Date: Wednesday, August 19, 2026​​ 

Oras: 9:30 a.m. – 3 p.m.​​ 

DHCS Staff Presenters: Michelle Baass, Director; Tyler Sadwith, State Medicaid Director; Yingjia Huang, Deputy Director, Health Care Benefits & Eligibility; Erica Holmes, Assistant Deputy Director, Health Care Benefits & Eligibility; Mistie Chiddick, Division Chief, Provider Enrollment Division; Marlies Perez, Chief, Community Services​​ 

SAC Members in Attendance: Adam Dorsey, Al Senella, Anna Leach-Proffer, Beth Malinowski, Carlos Lerner, Carlos Marquez III, Chris Perrone, Christine Smith, Danielle Bradley, Faith Colburn, Janice Rocco, Katie Rodriguez, Kim Lewis, Kiran Savage-Sangwan, Laura Sheckler, Le Ondra Clark Harvey, Linda Nguy, Marina Owen, Michelle Cabrera, Michelle Gibbons, Ryan Witz, Toby Douglas, Virginia Hedrick, William Walker​​ 

BH-SAC Members in Attendance: Adrienne Shilton, Al Senella, Brian Hurley, Carlos Marquez III, Catherine Teare, Danielle Bradley, Dannie Ceseña, Hector Ramirez, Jason Robinson, Jei Africa, Jevon Wilkes, Karen Larsen, Kim Lewis, Kiran Savage-Sangwan, Kirsten Barlow, Le Ondra Clark Harvey, Leticia Galyean, Linnea Koopmans, Michelle Cabrera, Robert Harris, Rose Veniegas, Samuel Jain, Sara Gavin, Sarah-Michael Gaston, Vitka Eisen, William Walker​​ 

Karagdagang Impormasyon: Mangyaring sumangguni sa presentasyon ng PowerPoint na ginamit sa pulong para sa karagdagang konteksto at mga detalye.​​ 

Panimula at Buod ng Nilalaman​​ 

• The joint Stakeholder Advisory Committee and Behavioral Health Stakeholder Advisory Committee (SAC/BH-SAC) meeting addressed topics related to Medi-Cal and California’s behavioral health landscape. Panel members received a Director’s update on the 2026-27 Budget Act. The following topics were also covered during the meeting:​​ 
  • Centers for Medicare & Medicaid Services (CMS) Interim Final Rule: Impact on Medi-Cal Work and Community Engagement RequirementsOrdering, Referring, and Prescribing (ORP) Provider Enrollment​​ 
  • Update sa Pagbabago sa Kalusugan ng Pag-uugali​​ 
• Nagtapos ang pulong sa isang panahon ng pagbibigay ng komento sa publiko, na nagpapahintulot sa mga dumalo na magbigay ng feedback sa DHCS at mga miyembro ng panel.​​ 

Mga Paksang Tinalakay​​ 

Update ng Direktor​​ 

Michelle Baass, Direktor​​ 

DHCS opened the meeting by providing an overview of the 2026-27 Budget Act, which allocated $337.7 billion for health and human services, including $226.3 billion and 4,765.5 positions for DHCS. The presentation highlighted major budget issues, such as the renewal of the Managed Care Organization (MCO) Tax, the transition of members with unsatisfactory immigration status (UIS) from managed care to fee-for-service (FFS), and adjustments related to federal H.R. 1 requirements. DHCS addressed cost reductions, funding for care coordination, and changes in eligibility and service criteria for Enhanced Care Management (ECM) and Community Supports. Additional funding was granted for county Medi-Cal administration, mobile crisis services, behavioral health programs, and one-time initiatives like hospital grants and pilot programs for severe mental health conditions. The presentation also noted delays in implementing certain cost-saving measures from the 2025 Budget Act and changes to Medi-Cal asset limits and premiums. DHCS provided additional resources for more information.​​ 

