Questions Related to Specific Bespoke Templates
Speciality Mental Health Services (SMHS) Memorandum of Understanding (MOU) Questions
1. Are Mental Health Plans (MHPs) and Managed Care Plans (MCPs) allowed to enter into agreements outside of the MCP/MHP MOU?
Yes, the Department of Health Care Services (DHCS) acknowledges that there may be other written agreements between the Parties relating to the MHP services specified within the agreement. Other written agreements may exist but should not conflict with the provisions within the MOU.
2. Are MCPs and Third-Party Entities required to develop joint policies and procedures (P&Ps) or can each party use their own internal P&Ps?
No, parties may utilize their own P&Ps provided both parties agree and communicate any changes to each other and DHCS. However, DHCS highly encourages the joint development of P&Ps.
3. Are MHP and Drug Medi-Cal Organized Delivery System (DMC-ODS) County network/contracted providers required to be a signatory to their delivery system’s respective MOUs?
No. The required signatories (in addition to the MHP/DMC-ODS County and the MCP) are MCP Subcontractors or Downstream Subcontractors that are Knox-Keene licensed health care plans and have entered into agreements with MCPs to delegate all or part of their responsibilities relating to sending/receiving referrals and care coordination for members served by both parties of the MOU. This does not include network/contracted MHP and DMC-ODS providers.
Substance Use Disorder (SUD) MOU Questions
4. Should MCPs use the DMC-ODS MOU template for SUD services provided in all counties or will DHCS issue a separate MOU template for DMC Counties?
The DMC-ODS MOU Template should be used by DMC-ODS Counties. DHCS has posted a separate MOU template for DMC counties only. MCPs in counties participating in DMC-ODS should use the DMC-ODS Template provided with the
BHIN 24-016.
5. What is the submission process for quarterly reports to DHCS for DMC-ODS and MHPs?
DMC-ODS counties and MHPs that are unable to execute their MOUs by January 1, 2024, must submit quarterly progress reports and documentation to DHCS demonstrating evidence of their good faith effort to execute the MOU as required by BHIN
24-016,
23-056 and
23-057.
Please send these quarterly progress reports and documentation demonstrating evidence of their good faith effort to execute the MOU to DHCS via email at BHOMDMonitoring@dhcs.ca.gov. These updates are required until the MOU is executed, and all associated policies and procedures are established and submitted to DHCS. County Child Welfare (CCW) MOU Questions
6. What is AB 2083 and why is it referenced in the CCW MOU?
AB 2083 (Chapter 815, Statutes of 2018),
Children and Youth System of Care (SOC), requires each county to develop and implement a MOU setting forth roles and responsibilities of agencies and other entities, such as regional centers, county offices of education, county child welfare, juvenile probation, and behavioral health agencies, that serve children and youth in foster care who have experienced severe trauma as outlined in the
All County Letter No. 19-116 /
BHIN 19-053. The purpose of AB 2083 MOUs (also referred to as
SOC/ILT MOUs) is to ensure that children and youth in foster care receive coordinated, timely, and trauma-informed services. While AB 2083 focuses on children and youth in foster care who have experienced severe trauma, it reflects a priority to build a locally governed interagency or interdepartmental model on behalf of all children and youth across California that have similar needs, that interact with and are served by multiple agencies.
These AB 2083 MOUs are between counties and other local entities that serve children in child welfare/foster care include California’s Integrated Core Practice Model (ICPM) which establishes practices and leadership behaviors through which individuals and organizations must partner and collaborate with one another, and children and families, to ensure an integrated approach to meeting the needs of children and families. MCPs are not required to be parties to AB 2083 MOUs. However, counties may wish to align their MOUs with MCPs with their AB 2083 MOUs to ensure coordination across all entities providing services and coordinating care for children and youth in child welfare/foster care.
DHCS encourages MCPs and Third-Party Entities to collaborate to identify opportunities for coordination and alignment between the MCP required MOUs and AB 2083 MOUs to meet the goal of ensuring Members receive comprehensive, whole person care. The Parties may agree to add requirements such as the following optional provisions included in the County Child Welfare MOU:
- MCP must participate in AB 2083 SOC Local Interagency Leadership Team meetings to which MCP is invited by County to discuss aligning care coordination activities required by this MOU with County’s efforts to coordinate care through SOC activities, wherever possible.
- MCP must collaborate with County to identify opportunities for coordination and alignment of this MOU with County’s Interagency Leadership Team’s efforts in implementing the SOC MOU to increase Members’ ability to receive timely, coordinated care.
- County must include MCP as a party to its SOC MOU with local entities to ensure coordination between MCP, County, and local entities as necessary and applicable to ensure Members receive whole person care.
