General Information FAQs
1. What are the goals/intent of the Memoranda of Understanding (MOUs)?
The MOUs are intended to:
• Clarify roles and responsibilities of each party,
• Enhance local engagement,
• Improve care coordination among parties, and
• Develop and document processes and procedures to provide whole-person care to Members.
The MOUs leverage existing requirements and policy and guidance documents, incorporating the relevant components into a single document that can be used by the Managed Care Plan (MCP) and Third-Party Entities to improve transparency in and accountability for each party to carry out existing requirements as they relate to the provision of services or care delivery and coordination.
Each MOU is a binding, enforceable contractual agreement between the MCP and Third-Party Entities such as county Mental Health Plans (MHPs), Drug Medi-Cal (DMC), and Drug Medi-Cal Organized Delivery System (DMC-ODS) counties. These agreements outline each party’s respective responsibilities and obligations in coordinating medically necessary Covered Services and carved-out services for Members served by multiple parties.
The MOUs are not intended to be an exhaustive list of all MCP, MHP, DMC-ODS, or DMC requirements, but a specific subset of requirements for MCPs to coordinate with Third-Party Entities (e.g., MHP, DMC, DMC-ODS, etc.) to provide care to Members. MCPs must still comply with the MCP Contract, All Plan Letters (APLs), and other applicable guidance. MHPs must still comply with the 2022-2027 MHP Contract, DMC counties must still comply with the 2023-2027 DMC Contract, and DMC-ODS counties must still comply with the DMC-ODS Contract, as well as Behavioral Health Information Notices (BHINs) and other applicable guidance.
2. When is the Base MOU Template used?
DHCS recommends using the Base MOU Template if the MCPs want to execute a MOU with a Third-Party Entity that does not have a Bespoke MOU Template. For all MOUs required by the MCP Contract, the Bespoke MOU templates are required to be used.
3. What is the intent of each provision outlined in the MOUs?
The intent of each provision is described below:
- Provision of Services: Lists the services covered by the MOU;
- Party Obligations: Outlines the parties’ obligations, to ensure each party is aware of what services the other is required to provide or arrange under existing requirements. This section also requires that each party provides the appropriate contact information to ensure that the parties know how and who to contact for carrying out the obligations set forth in the MOU;
- Training and Education Requirements: The MOU describes the necessary training and education for the parties’ employees who carry out the obligations set forth in the MOU and requires MCPs to provide their Subcontractors, Downstream Subcontractors, and Network Providers with information necessary for them to coordinate care with and make referrals to or receive referrals from the Third-Party Entities;
- Referral Processes: The referral section is meant to encourage the parties to develop and document how they will each refer Members to one another as appropriate and outline what information may be needed to accompany each referral;
- Care Coordination: Care coordination requirements are intended to encourage the parties to develop and document how the parties will coordinate care, monitor whether those processes are working, and improve the processes, as necessary;
- Quarterly Meetings: Quarterly meetings are required to ensure that the parties have a set time to meet to assess whether the MOU is effective in supporting care coordination and whole-person care, as well as to address specific issues that may have arisen related to carrying out the obligations of the MOU;
- Quality Improvement: This requirement is for the parties to ensure ongoing quality improvement specifically related to carrying out the obligations of the MOU and is intended to encourage the parties to develop and document how they will assess whether the MOU is improving care coordination and whole-person care and to develop metrics to evaluate whether the MOU is effective in achieving its goals;
- Data Sharing and Confidentiality: The parties should determine and document the minimum necessary information that must be shared in order to facilitate referrals and coordinate care, develop processes for how to share that information, and determine whether Member consent is required to share the minimum necessary information and, if so, implement a standardized process if possible, to obtain Member consent;
- Dispute Resolution: The parties must develop and document a dispute resolution process to resolve conflicts with regard to each party’s responsibilities under the MOU, including a timeline for resolving disputes and an escalation process for bringing unresolved disputes to DHCS’s (and/or other State departments’) attention as necessary; and
- General Provisions: These provisions describe general contract requirements, such as the requirements that the MCP must publicly post the executed MOU on its website, that the MCP must annually review the MOU to determine compliance and whether updates are needed, that the MCP cannot delegate the MOU except as permitted under the MCP Contract.
4. What are the Bespoke MOU Templates?
The Bespoke MOU Templates refers to a set of specific templates for the MOUs (e.g. the Regional Center MOU Template, First 5 County MOU Template, etc.) required by the MCP Contract between an MCP and a Third-Party Entity. They contain both the Base MOU Template provisions (listed above) and program-specific provisions that are particular to the MCP and the specified Third-Party Entities. Similar to the Base Template, Third-Party Entities and MCPs may adjust the language as needed to reflect local agreements, so long as they do not conflict with the minimum required provisions. Please refer to optional provisions and the MOU submission process for more information. The Bespoke MOU Templates can be found on the
DHCS MCP MOU webpage.