Talakayan​​ 

• A member raised concerns about ensuring accurate identification of individuals transitioning to FFS, particularly within the humanitarian immigrant population, noting data discrepancies and the complexity of tracking immigration status changes. They also asked how the Department plans to use Community Health Worker (CHW) and related care coordination resources during the transition and offered to provide suggestions. DHCS responded that it is actively refreshing immigration data, especially for individuals nearing the five‑year bar, and will share updated information soon. DHCS emphasized efforts to ensure those gaining satisfactory status remain in managed care and noted that more details on the $39 million CHW‑related funding are forthcoming as the Department finalizes scope of work, provider guidance, billing information, and engagement plans.​​ 
• A member expressed appreciation for DHCS’ thoughtful approach to balancing complex issues, while emphasizing the need for continued discussion about ensuring high‑quality care for residents in skilled nursing facilities. They highlighted concern that a successful, workforce‑supporting program was not included in the recent budget agreement, noting its positive impact on both residents and facility staff. The member noted the current proposal was reasonable and looks forward to ongoing conversations to address this gap.​​ 
• A member asked whether DHCS anticipates any issues with CMS approving the revised MCO Tax and raised concerns about accurately identifying individuals affected by upcoming immigration‑related coverage changes, including those in the Supplemental Security Income (SSI) population whose data states cannot currently verify. DHCS responded that it has not yet submitted the MCO Tax, but it will go to CMS in the fall. DHCS believes the proposal meets all federal technical requirements, though certain Proposition 35‑mandated elements may not be federally approvable. DHCS emphasized that these changes affect only backend claiming processes, with no effect on member coverage until July 1. DHCS also noted that states lack the ability to independently identify the SSI subgroup and are awaiting federal verification tools. Recent technical guidance has been received, and more information will follow.​​ 
• A member asked whether the shift to FFS on January 1 will be immediate and expressed concern about ensuring adequate navigation support for affected individuals, including funding for community‑based organizations (CBO), advocates, and provider coordination. They also asked whether plans are helping identify FFS‑participating providers ahead of the transition and whether DHCS will publish data on this population. DHCS explained that $8 million of the $39 million allocation is designated for clinic and CBO navigators, with details on the grant process still being developed. DHCS noted ongoing work with plans to assess risk, understand provider connections, and improve coordination, supported by transition policy guides already shared with plans. DHCS is analyzing provider networks to identify gaps and encouraged continued provider participation, and while internal analytics are currently used for planning, DHCS is exploring future transparency around utilization, access, and outcomes for the FFS population. DHCS’ priority is ensuring a smooth transition.​​ 
• A member voiced significant concern about the upcoming transition of the UIS population from managed care to FFS, stressing that the shift will likely disrupt care and reduce access in a system they described as fragmented and ill‑equipped for nearly two million affected members. While continuing to collaborate with DHCS and managed care plans (MCP) on preparedness, the member requested that the SAC hold a dedicated meeting to review transition policies, provider and member communications, noticing, and supports before the next SAC meeting in late October. They also outlined key recommendations, including establishing readiness criteria, developing individualized care plans for high‑risk members, providing extended (30/60/90‑day) notices, honoring prior authorizations, expediting provider enrollment and billing processes, and clearly defining how care coordination will function for members losing ECM and plan‑based support.​​ 
• A member asked whether DHCS will provide earlier or specialized notices for UIS members, particularly those in institutional settings, and raised concerns that providers currently have no way to identify who is UIS, which could create confusion as the January 1 transition approaches. The member also sought clarity on how many members are considered high‑risk within the stratified group. DHCS responded that approximately 15,000 members fall into the high‑risk category and explained that both member and provider communication strategies are being developed. DHCS emphasized that MCPs will play a central role in proactively notifying and coordinating with providers, while DHCS will also share information and finalize a broader communication plan to support continuity of care ahead of the transition.​​ 
• A member emphasized deep concerns about the UIS transition, urging DHCS to ensure accurate identification of affected individuals and expressing disappointment that the SAC meeting did not include substantive discussion on the transition. They stressed that the shift to FFS is essentially a major budget‑driven cut that will significantly reduce provider rates, undermine access, and create serious disruption as nearly two million members move out of managed care in a single day. The member highlighted unanswered questions in DHCS’ policy guide, such as what happens when providers refuse FFS rates, whether authorizations will carry over, how active treatment will be protected, and how care coordination and navigation will function without ECM and Community Supports. They called for stronger readiness criteria, extended member notices, clearer escalation pathways, and more transparency and involvement of the SAC. Despite the challenges, they reiterated their commitment to supporting members and providers and closed by praising the collaborative behavioral health pilot on the Central Coast.​​ 
• A member asked for clarification about a slide referencing the elimination of the incentive component in the quality withhold program, wondering whether the program had been discontinued, if dollars were still being withheld, and if this effectively amounted to a rate cut for plans. DHCS explained that the quality withhold remains in place: dollars are still withheld from plans that do not meet minimum quality standards, but the previously offered “upside” payments for high‑performing plans will no longer be redistributed and will instead support the broader Medi‑Cal program due to budget constraints. DHCS emphasized that this is not a rate cut, plans will still receive sufficient funds to pay providers and deliver benefits, and the change eliminates only the incentive portion while maintaining the quality‑related withhold structure.​​ 
• A member expressed appreciation for the detailed discussion on the UIS transition and emphasized two key concerns. First, they urged DHCS to broaden participation in transition planning by including a wider group of stakeholders, especially providers, beyond the meetings held with plans. Second, they strongly advocated for continuity‑of‑care protections for UIS members with serious diagnoses, noting that these individuals should be able to continue seeing their current providers for a defined period while navigating the shift to FFS. They stressed that losing established care relationships or facing repeated prior authorization requirements would create unnecessary hardship and hoped DHCS would reconsider its current approach to ensure a smoother, safer transition for these vulnerable members.​​ 
• A member raised concerns that the state budget did not include a plan to create a state‑only Medi-Cal billing pathway for gender‑affirming care for transgender and non‑binary youth, noting that CMS has now finalized a federal rule ending Medicaid and Children’s Health Insurance Program (CHIP) funding for these services, effective October 13. They emphasized that California has long been aware of this impending loss of federal funds, and that state leaders have publicly committed to protecting access to medically necessary gender‑affirming care, yet current budget actions do not provide a mechanism to maintain reimbursement for providers. Citing state nondiscrimination laws and guidance from the Attorney General, the member asked how DHCS plans to uphold legal protections and prevent gaps in care or payment for Medi-Cal youth beginning in less than two months. DHCS responded briefly that it is actively working through these issues.​​ 
