Home Services California Children’s Services FAQ for Federal and State Eligibility Changes​​ ​

Frequently Asked Questions for Federal and State Eligibility Changes​​ ​

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Medi-Cal is undergoing a series of federal and state policy changes that will affect the CCS Program operations, including member eligibility, enrollment, case management responsibilities, beginning in 2026 and through 2027.

This FAQ is intended to provide County CCS Programs with an overview of anticipated changes, implementation expectations, and operational considerations related to the Medi-Cal program eligibility requirements and/or delivery system. Information contained in this document will be updated as additional guidance is finalized by the Department of Health Care Services (DHCS).

This FAQ is intended to be an accompaniment to an overview document titled, “California Children’s Services: Overview on Medi-Cal Enrollment and Eligibility Changes: H.R. 1 and State Budget Changes and What County CCS Administrators Need to Know.”
In addition, the following guidance and resources are also available:​​ ​

Key Terms​​ ​

Coverage Types​​ ​

  • Full-Scope Medi-Cal: Medi-Cal coverage for the full range of Medi-Cal benefits, including primary, specialty, hospital, pharmacy, and behavioral health services. For some members, full-scope coverage is funded only by the state (“full-scope state-only Medi-Cal”).​​ ​
  • Restricted-Scope Medi-Cal: Medi-Cal coverage limited to emergency services, pregnancy-related services, long-term care services, and outpatient maintenance dialysis.​​ ​
  • Medi-Cal CCS: CCS coverage for a member who is enrolled in both CCS and Medi-Cal. Medi-Cal pays for the member’s CCS-authorized services.​​ ​
  • CCS-Only: CCS coverage for a member who meets CCS medical, residential, and financial eligibility requirements but is not enrolled in full-scope Medi-Cal. CCS-Only is funded equally by the State and County. It is also referred to as CCS State-Only.​​ ​

Delivery Systems​​ ​

  • Medi-Cal Fee-for-Service (FFS): Also referred to as Regular Medi-Cal or Straight Medi-Cal. Members enrolled in Medi-Cal FFS access services through providers that are enrolled in the Medi-Cal FFS network. Members enrolled in Medi-Cal FFS are not eligible for services through an MCP.​​ ​
  • Medi-Cal Managed Care Plan (MCP): Members enrolled in Medi-Cal managed care select an MCP in their county that is responsible for covering their benefits and services. Members receive health services through their MCP, including medical services, non-specialty mental health services, care coordination and care management, and other covered services such as enhanced care management and community supports.​​ ​
  • Primary Care Provider (PCP): In managed care, Medi-Cal members select a PCP who provides their primary care services, including regular check-ups, preventive health services, and referrals to specialty care. In Medi-Cal FFS, members do not have an assigned PCP and can access primary care from any provider who is enrolled in Medi-Cal FFS.​​ ​

Potential Reasons for Losing Medi-Cal Coverage​​ ​

  • Procedural Reason: A member loses Medi-Cal for a procedural reason when they don’t complete a required step to keep their coverage, even if they otherwise meet Medi-Cal rules. Examples include, but are not limited to, not returning a renewal packet or requested information, and, under work and community engagement requirements (WCER), not meeting the required work, study, or volunteer hours. Members who lose Medi-Cal for a procedural reason must restore or reapply to Medi-Cal prior to being considered for CCS-Only.​​ ​
  • Eligibility Reason: A member loses Medi-Cal for an eligibility reason when they complete every required step but no longer meet a Medi-Cal eligibility rule, including but not limited to the income or asset limit. Members who lose Medi-Cal for an eligibility reason may be assessed by the County CCS Program for CCS-Only.​​ ​