5. If counties have multiple services or programs under one agency, do they need to execute each MOU separately?
No. To reduce administrative burden on the parties, and to account for local variation in the county structure, to the extent that multiple MOU Templates apply to a single Third-Party Entity, multiple services or programs may be included under a single MOU.
For all MOUs required by the MCP Contract, the Bespoke MOU Templates are required to be used. Therefore, if DHCS has issued a Bespoke MOU Template for MCPs to execute with a Third-Party Entity, the parties would not utilize the Base MOU Template. MCPs may use the Base MOU Template for a Third-Party Entity that DHCS does not have a Bespoke MOU Template for and combine it with other Bespoke MOU Templates as needed.
In addition, DHCS encourages but does not require multi-party MOUs, which may include more than one MCP and/or Third-Party Entity signing an MOU as long as the goals of the MOU can be fulfilled at the local level. MOUs serve as instruments aimed at promoting and facilitating collaboration and communication on a local level. It is essential to bear this fundamental purpose in mind when multiple parties are entering into MOUs. The MOUs are designed to foster cooperation, and their successful implementation relies on a shared commitment to enhance collaboration and maintain open lines of communication among all involved parties. In situations where multiple MCPs are entering into an MOU, and are proposing redline edits to the MOU, only one MCP is required to submit the redline MOU to DHCS for review and approval.
MCPs only need to execute MOUs in the counties in which the Third-Party Entity have responsibilities and not all MOUs are required for every MCP and Third-Party Entity. For example, the MCP will only need to execute a DMC-ODS MOU in the counties in which the
DMC-ODS operates. This also applies to County-Based Targeted Case Management and Whole Child Model.
If the parties agree to combine multiple Bespoke Templates into a single MOU, without altering or removing any of the minimum mandatory requirements, the combined MOU can be submitted without redline for file and use. If the parties modify or remove any of the mandatory requirements, the MCP must submit a redlined version of the proposed MOU for review and approval prior to execution as outlined above.
6. Why are some terms capitalized in the APL and the MOU Templates and what is their significance?
Capitalized terms have the meaning ascribed to them by the MCP Contract between MCPs and DHCS or as defined in the MOU Templates. The terms include, but are not limited to, those listed in the
MCP Contract.
The lists of capitalized terms specific to the Specialty Mental Health Services (SMHS) with MHPs, and Substance Use Disorder (SUD) treatment services including counties participating in
DMC-ODS and
DMC Counties are found in the
2022-2027 MHP Contracts.
7. What are the roles and responsibilities of the Responsible Person?
- The “MCP Responsible Person” is the person designated by the MCP who is responsible for overseeing the care coordination activities and communications with the Third-Party Entity and ensuring the MCP’s compliance with the MOU.
The MCP Responsible Person is responsible for ensuring the following:
- Meeting at least quarterly with the Third-Party Entity to address any issues arising under the MOU;
- Reporting on the MCP’s compliance with the MOU to MCP’s compliance officer; and
- Ensuring there is sufficient staff at MCP to support compliance with and management of the MOU;
- Serving as, or designating another person to serve as, the point of contact and liaison with the Third-Party Entity to ensure the Parties meet regularly, maintain channels of communication, etc.
- The Third-Party Entity must also designate a “Responsible Person” responsible for overseeing the Third-Party Entity’s care coordination activities, communications with the MCP, and compliance with the MOU. The Responsible Person also serves, or may designate a person to serve, as the designated liaison and the point of contact with the Third-Party Entity who carries out a subset of the Responsible Person’s obligations on a day-to-day basis such as communicating with the Third-Party Entity, coordinating meetings, and reporting to the Responsible Person.
Bel ow are additional roles required by the MOU Contract that are defined, and only relevant for the specific Bespoke MOU Templates referenced in parenthesis:
- (County Child Welfare (CCW) MOU): The “MCP Child Welfare Liaison” is the MCP’s designated individual assigned to ensure the needs of Members involved in child welfare and foster care, covered under the CCW MOU, are met. Additional information can be found in APL 24-013.
- (In-Home Supportive Services (IHSS) MOU; Regional Center MOU): The “Long Term Services and Supports (LTSS) Liaison” is the MCP’s identified individual or set of individuals as part of their Provider Relations or related functions to serve as the liaison for Long Term Services and Supports LTSS Providers, which includes IHSS Programs and Regional Centers. For more information on the LTSS Liaison, including the definition and applicable requirements, see APL 24-009, and any subsequent APLs on this topic.
- (Whole Child Model (WCM) MOU; Local Health Department (LHD) MOU): The “California Children’s Services (CCS) Liaison” is the MCP’s designated individual for the CCS Program. These liaisons must receive comprehensive training on CCS rules and regulations, including referral and authorization processes, annual medical reviews with counties, and care management requirements. Trained liaisons will ensure compliance, streamline coordination with counties, and improve outcomes for CCS-eligible children. For more information on the CCS Liaisons, see the MCP Contract.