• A member expressed deep personal fear and sadness about the direction of federal disability policy, referencing a recent Department of Justice memo signaling support for greater institutionalization of people with disabilities and framing disabled individuals as a financial burden in national budget debates. The member connected this to broader attacks on vulnerable communities, including women, transgender people, refugees, and those with disabilities, and urged the group to prioritize continuity of care for the most at‑risk populations, noting that many are already falling through the cracks. They called for solidarity, compassion, and vigilance to ensure Californians with disabilities are not left behind. DHCS responded by affirming its commitment to centering people in all decisions, upholding long‑fought protections, such as the Olmstead mandate, and maintaining California’s strong values around home‑ and community‑based care.​​ 
• A member emphasized the need for deeper engagement and more robust dialogue with DHCS, especially as counties prepare for shifting indigent care responsibilities amid changing estimates and limited resources. They urged clearer discussions on whether the state will continue retaining county funds, despite rising local demand, and highlighted the importance of maintaining a bridge for individuals who may lose coverage. Turning to the UIS transition, the member noted complex and rapidly shifting policy issues within California Children’s Services (CCS) and stressed the need for clearer guidance on potential UIS coding, Medi-Cal disenrollment scenarios, and CCS eligibility implications. They underscored that CCS clients require more than a standard 30‑day notice and should receive CCS‑specific communications to help families understand the transition. They also called for faster analysis of provider overlap between FFS, managed care, and CCS paneled providers, given counties’ growing responsibility to support families in accessing care. Finally, the member urged DHCS to recognize and fund county‑based care coordination programs, such as home visiting, which will be directly impacted by coverage shifts and increased workload, and reiterated the need for continued dialogue as these major changes approach.​​ 
• A member voiced concerns that county behavioral health plans are not being adequately included in UIS transition planning, noting that they cannot identify which clients are UIS and may miss opportunities to support continuity of care. They asked whether ECM and Community Supports are the only Medi‑Cal benefits affected, emphasized the need for coordinated member and provider communication, and requested template notices and inclusion in transition‑related updates. The member also sought clarification on whether nurse advice line information will be shared and asked about the size of the rate increase for non‑specialty mental health through the MCO Tax, while thanking DHCS for extending the mobile crisis benefit. DHCS responded that ECM and Community Supports are the only managed care‑specific benefits discontinued under FFS, and that the relationship between UIS members and county behavioral health plans remains unchanged. DHCS agreed to improve coordination and develop consistent messaging templates, confirmed the availability of the nurse advice line, and noted that roughly $300 million from the MCO Tax supports primary care, non‑specialty behavioral health, and maternity care rates.​​ 
• A member expressed support for stronger navigation funding, statewide outreach, continuity‑of‑care protections, and emphasized the importance of thorough user testing for the Medi‑Cal Finder tool. They asked whether Children’s Health Insurance Program Reauthorization Act (CHIPRA)‑funded and lawfully residing pregnant people and children are excluded from the managed care carveout since they receive federally funded Medicaid and reiterated the urgent need for a state‑only FFS billing pathway to preserve access to gender‑affirming care for transgender youth. They also encouraged the state to expand uncompensated‑care funding to encompass services not covered by Medi-Cal and to build provider capacity. DHCS clarified that CHIPRA‑funded and lawfully residing pregnant people and children are not included in the managed care exclusion.​​ 
• A member echoed concerns about the UIS transition and asked to be included in planning discussions, especially given their role in ECM and Community Supports. They emphasized the need for clear, consumer‑friendly materials to prevent misunderstandings, such as members believing they will lose access to care entirely and requested more details on funding for CBOs that will serve as ambassadors during the transition. DHCS explained it is actively working on clearer messaging, noting that even the term “fee‑for‑service” caused confusion during Medi-Cal Member Advisory Committee (MMAC) meetings. DHCS shared that it is partnering with philanthropy, including the California Health Care Foundation and the California Endowment, to conduct consumer testing and refine language, and are using feedback from the MMAC to shape communications and help members understand the transition and navigate their care effectively.​​ 
• A member thanked DHCS for its investments to help mitigate impacts of H.R. 1, including support for county eligibility work, community engagement requirements, and public hospitals, but emphasized ongoing concerns about the absence of indigent care funding in the budget. They noted that many people are expected to return to county indigent programs, which were largely dismantled after the Affordable Care Act and lack sufficient resources. DHCS responded that the state has set aside bridge funding to support counties as demand increases and is seeking technical cleanup language in a trailer bill to prevent counties from being locked into outdated redirection formulas. DHCS added that it will continue working with the administration and legislature to develop long‑term solutions, with the guiding goal of maintaining coverage for as many people as possible.​​ 
• A member asked how many UIS individuals are youth or parents of youth and raised concerns about how the transition to FFS could affect Medi-Cal billing and access in K‑12 settings, especially for unhoused students who rely on school‑based services. They stressed the importance of protecting young people’s pathways to care. DHCS responded that approximately 107,000 UIS members are under age 21, based on current analysis, and acknowledged the significance of these issues for ongoing program planning.​​ 
• A member thanked DHCS and stakeholders for their ongoing work during a period of significant change and echoed widespread concerns about the transition of UIS members to FFS. They highlighted the importance of clear, accessible communication, noting that even advocates find the concept challenging to explain. As co‑chairs of the Health for All Campaign, they offered to share insights from upcoming community engagement sessions, anticipating that people’s primary questions will center on where and how they can get care, along with how continuity of treatment will be preserved during the transition.​​ 
• DHCS acknowledged that the UIS to FFS transition is a major concern and noted that, although it appeared only in the Director’s Update, they expected substantial discussion on the issue. DHCS emphasized that it is navigating numerous new federal policy requirements, many of which DHCS would prefer not to be implementing, such as work requirements and the FFS transition, and recognized that stakeholders are carrying this burden alongside them. DHCS committed to scheduling an ad hoc SAC meeting dedicated to the UIS transition, explaining that they want to return with clearer data and more detailed information. DHCS thanked members for the conversation and confirmed that additional updates are forthcoming.​​ 

