are not required to verify Medi-Cal enrollment for BCBAs?
Medi-Cal Managed Care Plans (MCPs) are required to confirm enrollment for providers that are eligible to enroll in fee-for-service Medi-Cal. Effective November 17, 2025, DHCS will begin accepting enrollment applications from individual BCBAs who are working from their residence or other administrative location and not providing physical services from this address.
9. Is there a new deadline for Medi-Cal enrollment or will each organization be required to be enrolled by November 1, 2025?
No, there is no deadline to enroll in fee-for-service Medi-Cal. If you are contracted with or intend to contract with a Medi-Cal managed care plan (MCP), please direct questions regarding credentialing requirements from the plans directly to the plan(s) for which you are contracted or intend to contract. The Medi-Cal Managed Care Plan directory contains contact information for each plan.
10. Is the intent to support solo practitioners starting out, while holding groups to a higher standard of infrastructure? Will the policy eventually expand to groups, or is this distinction meant to remain permanent?
The exemption applies only to individual BCBAs who enroll solely to bill for services they personally deliver without having an established place of business (EPOB). DHCS is committed to continued stakeholder engagement and discussion but must uphold federal and state program integrity standards, including fraud prevention protocols tied to organizational enrollment.
11. Can non-profit organizations apply for an exemption?
QAS providers may enroll as a non-profit organization as there are no restrictions on the type of entity that may enroll as this type of health care business. However, if you intend to enroll as a Community-Based Organization (CBO) and bill for behavioral health treatment services, you need to be organized as a 501(c)(3) non-profit organization and there are no exemptions for this enrollment pathway. For further information please review these bulletins:
Updated Medi-Cal Enrollment Requirements and Procedures for Community-Based Organizations, Local Health Jurisdictions and County Children and Families Commissions
Updated Medi-Cal Enrollment Requirements and Procedures for Community-Based Organizations, Local Health Jurisdictions, and County Children and Families Commissions (Amended on May 5, 2025 for CBO Providers Offering Behavioral Health Treatment Services)
Furthermore, if you intend to enroll under a pathway for a professional provider type, such as a Licensed Marriage and Family Therapist or Physician, then you would not be eligible to enroll as a non-profit entity and would need to enroll under a professional corporation in order to bill Medi-Cal for their services.
12. Under this policy, when an individual BCBA enrolls without a business address, are they expected to personally deliver all services (one-to-one, family training, supervision), or do they also bill for technician delivered services under their supervision? We'd like to better understand the reasoning to why the new policy allows individual BCBAs to enroll without a business address, but small group practices with only two or three BCBAs are still required to maintain one?
There are no changes to the existing requirements for QAS provider organizations composed of multiple individual QAS providers who intend to bill on behalf of QAS professionals and paraprofessionals. These organizations must continue to meet all applicable program requirements.
DHCS remains committed to ongoing collaboration with stakeholders to refine policies in ways that better support the needs of the QAS provider community. Feedback received will continue to inform future policy development.
13. For a QAS organization that has QAS professionals or paraprofessionals that they are billing for, do they count as an individual and are exempt from this requirement?
No, the updates to the QAS provider bulletin only apply to individual BCBAs who intend to enroll solely to bill for their own services and who list their residence or another non-clinical location as their administrative address. These individuals are exempt from the EPOB requirements, as they do not provide in-person services at that location.
However, if a QAS organization intends to bill for services rendered by a paraprofessional, this enrollment pathway would not be applicable. Such organizations must follow the standard enrollment process and meet all program requirements.
14. What is the difference in enrolling as a QAS organization or a Community-Based Organization (CBO)?
QAS provider organizations and individuals enroll in the Medi-Cal program to bill for behavioral health treatment services only.
Community-based organizations (CBOs) enroll in the Medi-Cal program to bill for community health worker (CHW), asthma preventive (AP), justice-involved (JI), and/or behavioral health treatment services.
Billing
1. Can we get more clarification on the BCBAs billing on their own or can we bill under our organization as we already do?
BCBAs may enroll and bill as an individual or an organization.
2. We are a QAS organization, and as of November 17, 2025, we will no longer be required to add any additional providers. Will we still bill under individual providers, or would we bill under one designated provider for all services?
A QAS organization with a type two NPI will bill under that type two NPI for all services.
Additional Resources
1. Why does an individual QAS provider have to only provide benefits to individuals with autism when the benefit is not limited to individuals with autism?
Behavioral health treatment is not limited to children with autism and is available to all Medi-Cal children under 21 years of age for whom a physician or psychologist determines it is medically necessary. If you would like more clarification on what services are covered under this benefit, please email the Benefits Division: MediCal.Benefits@dhcs.ca.gov.
2. Will you send this PowerPoint? Or will this recording be on the website?
The recording of the public hearing will be posted to the bulletin webpage: https://www.dhcs.ca.gov/Pages/stakeholder-hearing-qas-providers-bhts.aspx
3. Our MCO, CalOptima, states that we need to have our newly added BCBAs added to Medi-Cal PAVE. However, we can't currently add to the application. How do we add new providers as BCBAs to the PAVE portal, as currently the account states no changes can be made?
Prior to November 17, 2025, you will be able to update your roster within the application; however, it is not required. After November 17, 2025, this information will no longer be required to be included as part of the application.
If you're having difficulty with your PAVE account, please email DHCSPEDstakeholder@dhcs.ca.gov and we can assist you.
4. How do we get notified if a QAS provider is not validated with Medi-Cal?
DHCS Provider Enrollment does not send notifications for QAS provider Medi-Cal validation.
You can check the status for providers for fee for service Medi-Cal by going to the Medi-Cal Open Data Portal.