8. Is the MOU Liaison role meant to be a different person for each MOU?
No. MCPs do not need unique liaisons for each MOU, as long as the liaison has the necessary expertise and capacity to fulfill the role.
9. If employee turnover occurs within any party, and individual names need to be updated, is an addendum to the MOU required for each update?
In the event of a change in the Liaison or Responsible Person, DHCS requires MCPs to provide notification as soon as possible, and no later than five working days following the change. This is to ensure that all parties are aware of the appropriate contact for fulfilling the obligations outlined in the MOU. The notification must include the individual's name and contact information, rather than just their role or title. While DHCS must be informed of any changes to the designated Liaisons and Responsible Persons via the Managed Care Operations Division (MCOD) Liaison Directory, this does not necessitate an addendum to the MOU document.
10. Do MCPs need to post executed MOUs on their websites, including representative names and signatures?
MCPs must post executed MOUs on their website. Parties may choose to include the names and contact information for the MOU Liaisons and Responsible Persons in their Policies and Procedures (P&Ps) and include position titles only in the executed MOU. If contact information is included in the P&Ps, parties should include a statement in the MOU to reference that the contact information is available in the P&Ps.
As a reminder, MCPs are required to report MCP contact information for each MOU Liaison and Responsible Person to the MCOD Liaison Directory for each MOU, by filling out the MOU Subtype.
MCPs may redact signatures and replace with “Original Signed by” on copies of executed MOUs posted to the MCP’s website.
11. How will additional policy development in the future impact the MOUs?
The Base and Bespoke MOU Templates were designed deliberately to refer to requirements and policies relevant to the relationship between the MCP and the Third-Party Entity. However, the MOUs do not restate all requirements. The intent of referring to requirements and policies is to allow the MOU to be stable but allowing flexibility for policies to be updated as needed.
For example, DHCS has implemented policy decisions and operational requirements to: Enhanced Care Management (ECM), including division of case management responsibilities and Regional Center ECM responsibilities; MCP Child Welfare Liaison’s roles and responsibilities in
APL 24-013;
Closed Loop Referrals (CLRs); and Emergency Preparedness. Emergency Preparedness is required in Article 6.0 of the MCP Contract, but remains optional in the MOUs. DHCS did not make updates to the MOU Templates based on these new policies and does not plan to re-issue new MOU Templates as policies are changed or new policies are implemented and does not plan to re-issue new MOU Templates as policies are changed or new policies are implemented.
MCPs are responsible for reviewing their MOUs annually for any needed modifications or renewal of responsibilities and obligations and identifying new or changed policies or guidance that impact the MOU. MCPs should collaborate with the Third-Party Entity to amend or add attachments to the MOU as appropriate to reflect such new or changed policies. MCP must submit to evidence of the annual review of MOUs as well as copies of any MOUs modified or renewed as a result
In future years, DHCS intends to periodically review and revise/re-issue the APL and Templates as it evaluates MCPs’ compliance with the APL and MOUs, as parties enhance their coordination efforts, and when updated MCP contracts, policies, or guidance require revisions to mandatory provisions or definitions.
12. How can Parties be held accountable for policies that are not yet issued?
DHCS will hold MCPs accountable for compliance with policies no sooner than or upon their effective date and will provide notice to MCPs when new policies are issued and their effective date. DHCS intends for MCPs and Third-Party Entities to collaborate, assess current gaps in processes and work towards establishing processes in these areas, understanding that these policies will be developed.
13. If an MOU was executed prior to a technical change being made to the MOU Template, will the MCP need to submit an amendment to the MOU?
If the MOU was executed prior to the release of the MOU with technical changes to the template, or was in the final stages of execution process, the MCP is not required to execute and submit an amendment. For all other MOUs that have yet to be executed, please use the most recent version of the template. Additionally, the MCP must review its MOUs annually for any needed modifications or renewal of responsibilities and must submit evidence of the annual review of MOUs as well as copies of any MOUs modified or renewed as a result, as outlined in APL 23-029.
14. What if a Third-Party Entity is a Network Provider delivering Covered Services, does that impact the MOU?
If a Third-Party Entity is also a Network Provider providing Covered Services to Members, pursuant to a separate agreement between the MCP and Third-Party, the MOU does not govern the Third Party’s provision of Contracted Services. For example, if an LHD is a contracted ECM Provider, the MCP is still expected to make good faith efforts to enter into an MOU with the LHD, for the non-ECM services included in the MOU. The LHD MOU would not govern contracted ECM Services between the LHD and the Network Provider. For more information on ECM, please see the
ECM Policy Guide.