CMS Interim Final Rule: Impact on Medi-Cal Work and Community Engagement Requirements​​ 

Yingjia Huang, Deputy Director, Mga Benepisyo sa Pangangalagang Pangkalusugan at Pagiging Karapat-dapat​​ 

DHCS explained that CMS issued an Interim Final Rule (IFR) establishing new work and community engagement requirements for Medicaid eligibility, effective January 1, 2027. The presentation described how individuals in the New Adult Group must demonstrate compliance with qualifying activities or meet exclusions, such as medical frailty or being the parent of a young child. DHCS provided detailed definitions for qualifying activities, clarified verification standards, and outlined processes for evaluating compliance and exceptions. DHCS discussed the impact of narrowing the medical frailty exclusion, the need for documentation, and the risk of coverage loss for some individuals. The presentation also covered outreach requirements, short-term hardship exceptions, and the option for states to request good faith waivers to delay implementation.​​ 

Talakayan​​ 

• A member acknowledged the difficulty of the current situation and expressed concern about the state’s readiness for a January 1 implementation of the IFR‑driven federal changes, noting unanswered questions, workforce strain, and ongoing delays in federal guidance. They asked whether California should proactively choose to delay implementation to mid‑2027 to ensure stability for members and counties, rather than rushing notices and training this fall. DHCS responded that while it understands and share these concerns, DHCS cannot unilaterally postpone implementation without losing critical federal funding, and must instead continue pursuing multiple pathways, including active litigation, potential good faith waivers, and federal engagement, while simultaneously preparing for both a January 1, 2027, launch, and the possibility that federal relief does not materialize. DHCS emphasized close coordination with counties, noted that pre‑IFR training materials are nearly ready, and committed to supporting county eligibility staff through ongoing training, technical assistance, and system refinements as more information becomes available.​​ 
• A member expressed appreciation for DHCS’ work while stressing the seriousness of the federal IFR and the need for clear communication to Medi-Cal members about both the upcoming changes and the political context that created them. They asked for an update on how high unemployment exemptions will be applied and whether the state intends to use flexibility in implementing new requirements for the state‑only Medi-Cal population. DHCS explained that unemployment exemptions must rely on federal Bureau of Labor Statistics data, unless CMS approves an alternative source, noting the threshold is 8% and that operationalizing the required one‑month look‑back still requires federal guidance. They added that about 400,000 people across 15 counties are projected to qualify under current state data, and while there is precedent for states using their own data, California has not yet received federal direction. Regarding the state‑only population, DHCS said current policies remain in place and that it has no further guidance yet on how federal rules may affect timelines or exemption criteria.​​ 
• A member acknowledged the immense challenges posed by the IFR, noting the uncertainty created by pending litigation, shifting CMS guidance, and the operational complexity states now face. They asked when California plans to submit any waiver or exception requests to CMS if formal guidance does not arrive, if the state is developing its own medically frail code list, if experiences from early‑implementer states like Montana are informing planning, and how retroactive coverage rules complicate hardship look‑backs and renewal timelines. DHCS replied that it intends to submit requests only after CMS provides clearer criteria and are currently developing verification approaches with clinical experts while consulting other states, though CMS has not endorsed any specific code sets. DHCS confirmed that many details, including medically frail determinations and retroactive eligibility processes, remain to be determined pending further federal direction, and said they are actively mapping scenarios and will include clearer examples in future guidance.​​ 
• A member stressed the importance of multilingual, accessible communication about upcoming policy changes, noting that traditional mailings are ineffective for many of the communities they work with. They urged DHCS to adopt a broader campaign‑style approach that leverages trusted messengers, including community leaders and influencers, to ensure critical information reaches disabled individuals, seniors, working families, college students, and others who will be affected. DHCS acknowledged these concerns, emphasized that it is committed to reaching all stakeholders, and noted that new funding for communications became available on July 1. DHCS said broader outreach efforts are being developed, though messaging remains difficult while federal policies are still unclear, and assured that more communication initiatives are forthcoming.​​ 
• A member expressed deep concern about applying federally driven work and community‑engagement requirements to the state‑funded undocumented population, noting that this group is not federally mandated to comply and faces unique risks. They highlighted how seasonal work, inconsistent employment, and privacy concerns could make documentation nearly impossible, potentially causing eligible individuals to lose Medi-Cal coverage and become unable to re-enroll due to the freeze. DHCS acknowledged these concerns and explained that applicants may use existing verification tools, such as income affidavits signed under penalty of perjury, when they cannot provide employment documentation, and that this option will remain available. DHCS also recognized privacy challenges related to community engagement reporting and said DHCS will use newly appropriated communications funding to help educate members about their choices and obligations under the new eligibility rules.​​ 
• A member thanked DHCS for making complex federal rules easier to understand and asked whether the IFR includes any penalties for individuals or states when verification errors occur, such as miscounted work or volunteer hours that later change a person’s exemption status. DHCS explained that individuals face no penalties for such mistakes, and that their eligibility would need to be corrected at the next six‑month renewal. Members are responsible for reporting changes within ten days, per current Medi‑Cal rules. However, DHCS noted that the state itself can face significant financial penalties through federal Payment Error Rate Measurement (PERM) audits if systemic eligibility or verification errors occur, especially given the new restrictions on “good faith” flexibility under H.R. 1. DHCS emphasized that while members are not punished, the state is exposed to substantial oversight risk if errors are found.​​ 
• A member asked for clarification on how short‑term hardship exemptions will be determined, whether counties could receive blanket exemptions, how seasonal changes in unemployment data affect eligibility, who will determine medical frailty, and what order of operations the state will use in applying Medi-Cal eligibility and work requirement denials. DHCS explained that California plans to use EDD unemployment data that is refreshed quarterly and will request CMS approval to rely on it. Short‑term hardship exemptions will still require an individual one‑month look‑back, not a county‑wide automatic exclusion. On medical frailty, DHCS noted that CMS has informally indicated states should rely on diagnosis and procedure code‑based criteria, though formal guidance is still pending, leaving operational details unresolved. Regarding workflow, DHCS said Medi-Cal eligibility will be determined first and then work‑requirement compliance or exemption will be assessed, with clear denial reasons being developed so counties and programs can identify when work requirements are the cause of ineligibility.​​ 
• A member asked whether California could delay applying work requirements to the UIS population if system readiness becomes a concern since the 90/10 federal match does not apply to that group. The member also requested any estimates of how the IFR would affect Medi-Cal eligibility determinations. DHCS responded that systems can technically support a January 1, 2027, launch using the pre‑IFR build, but DHCS intends to apply all policies uniformly across the Medi-Cal population, including UIS members. DHCS added that updated estimates on how many people will qualify under the new IFR rules are not yet available and will be provided in the Governor’s January Budget.​​ 
• A member asked whether DHCS could share more details on how the exemption for individuals participating in drug or alcohol treatment programs would work under the IFR. DHCS responded that this exemption is still under active development and review. DHCS explained that states are examining whether participation in such programs can be reliably identified through claims and encounter data, and that CMS has indicated it may address this exemption in forthcoming sub‑regulatory guidance. Until CMS issues that clarification, DHCS cannot finalize how the exemption will be operationalized and will provide more information as guidance becomes available.​​ 