Coverage Timeframes and Renewals​​ ​

  • Six-Month Renewal: H.R. 1 requirement that certain adults renew their Medi-Cal eligibility every six months instead of every 12 months. For the CCS Program, this affects only members ages 19–20 in the New Adult Group. Children ages 0–18 stay on 12-month renewals.​​ ​
  • New Adult Group: The Medi-Cal eligibility group for adults ages 19–64 who qualify under the Affordable Care Act (ACA) Medi-Cal Expansion. For the CCS Program, this group includes members ages 19–20.​​ ​
  • Work and Community Engagement Requirement (WCER): A federal H.R. 1 requirement that certain members in the New Adult Group complete a required number of work, study or volunteer hours to keep Medi-Cal. Not meeting WCER is a procedural reason for losing Medi-Cal, not an eligibility reason.​​ ​
  • 90-Day Cure Period: The 90 days after a member’s Medi-Cal coverage ends because they did not complete a renewal on time. This Cure Period is current practice for the Annual Renewal period. During this period, the member does not have active Medi-Cal coverage. If the member completes the renewal within the Cure Period and is still eligible, Medi-Cal is reinstated retroactively with no gap in coverage. If they do not, the loss of coverage stands as a procedural loss. The member is then not eligible for CCS-Only and must reapply to Medi-Cal.​​ ​
  • 90-Day Expansion Grace Period: The period during which an undocumented member age 19 or older who loses full-scope Medi-Cal can restore it despite the Undocumented Adult Enrollment Freeze. If the member restores coverage within the Grace Period, they keep full-scope Medi-Cal and Medi-Cal CCS. If they reapply after the Grace Period ends, they qualify only for restricted-scope Medi-Cal, and the County CCS Program may assess them for CCS-Only. If they do not reapply, they lose Medi-Cal for a procedural reason and are not eligible for CCS-Only.​​ ​
  • Reinstatement: Restoring a member’s existing Medi-Cal coverage, back to the date it ended, after they complete a renewal within the Cure Period or restore coverage within the Expansion Grace Period. Reinstatement continues existing coverage. It is not a new application.​​ ​
  • Retroactive Coverage: Medi-Cal covers services rendered from the months before a new Medi-Cal application. Currently the retroactive coverage time is limited to three months. However, starting January 1, 2027, H.R. 1 limits retroactive coverage to one month for adults ages 19–64 in the New Adult Group and two months for all other members.​​ ​

Undocumented Adult Enrollment Freeze​​ ​

As of January 1, 2026, DHCS froze new Medi-Cal enrollments for undocumented adults ages 19 and older who qualified for full-scope Medi-Cal under the state-funded New Adult Expansion Initiative. Adult members who fall under the enrollment freeze are those who have no immigration status, an unverified immigration status, or are certain non-immigrant visa holders. These individuals who newly apply for Medi-Cal are eligible only for restricted-scope Medi-Cal (emergency and pregnancy services).​​ ​

1. How will the Medi-Cal enrollment freeze impact CCS members?​​ ​

Undocumented CCS members ages 19–20 who are currently enrolled in full-scope Medi-Cal keep that coverage as long as they continue to meet Medi-Cal requirements. If they lose Medi-Cal, they can restore full-scope Medi-Cal and Medi-Cal CCS within the 90-day Expansion Grace Period (See ACWDL 25-13.) After the grace period ends and if the reason for discontinuance is not addressed during the Expansion Grace Period, they can no longer get full-scope Medi-Cal. They may reapply and qualify for restricted-scope Medi-Cal, and the County CCS Program may then assess them for CCS-Only. If they do not reapply, they lose Medi-Cal for a procedural reason and are not eligible for CCS-Only.​​ ​

Undocumented individuals ages 19-20 newly presenting to Medi-Cal are unable to enroll in full-scope Medi-Cal as of January 1, 2026. However, these individuals may be eligible for restricted-scope Medi-Cal (emergency and pregnancy related care). Individuals must apply for Medi-Cal coverage prior to being considered for CCS-Only services if they meet CCS Program eligibility requirements, residential, financial, and medical.​​ ​

Children ages 0–18 will still be able to apply for and receive Medi-Cal regardless of immigration status.​​ ​

2. What steps do County CCS Programs need to take in the event a CCS applicant or member is unable to enroll in full-scope Medi-Cal due to the Medi-Cal enrollment freeze?​​ ​

County CCS Programs should follow existing application processes and direct applicants who may qualify for Medi-Cal to submit a Medi-Cal application. See the CCS Administrative Case Management Manual for more information.​​ ​

County CCS Programs must conduct applicable CCS eligibility determination processes in accordance with existing guidance. County CCS Programs are encouraged to monitor MEDS alerts for changes in Medi-Cal eligibility or enrollment statuses among CCS members. County CCS Programs may also generate the CMS 39 Active Cases with Recently Terminated Medi-Cal Coverage report in Microsoft Business Intelligence (MSBI) to identify members that may be impacted by changes in Medi-Cal eligibility.
In addition, in accordance with APL 26-16, through December 31, 2026, MCPs must notify their CCS County Administrator for each of their CCS members who loses full-scope Medi-Cal as a result of the Enrollment Freeze and provide information regarding the member in order for the County to conduct the CCS eligibility review process to determine if the member qualifies for CCS-Only.​​ ​

3. Individuals impacted by the Undocumented Adult Enrollment freeze who lose full-scope Medi-Cal coverage have a 90-day Expansion Grace Period. How will County CCS Programs know when Medi-Cal coverage is reinstated for a CCS member in this situation? How are costs for CCS services that occur during this 90-day period handled?​​ ​

Medi-Cal coverage ends at the end of the Medi-Cal renewal due date if the member does not renew on time (which may mean the member does not provide required documentation on time). If the member completes their renewal within the 90-day Expansion Grace Period, Medi-Cal coverage is reinstated retroactively with no gap in coverage. If the member does not complete the renewal, they lose Medi-Cal for a procedural reason and are not eligible for CCS-Only as of the date of Medi-Cal discontinuance; they must restore or apply to Medi-Cal first before reapplying to the CCS Program to be considered for CCS-Only.