More information about foster youth rights can be found in the handbook. Local Health Department (LHD) Questions
7. Does Exhibit F of the LHD MOU apply to Whole Child Model (WCM) counties when the county acts as a “Classic” county for California Children's Services (CCS)-Only/Fee-For-Service (FFS) Medi-Cal population?
No, Exhibit F of the LHD MOU does not apply to the WCM counties. This exhibit of the MOU is for the coordination between the MCP and the county for MCP’s Members enrolled, or eligible to enroll, in the CCS Program. Because the CCS-Only/FFS Medi-Cal populations are not served by the MCPs, this MOU exhibit would not be applicable. MCPs participating in the WCM Program should not utilize the California Children’s Services Exhibit F of the LHD MOU and instead should utilize the
WCM MOU.
8. Who should be involved in the MOU development, execution, and coordination of the LHD MOU from the department/agency?
LHD leadership with decision-making authority on behalf of the department/agency and jurisdiction should be involved in the LHD MOU development, execution, and coordination.
9. Why is the MCP required to provide immunization status of Members to LHDs upon request?
The requirement for MCPs to provide immunization status of Members to LHDs is intended to prevent duplication of services as well as coordination of services as applicable under local structures.
In-Home Supportive Services (IHSS) Questions
10. Can a different IHSS MOU Template be used as long as all language from DHCS’ templates is incorporated? Can language from the IHSS MOU Template be incorporated into an existing agreement?
DHCS requires MCPs to utilize the Bespoke Templates for MOUs that have Bespoke Templates available, which includes the IHSS MOU. The MCP and the Third-Party Entity may agree to include additional provisions, provided any additional provision does not conflict with the required minimum provisions.
Upon submission to DHCS, MCPs must attest that they did not modify any of the provisions of the Template except to add provisions that do not conflict with or reduce either party’s obligations under the Base Template or Bespoke Templates. If the MCP modifies any of the provisions of the Base Template or Bespoke Templates, the MCP must submit a redlined version of the MOU to DHCS for review and approval, prior to execution.
We recommend MCPs work closely with counties to ensure the executed MOU meets the requirements for MCPs as described in
APL 23-029.
11. Are there any resources to assist with the training provisions and requirements outlined in the IHSS MOU template?
Yes. The California Department of Socia Services (CDSS) has created the following IHSS training videos to support the training provisions outlined in the IHSS MOU.
12. Does the MOU require MCPs to determine or authorize IHSS hours or providers?
No. IHSS eligibility and authorized hours are determined by county social service agencies, and the county social services agency works with an IHSS recipient to connect the recipient with an IHSS providers. MCPs do NOT determine or authorize IHSS hours or providers.
13. Does this MOU require counties to share IHSS data for all county IHSS recipients with MCPs?
No, the MOU Template is intended to support coordination between counties and MCPs for their shared clients – IHSS recipients who are MCP Members. The data sharing requirements are focused on the need to share information for select Members that counties and MCPs need to discuss together for care coordination. DHCS shares IHSS data with MCPs for their Members on a monthly basis, although that data sharing is not “real time.”
14. What happens in a county with multiple MCPs? Can the county sign the same IHSS MOU language with each plan?
DHCS recognizes that a county may want to use the same language for all IHSS MOUs with MCPs and DHCS encourages but does not require MCPs to align their MOU language within the same county.
15. Are counties required to sign IHSS MOUs with MCPs?
To support the needs of IHSS recipients and improve coordination for care at home and in the community, DHCS and CDSS strongly encourage counties to work with MCPs and develop language that is mutually agreeable.
For example, individuals who need help with activities of daily living may get referrals to IHSS from their MCP or health care provider and sometimes there is a need for an expedited IHSS application, or reassessment, when someone is transitioning from a hospital or nursing facility stay. For these situations and others, having the county and health plan working together can improve the individual’s experience of care.
16. If a county and MCP already have an MOU established, does that MOU need to be amended?
Yes. The IHSS MOU Template imposes new requirements with which MCPs must comply. If the currently established MOU includes requirements that go above and beyond those in the IHSS MOU Template, the parties may incorporate those requirements into their executed IHSS MOU so long as they do not conflict with the requirements set forth in the IHSS MOU Template.
17. What should we do if we presently have existing IHSS MOUs in place with MCPs that don’t expire until a future date? Are we expected to end the existing MOUs sooner than the end date and replace it with the new MOUs, or should we have both in place?
DHCS requires MCPs to build partnerships and execute MOUs with counties for IHSS.
APL 23-029 requires that MCPs include all of the minimum requirements in Bespoke Templates without alteration. However, the MCP and the Third-Party Entity may agree to include additional provisions, provided any additional provision does not conflict with the required minimum provisions.