ORP Provider Enrollment​​ 

Erica Holmes, Assistant Deputy Director, Health Care Benefits & Eligibility; Mistie Chiddick, Division Chief, Provider Enrollment Division​​ 

DHCS explained that federal regulations require all ordering, referring, and prescribing (ORP) providers to be enrolled in Medicaid with a Type 1 National Provider Indicator (NPI). DHCS launched a multi-year approach to enforce these requirements, verifying enrollment through claim edits across medical, pharmacy, and behavioral health systems. DHCS described the definitions of ORP providers, emphasized the importance of compliance for program integrity and funding, and outlined potential impacts, such as delays in member access and claim denials. DHCS implemented mitigation efforts, including targeted outreach, education, and gradual enforcement to minimize disruption. Stakeholders were asked to distribute reminders, identify unenrolled providers, and support compliance. The presentation concluded with enrollment requirements, next steps, and resources for further assistance.​​ 

Talakayan​​ 

• A member asked whether DHCS could clarify how many ORP compliance issues stem from providers not being enrolled in Medi‑Cal versus enrolled providers submitting claims without proper NPIs, noting that each problem requires a different solution and missing NPIs can be just as disruptive as non‑enrollment. DHCS explained that it analyzes these issues separately, reviewing claims with missing NPIs, incorrect NPIs, and NPIs belonging to non‑enrolled providers, and is working internally to ensure a comprehensive approach. DHCS noted that many noncompliant claims involve missing NPIs or the use of Type 2 NPIs, and that efforts are underway both to encourage provider enrollment and to educate billers on correct NPI use to reduce claim rejections.​​ 
• A member thanked DHCS for strong communication efforts and asked what providers can expect in terms of enrollment processing timelines and support for troubleshooting issues. DHCS explained that it anticipates 50,000 to 80,000 new ORP applications and has added resources to maintain the typical 60‑day approval timeline. DHCS noted that automation is planned to streamline the process in the future and emphasized that support is available for providers experiencing challenges during enrollment.​​ 
• A member asked whether the ORP “rework” for non‑enrolled providers was simply an administrative transfer of information. DHCS clarified that it is not just a data transfer, but tens of thousands of providers must actively enroll in Medi-Cal before their NPIs can be used on claims. DHCS emphasized that claims will be rejected if providers are not enrolled or if the claim contains an incorrect or missing Type 1 NPI, meaning both enrollment and proper claim submission are essential. DHCS underscored that every affected provider must take action to ensure their patients can obtain prescriptions and services without interruption.​​ 
• A member asked whether nonprofit providers must enroll in both Provider Application and Validation for Enrollment (PAVE) and the ORP pathway. DHCS explained that nonprofits typically operate under a Type 2 NPI, but any individual practitioner, such as physicians or others who order, refer, or prescribe for Medi-Cal members, must enroll through the ORP pathway, using the PAVE system to complete that enrollment.​​ 
• A member asked whether DHCS has insight into which types of providers are most affected by ORP non-enrollment and whether recent legislation allowing pharmacists to refill prescriptions without an active prescriber would protect patients if a provider fails to enroll in time. DHCS responded that physicians make up the largest share of non-enrolled ORP providers, and analysis considers how many Medi-Cal members each affected provider serves. DHCS explained that pharmacist refill authority is limited to very narrow circumstances and, when pharmacists function as prescribers, they must enroll with a Type 1 NPI. Therefore, the legislative safeguard does not replace the need for enrollment. Providers must enroll with their Type 1 NPI to avoid claim denials and ensure uninterrupted patient access to medications and services.​​ 
• A member asked whether DHCS’ systems can handle a large surge of provider enrollments if outreach efforts are highly successful, and whether processing delays have been factored into planning. DHCS responded that while the technology systems can easily accept a high volume of applications, the limiting factor is human processing capacity. DHCS explained that additional staff and resources have already been redirected to DHCS’ Provider Enrollment Division to maintain current timelines, and longer‑term automation is being developed to reduce manual workload. DHCS noted that enforcement will be phased, not activated all at once, and that ongoing monitoring of application volume will guide decisions about readiness and timing to avoid provider and member disruption.​​ 
• A member asked whether enforcement of ORP requirements could begin as early as February and emphasized the importance of ongoing dialogue to avoid disrupting patient access to prescription drugs. DHCS replied that enforcement will be phased in, like the Medi-Cal Rx rollout, and will depend on real-time data showing whether the system and provider enrollment levels are ready. DHCS noted that while it must eventually go live, it will not proceed until the data indicate sufficient readiness, balancing the need for implementation with the commitment to preventing avoidable access issues.​​ 
• A member, new to the ORP requirements, asked whom to contact for guidance across multiple programs, whether a meeting could be scheduled to identify affected staff, and if entities with Type 2 NPIs that don’t directly order, refer, or prescribe must switch to Type 1. DHCS directed questions to the ORP inbox for triage across teams and offered to meet. DHCS advised that any individual practitioner who prescribes, orders labs, or makes referrals should enroll with their type 1 NPI early to avoid disruption, while organizations should retain their Type 2 NPIs. The change focuses on ensuring that the individual prescriber/referrer is also enrolled, not altering the organization’s NPI type.​​ 
• A member asked how ORP requirements will interact with MCP enrollment and credentialing processes, and whether plans will face similar claim‑denial risks as FFS, especially as enforcement begins and UIS transitions occur. DHCS explained that pharmacy claims are already carved out of Managed Care and are FFS and, therefore, must comply with state ORP enrollment rules, while guidance for managed care encounter handling is still being developed. DHCS noted that most MCPs already require providers to enroll through the state’s pathway, with only a few exceptions, and emphasized that all prescribers, physicians, nurse practitioners, physical assistants, and others, must ultimately be enrolled with their Type 1 NPI to function as full Medi-Cal providers. DHCS added that February is only a potential starting point, as enforcement will be phased in based on readiness and data.​​ 
• A member asked for clarity on how CMS will treat non‑compliance with long‑standing ORP rules, noting confusion between providers failing to enroll and claims missing the required Type 1 NPI. DHCS explained that both issues must be fixed statewide: all individual prescribers must enroll, and their valid Type 1 NPI must appear on claims across all delivery systems, including managed care and behavioral health. DHCS emphasized that February 2027 represents only the earliest point at which claim denials could begin, and enforcement will be phased based on data readiness and stakeholder input. DHCS is working with stakeholders to craft a path that meets federal requirements while minimizing disruption, with DHCS’ goal being to demonstrate clear progress toward compliance rather than triggering widespread claim denials.​​ 