15. Do Third-Party Entities need to take any action prior to initial contact from the MCP?
DHCS requires MCPs to build partnerships and make good faith efforts to execute MOUs with various Third-Party Entities to foster communication and collaboration between parties. DHCS has released
APL 23-029, which requires MCPs to submit executed MOUs to DHCS that include all the minimum requirements for the applicable MOU. These minimum requirements are included in the MOU templates that are posted to the
DHCS MOU webpage.
DHCS expects MCPs to proactively reach out to and partner with Third-Party Entities to begin building those partnerships and collaborate on executing the MOUs. DHCS recommends that Third-Party Entities work closely with the MCPs to ensure the executed MOU meets the requirements for MCPs as described in APL 23-029.
16. Where can questions or requests for technical assistance regarding MOUs be sent?
DHCS has established a dedicated inbox to address all questions and requests for technical assistance related to MOUs. In order to effectively respond to inquiries in a timely manner, we kindly request that any inquiries or requests pertaining to MOUs be sent to email address:
MCPMOUS@dhcs.ca.gov. For county inquiries regarding the MOUs for DMC-ODS, DMC, or MHP, please contact
CountySupport@dhcs.ca.gov. For policy related inquiries regarding the Justice Involved MOU, please contact
CalAIMJusticeAdvisoryGroup@dhcs.ca.gov. For inquiries regarding the Local Educational Agencies (LEA) MOU, please contact
DHCS.SBS@dhcs.ca.gov with the subject line “MCP LEA MOU”.
17. Which date should be used as the effective date of the MOU? What is an effective date versus an execution date?
The MOU effective date is the date the MOU goes into effect. The execution date is the date when all parties have signed the MOU. Parties should determine the appropriate effective date for their MOU. In some cases, the effective date of the MOU is the same as the execution date (e.g., MOU signed on 12/1/24 and effective from 12/1/24). In other instances, a specific effective date is provided that is different from the execution date (e.g., MOU signed on 12/1/24 and effective starting on 1/1/25).
18. What is a Closed Loop Referral (CLR)?
A CLR is defined as a referral initiated on behalf of a Medi-Cal Managed Care Member that is tracked, supported, monitored, and results in a Known Closure. The implementation of CLRs involves requirements for MCPs to ensure effective tracking and support of these referrals. The goal of CLRs is to increase the share of Medi-Cal Members successfully connected to the services they need by identifying and addressing gaps in referral practices and service availability. Effective July 1, 2025, CLR requirements apply to ECM and Community Supports, two priority services for which MCPs play an active role in processing eligibility, authorizing services, and referring eligible Members to Network Providers. Services outside of ECM and Community Supports, including referrals between MCPs and other managed care delivery systems (e.g., behavioral health), do not fall under the CLR requirements at this time. DHCS intends to leverage the CLR definition and requirements as it defines guidance for CLR across delivery systems and for other services, as applicable, over time. For additional information on CLR requirements, please refer to the
CLR Implementation Guidance and
CLR FAQs.
19. What is the updated guidance as of May 2025 regarding CLRs?
Only MCPs are required to conduct CLRs. CLR requirements for MCPs will be effective on July 1, 2025, and will apply to referrals made to two services – ECM and Community Supports. MCPs will be responsible for enhanced efforts to support and track all referrals made to ECM and Community Supports (e.g., referrals made by healthcare providers, counties, social service organizations and community-based organizations), with the goal of increasing the number of referred members successfully engaged in ECM and Community Support services. More information on CLR requirements can be found in the
Population Health Management Policy Guide.
Additionally, DHCS has updated the optional CLR provision for the MOU templates (included below). DHCS encourages MCPs to incorporate the updated CLR provision into their MOUs with Third-Party Entities that are not yet executed. More information about MOU requirements can be found on the DHCS MCP MOU webpage.
Updated Optional MOU Provision:
“Closed-Loop Referrals (CLR). Effective July 1, 2025, MCP must comply with DHCS Closed-Loop Referral Implementation Guidance. For all referrals made to Enhanced Care Management (ECM), Community Supports, and future CLR-applicable services, MCP must implement procedures to track, support, and monitor referrals submitted by [Other Party] through referral closure. MCP must also adhere to requirements for notifying the [Other Party] of the authorization status, referral loop closure reason and closure date within timeframes outlined in the guidance to support [Other Party] in their awareness of referral status and outcomes for Members referred to CLR services. The Parties will work together collaboratively to establish the means and methods for MCP notifications for CLRs. DHCS requires MCPs to use electronic methods to notify referring entities of a referral’s status, not paper-based methods.”
Outside of CLR requirements, DHCS continues to encourage Third-Party Entities to refer Members to their MCP who would benefit from
ECM and Community Supports. More information on making a referral to ECM and Community Supports can be found on each MCP’s website.