The IHSS MOU Template imposes new requirements with which MCPs must comply. If the currently established MOU includes requirements that go above and beyond those in the IHSS MOU Template, the parties may incorporate those requirements into the new IHSS MOU Template so long as they do not conflict with the requirements set forth in the IHSS MOU Template.
18. Does DHCS share IHSS program data with MCPs? What is the intent of the data and how can it be utilized?
DHCS shares IHSS data with MCPs with the intent to assist the MCP in coordinating care for Members provided by MCP’s Network Providers, providing information necessary to assist Members or their Authorized Representatives in referring themselves to County for IHSS, and coordinating services and other related Medi-Cal and Long Term Services and Supports (LTSS) provided by the MCP and other providers of carved-out programs, services, and benefits.
19. How often is the IHSS data updated and shared with the MCPs?
DHCS shares the data monthly with MCPs. The data transmitted to MCPs has a lag of approximately ten weeks. To assist with more real time data exchange, as outlined in the IHSS MOU, the MCPs and IHSS agencies must implement policies and procedures to ensure that the minimum necessary Member information and data for accomplishing the goals of this MOU are exchanged timely and maintained securely and confidentially and in compliance with the requirements set forth below.
Targeted Case Management (TCM) Questions
20. Which local government agencies are expected to provide TCM in State Fiscal Year 25-26?
The following local government agencies are expected to provide TCM in State Fiscal Year 2025-2026: Alameda; Kern; Los Angeles; Napa; Orange; Riverside; San Diego; Santa Cruz; Stanislaus; Sutter; City of Berkeley; City of Long Beach.
21. What does DHCS’s policy regarding TCM and ECM coordination establish?
DHCS's existing policy on TCM and ECM Coordination establishes that TCM providers must screen members for ECM eligibility and refer ECM-eligible members to MCPs. DHCS's ECM Policy Guide further establishes that ECM authorization must occur during the same timeframes outlined in
APL 21-011, or five working days for routine referrals and 72 hours for expedited referrals. As of July 1,2025, no exceptions exist to the aforementioned coordination policy.
Justice Involved Questions
22. What is the effective date for the MOUs with County Jails and Youth Correctional facilities?
For California Department of Corrections and Rehabilitation, county jails, and Youth Correctional Facilities that go live with pre-release services prior to, or on January 1, 2026, MCPs must collaborate and execute MOUs effective January 1, 2026.
For Correctional Facilities that go live after January 1, 2026, MCP must collaborate and execute MOUs with California Department of Corrections and Rehabilitation, county jails, and Youth Correctional Facilities by the Correctional Facilities’ go live date.
23. Will DHCS release a separate MOU template for California Department of Corrections and Rehabilitation?
Yes, a separate MOU template for use between MCPs and the California Department of Corrections (CDCR) is forthcoming.
24. When are MCPs required to begin reporting about Justice Involved MOUs?
MCPs must report a good faith effort on their execution of the CalAIM Justice Involved Reentry Initiative MOU with LGA/California Department of Corrections and Rehabilitation (CDCR), County Jails, and Youth Correctional Facilities starting January 1, 2026, with the first report due for Quarter 1 on the last business day of April 2026.
However, as of April 2026, DHCS has not finalized or released the separate MOU template that MCPs must use for CDCR. Because of this, DHCS will not require MCPs to report progress on good faith efforts to execute the MOU with CDCR until after DHCS finalizes and releases the CDCR MOU template.
25. Who should be contacted if there are policy related questions about the Justice Involved MOU?
26. Is a County’s contracted Correctional Health Provider required to be a signatory to the Correctional Facility MOU under current DHCS policy?
Correctional Facilities and any public entities responsible for the delivery of correctional health care services should each be parties to the MOU, as articulated in the
MCP-Correctional Facility Post-Release Webinar. Under current DHCS policy, a county’s contracted Correctional Health Provider (e.g., Wellpath) is not required to be a signatory to the Correctional Facility MOU. The county entity is responsible for ensuring that its subcontracted providers comply with the MOU provisions.
27. If the subcontracted provider is not required to sign, will DHCS be issuing written guidance, updated language, or an amendment to the existing MOU template to address this inconsistency?
The existing guidance aligns with current policy. Subcontractors are not required to be signatories to the MOU. As stated above, the county entity responsible for correctional health care services must ensure compliance with the MOU by subcontractors (e.g., third party vendors). The MOU template also states that signatories should be included as applicable.
28. What documentation or assurances should counties or MCPs maintain if the Correctional Health Provider is not a signatory to the MOU?
Counties and MCPs may consider updating their agreements with contracted third-party correctional healthcare services providers and should monitor subcontractors to ensure compliance with the MOU provisions.
For further details or information, please refer to the webinar recording for comprehensive context on these topics or you can send your questions to the CalAIM Advisory mailbox at CalAIMJusticeAdvisoryGroup@dhcs.ca.gov.