Update sa Pagbabago sa Kalusugan ng Pag-uugali​​ 

Marlies Perez, Pinuno, Mga Serbisyo sa Komunidad​​ 

DHCS highlighted progress in transforming behavioral health services across California, following the passage of Proposition 1. Updates included released updates to the BHSA County Policy Manual, launched applications for licensing and certification, calculated performance measures, and awarded infrastructure grants to expand behavioral health services. Counties submitted and updated integrated plans, with most requests and exemptions approved. DHCS implemented Individual Service Level (ISL) encounter reporting to provide a unified view of behavioral health services, supported counties with technical assistance, and developed a public county profile to increase transparency. The presentation highlighted the development of statewide goals, performance measures, and accountability frameworks, emphasizing health equity and cross-sector collaboration. DHCS also engaged stakeholders through advisory committees and released resources to guide counties in planning, reporting, and improving behavioral health outcomes.​​ 

Talakayan​​ 

• A member thanked DHCS for piloting and phasing the new processes to reduce disruption and noted that the added administrative burden will significantly affect county behavioral health operations. They asked why some Behavioral Health Services Act (BHSA) transfer requests were denied. DHCS explained that most denials were due to counties misunderstanding the new process, for example, requesting a transfer when they actually needed an exemption, or submitting requests that exceeded the allowable 7% transfer limit. In many cases, counties simply were not yet familiar with the available tools and requirements, so DHCS provided technical assistance and clarification rather than approving unnecessary or noncompliant transfers.​​ 
• A member supported DHCS’ plan to expand behavioral health data collection, including non‑MediCal data, but warned that the new county‑specific ISL systems could create significant administrative burdens, especially for providers operating across multiple counties, and asked to be included in technical assistance (TA) to shape implementation. DHCS agreed, noting that provider‑focused TA is just beginning and that materials are being developed for a broader provider outreach “push” this fall. DHCS invited feedback from provider associations to refine guidance and ensure the transition is better understood and workable for providers.​​ 
• A member echoed earlier concerns about the heavy administrative burden counties are facing as they implement numerous new behavioral health and Medi-Cal initiatives. They noted that while counties see value in better understanding services across the continuum, the workload, including provider engagement, corrective action plans, and system transitions, is overwhelming and risks pulling focus away from direct client care. They emphasized appreciation for DHCS’ outreach and collaboration, but urged DHCS to provide greater flexibility, acknowledging that counties are doing the best they can amid an unprecedented volume and pace of required changes.​​ 
• A member asked when new behavioral health and Medi‑Cal data would be publicly available, and whether it would provide a county‑level view of nonmedical services with payer detail, include demographic breakouts for equity analysis, and move beyond annual reporting. DHCS said first‑time submissions will take longer as counties learn the system (with immediate validation to fix issues), and the initial public release will appear on the Behavioral Health County Profile, with a fuller ISL data visualization estimated for early 2028 and additional pieces posted sooner. The county profile is intended to consolidate data across behavioral health, managed care, and broader population health (e.g., opioid dashboards), guided by Behavioral Health Outcomes, Accountability, and Transparency Report (BHOATR) timelines and mindful that the landscape will look different after 2026. DHCS confirmed plans to include demographic and equity measures, and while annual reporting is the current approach (aligned with providers’ one‑year claim submission window), it may explore more frequent updates in the future, balancing timeliness with administrative burden.​​ 
• A member asked what behavioral health-related data DHCS plans to collect under the BH‑CONNECT reporting shown on slide 76. DHCS explained that the initial “version 2” release will include three core elements: whether counties are participating in the Institution for Mental Diseases (IMD) component of BH‑CONNECT, data tied to the BH‑CONNECT incentive program, and information on evidence‑based practices (EBP). Additional data elements will be added over time as BH‑CONNECT matures.​​ 
• A member cautioned that county population‑health profiles may confuse users about what’s included and how MCP data will reflect joint accountability across delivery systems, urging DHCS to clearly explain the site’s purpose, scope, and takeaways. They noted opioid dashboards capture all residents (including privately insured and uninsured), asked how many novel measures are being introduced and how DHCS will validate their usefulness amid external factors (federal policy shifts, natural disasters), and highlighted the need to communicate data “truthing” to avoid misinterpretation in a scarce‑resource environment. They also asked how the California Department of Public Health’s (CDPH) population‑based prevention role will integrate with DHCS’ public reporting, given changing funding flows. DHCS said novel measures will be clearly labeled (potentially shortly after the initial release), emphasized rigorous development with the Quality and Equity Advisory Community (QEAC) and technical specifications, and described close coordination with CDPH and other departments under shared statewide behavioral health goals. DHCS reiterated the aim to provide transparent, comprehensive county profiles that bring together data across systems, while continuing to refine communications and operations as implementation proceeds.​​ 
• A member noted discrepancies between DHCS‑published performance measures and health plan‑validated rates, attributing differences to varying specifications and DHCS’ lack of access to some supplemental plan data. They asked DHCS to work with plans to reconcile and explain these differences publicly and to use its own analyses to guide strategic policy decisions. DHCS agreed the work is complex and emphasized the need to present data clearly across three lenses—transparency (what’s happening locally), population health (countywide trends), and accountability (whether investments yield intended outcomes). They acknowledged apples‑to‑apples comparability challenges and said DHCS should publicly interpret what the data show about the system and how those conclusions inform regulation and policy.​​ 
• A member thanked DHCS for including language access and equity components in the new cultural competency requirements and highlighted ongoing gaps in county language access planning. They also praised progress in behavioral health measurement while noting remaining challenges. Their main question was whether BH‑CONNECT reporting would eventually show not just whether counties opted into enhanced CHW services, but how many people are actually receiving them. DHCS responded that the initial BH‑CONNECT data release will only include three elements, county IMD participation, incentive program information, and evidence‑based practice details, and that enhanced CHW utilization data has not yet been developed. DHCS agreed to take the request back for consideration and noted that meaningful CHW utilization reporting may need to align with claim timelines and future Medi-Cal Connect capabilities.​​ 
• A member thanked DHCS for the significant effort required to build new reporting systems amid major program changes and suggested returning to users, counties, providers, and QEAC members, to reassess how well the finalized structures function in practice. They noted that some design elements may not work as intended once implemented and encouraged continued refinement of measures, presentation formats, and usability. The member also asked whether DHCS still intends for the behavioral health transformation data effort to serve as a model for broader Medi-Cal or enterprise‑wide data reporting, underscoring that if so, it is even more important to evaluate this rollout, conduct user testing, and ensure the information is understandable and genuinely useful.​​ 
• A member asked whether the information DHCS recently shared about temporary funding withholds and related action plans for county behavioral health plans is publicly available. DHCS confirmed that the update came from its weekly stakeholder communication and explained that 10 county behavioral health plans across 9 counties received temporary funding withholds after failing to correct network adequacy and timely access deficiencies over two consecutive certification cycles. These counties may meet with DHCS to provide additional data through a meet‑and‑confer process, and funds will be restored once compliance is demonstrated. DHCS added that affected plans will enter enhanced monitoring, with potential escalation to permanent sanctions, and noted that staff can follow up by sharing the publicly available information.​​ 

Pampublikong Komento​​ 

During the public comment period, participants had the opportunity to share concerns and provide feedback to DHCS and panel members, either verbally or in writing.​​ 

• A member of the public expressed appreciation for the meeting, but emphasized the need for an ad hoc session focused on the upcoming UIS to FFS transition and broader H.R. 1 implementation changes. They urged DHCS to more actively engage providers, counties, and frontline staff who are directly supporting affected populations and fielding frequent questions. The commenter noted that the provider enrollment presentation raised even more questions and highlighted ongoing issues with the PAVE system, including administrative burdens and persistent enrollment problems reported by providers. They requested that DHCS consider these real‑world challenges as new enrollment requirements roll out and asked for stronger stakeholder involvement to ensure concerns from the provider perspective are addressed.​​ 
• A member of the public asked how Non-Emergency Medical Transportation (NEMT) and Non-Medical Transportation (NMT) services will be arranged for the roughly two million Medi-Cal members transitioning to FFS.​​ 
• A member of the public thanked DHCS for its work navigating the IFR, but expressed significant concerns about unresolved policy questions, implementation challenges, and the repeated need to retrain providers, which creates confusion and administrative burden. They urged DHCS to consider delaying implementation to avoid federal compliance risks and errors. They also appreciated the budget updates and support for eligibility workers, but asked for a no‑cost, multiyear funding authority in the August budget, emphasizing that one‑year funding creates hiring barriers for counties, especially as disenrollments are expected to peak in 2027-28 when six‑month renewals and work requirements take full effect.​​ 
• A member of the public with Rainbow Families Action expressed deep concern that California has not established a billing pathway for Medi-Cal providers to deliver gender‑affirming care to trans youth, despite knowing for nearly a year that new federal rules would require it. They warned that without urgent action, vulnerable families could lose access to essential care, providers may be unable to get reimbursed and could shut down services, and treatment interruptions could severely harm young patients’ mental health and stability. The commenter called the situation unacceptable, emphasized that Medi-Cal families cannot pay out of pocket, and demanded an explanation for why a predictable problem is now projected to take more than a year to fix, stressing that children’s lives and continuity of care are at risk.​​ 
• A member of the public expressed concern about the impacts of H.R. 1’s work requirements and urged DHCS to deploy California’s 10,000 certified Medi-Cal peer support specialists, alongside navigators, to help Medi‑Cal members understand and comply with the new eligibility, reporting and work rules. They noted that CMS’ narrow definition of medical frailty could harm individuals with behavioral health conditions and emphasized that peers, already supporting specialty mental health services statewide, are uniquely positioned to guide enrollees through complex requirements and prevent coverage loss. The commenter stressed that integrating peers into H.R. 1 outreach would protect vulnerable members, reduce disenrollments, and potentially save the state and plans billions by improving retention, and urged the state to use available navigation funding to ensure peers are fully included.​​ 
• A member of the public expressed deep alarm that California has not prepared a billing pathway for Medi-Cal providers to continue delivering gender‑affirming care to trans youth when new CMS rules take effect. They warned that without immediate state action, providers will be unable to bill for care, leaving vulnerable youth without access to a legally protected health benefit and creating a discriminatory and dangerous gap in treatment. They urged DHCS to rapidly establish a state‑only billing mechanism to prevent lapses in care, stressing that continuity is critical for the well‑being and mental health of trans youth and that the situation constitutes a genuine emergency requiring urgent intervention.​​ 
• A member of the public expressed urgent concern that their two children may lose access to essential health care due to the lack of a billing pathway for gender‑affirming services under Medi‑Cal. They described the potential interruption of care as cruel and devastating, emphasizing the severe mental health risks such a disruption would pose. The commenter stressed that the state has long known this issue was coming and insisted that immediate action is needed to ensure providers can be paid and vulnerable youth do not lose critical, legally protected care.​​ 
• A member of the public who is a parent of an 11‑year‑old transgender child and a member of Rainbow Families Action, shared that their daughter attempted suicide multiple times before age 10 and urgently needs gender‑affirming medical care to protect her mental health as she approaches puberty. They emphasized that their child is a real person, not a statistic, and pleaded for immediate action to ensure she can access the care her physicians say is necessary to keep her safe and stable.​​ 
• A member of the public expressed shock and anger that California and DHCS failed to prepare a plan ensuring that Medicaid patients, specifically transgender youth, could continue receiving gender‑affirming care under new CMS rules. They highlighted the contradiction between DHCS’ public statements on social media claiming readiness to protect this care and DHCS’ failure to create a billing pathway, which they said will result in illegal discrimination, care delays, and potentially complete loss of services for vulnerable LGBTQIA+ youth. The commenter argued that DHCS’ inaction disregards the values of care and respect California claims to uphold and stressed that transgender youth deserve equal access to healthcare.​​ 
• A member of the public provided a written statement detailing their experience as a Medi‑Cal member and long‑term pancreatic cancer survivor. They explained that they rely on Creon, a sole‑source, non‑substitutable pancreatic enzyme costing Medi-Cal about $84,000 per year, to stay alive, and that Medi‑Cal’s income limits have forced them to live in poverty for 17 years. They described how eligibility rules prevent savings, career advancement, and retirement, while the Working Disabled Program is inaccessible because it requires a federal disability determination that restricts earnings far below self‑sufficiency. With new federal work requirements under H.R. 1 poised to mandate 80 hours of monthly work while still capping income, they urged policymakers to recognize the contradiction and implement medically frail and caregiver exemptions realistically. The commenter asked that DHCS study reforms for chronically ill enrollees dependent on high‑cost sole‑source drugs, support CalRx’s review of the pancrelipase market, and ensure H.R. 1 implementation avoids harmful coverage losses.​​ 
• A member of the public provided a written statement urging DHCS to ensure that statewide accountability under the BHSA measures whether children and youth actually receive timely and appropriate care, not just overall spending or service volume. The commenter recommended that counties report key access metrics, such as referral-to-assessment and referral-to-treatment timelines, appointment availability, denials, service interruptions, and school‑linked referral outcomes, disaggregated by important demographic and system characteristics. They also called for more detailed workforce reporting, clear documentation of capacity‑related delays under Full Service Partnership presumptive eligibility, and provision of clinically appropriate interim services. Finally, the commenter stressed that school‑based prevention efforts must complement rather than replace access to licensed clinical care, and asked DHCS to require strong referral and coordination pathways between schools, county behavioral health plans, Medi‑Cal MCPs, and qualified community providers.​​ 
• A member of the public provided a written statement describing their family’s repeated struggles to obtain coordinated, effective mental‑health care for a loved one experiencing serious psychiatric crises, despite involvement from CARE (Community Assistance, Recovery, and Empowerment Act) Court, assisted outpatient treatment, county mental health programs, crisis services, and hospitals. They explained that families often move from one program to another without any entity taking responsibility for understanding the full pattern of recurring crises or coordinating next steps. Motivated by witnessing other families facing similar challenges, they launched an advocacy effort called Families Asking for Help. They urged DHCS and the BH-SAC to create a clear escalation pathway for families, improve coordination across programs, ensure meaningful follow‑up for individuals repeatedly encountering crisis services, allow families to provide longitudinal information within appropriate privacy limits, and strengthen accountability for whether public behavioral health systems are actually preventing people from cycling through crises. They emphasized that these reforms should protect civil rights and focus on treatment, coordination, and support, not unnecessary involuntary interventions.​​ 
• A member of the public provided a written statement urging DHCS to address the lack of any health care pathway to cover medically necessary disability‑specific service‑dog training. They explained that while the Americans with Disabilities Act recognizes psychiatric service dogs and the tasks they perform, there is no corresponding mechanism in the health care system to finance the specialized training many disabled individuals cannot afford or complete themselves. Citing high training costs and widespread confusion caused by fraudulent service‑dog “registrations,” the writer asked the Legislature to consider directing DHCS to study or pilot a Medi‑Cal benefit that would support clinically verified service‑dog assessment, task training, and handler instruction under defined eligibility, safety, and accountability standards. They argued that the state already operates standardized canine programs in other sectors and could adapt similar administrative expertise and emphasized that expanding coverage for service‑dog training could strengthen disability independence and support behavioral health, an important priority given California’s ongoing mental‑health system challenges.​​ 

Pagpapaliban at Paparating na Pagpupulong ng SAC/BH-SAC​​ 

Pinasalamatan ng DHCS ang mga miyembro ng komite at ang publiko para sa kanilang pakikilahok bago nagbigay ng paalala para sa nalalapit na pagpupulong.​​ 

• The next meeting is scheduled for October 28, 2026. Register here.​​ 
• Ang Joint SAC/BH-SAC ay magpapatuloy na maging hybrid hanggang sa susunod na abiso.​​