However, the member still has a 90-day Expansion Grace Period to submit their renewal paperwork. When a County identifies that a member’s Medi-Cal coverage has ended but is within the 90-day window, the County CCS Program should contact the CCS member and/or family to provide guidance and education on the implications if Medi-Cal is terminated. County CCS Programs should regularly check MEDS or MEDS Inquiry in the CMS Net Legacy Module to see if the member’s Medi-Cal has been reinstated.

County CCS Programs are encouraged to monitor MEDS alerts for changes in Medi-Cal eligibility or enrollment statuses among CCS members. County CCS Programs may also generate the CMS 39 Active Cases with Recently Terminated Medi-Cal Coverage report in MSBI to identify members that may be impacted by changes in Medi-Cal eligibility. (DHCS will update 03-0926 California Children’s Services Members with Unsatisfactory Immigration Status NL to be consistent with this updated direction)​​ ​

4. What if a family/member chooses not to enroll or lets their enrollment in Medi-Cal lapse due to fear of being reported to immigration authorities?​​ ​

If a member loses their Medi-Cal because they have not taken the necessary actions to maintain enrollment or to enroll, then they will lose their Medi-Cal coverage due to a procedural reason; they will also lose their Medi-Cal CCS as of the date of Medi-Cal discontinuance and will not be eligible for CCS-Only. Reinstatement, depending on their age and immigration status, may be possible but only if they reapply within specified timeframes outlined above.​​ ​

5. A CCS member ages 19–20 applies for and receives restricted-scope Medi-Cal (emergency and pregnancy coverage only) due to the January 2026 Medi-Cal enrollment freeze. How are CCS claims handled for this member? What is the order of payer responsibility (e.g., Medi-Cal first, CCS second)?​​ ​

Restricted-scope Medi-Cal covers emergency and pregnancy-related care. Therefore, Medi-Cal should be billed for all emergency services, including emergencies related to the member’s CCS-eligible condition, not CCS. If the member qualifies for CCS-Only, the County CCS Program or DHCS (for dependent counties) authorizes non-emergency services for the CCS-eligible condition​​ ​

UIS Fee-For-Service (FFS) Transition​​ ​

As of January 1, 2027, DHCS will transition all Medi-Cal members with UIS from the Medi-Cal managed care delivery system to the Medi-Cal FFS delivery system. These individuals will no longer be enrolled in their Medi-Cal managed care plans but will remain Medi-Cal members. This population must access covered Medi-Cal and CCS services through providers enrolled in the Medi-Cal FFS delivery system.​​ ​

These CCS UIS members will remain Medi-Cal and maintain their current CCS enrollment status. CCS members will not shift to CCS-Only as a result of this transition.​​ ​

6. Who are the Medi-Cal members affected by this UIS transition?​​ ​

All Medi-Cal members with UIS will transition from the Medi-Cal MCP delivery system to the FFS delivery system on January 1, 2027.​​ ​

Affected Populations:​​ ​

  • Medi-Cal members with UIS.​​ ​
  • Tất cả những người nhập cư không có giấy tờ hợp lệ, bao gồm cả trẻ em và phụ nữ mang thai.​​ ​
  • Lawful Permanent Residents (green card holders) who have been in the U.S. for less than five years.​​ ​
  • Những người không phải công dân thường trú hợp pháp (PRUCOL) đang sinh sống tại Hoa Kỳ với sự hiểu biết và cho phép của cơ quan quản lý nhập cư (chẳng hạn như những người đang chờ xét duyệt đơn xin tị nạn hoặc hoãn trục xuất) trong khi chờ quyết định cuối cùng về tình trạng cư trú.​​ ​
  • Qualified Non-Citizens (QNC) who lose federal full-scope eligibility due to H.R. 1. Applies to those who are ages 21 or over​​ ​

Not Affected Populations:​​ ​

  • U.S. citizens.​​ ​
  • Other immigrants:​​ ​
    • Lawful Permanent Residents (green card holders) who have been in the U.S. for five years or longer.​​ ​
    • Cuban and Haitian entrants​​ ​
    • COFA Migrants (Micronesia, Marshall Islands, and Palau)​​ ​
    • When they are lawfully present (Children’s Health Insurance Program Reauthorization Act):​​ ​
  • People under age 21​​ ​
  • Pregnant people (including 12 months postpartum)​​ ​
  • Members enrolled in Program of All-Inclusive Care for the Elderly (PACE).​​ ​

7. How many CCS members are affected as a result of the UIS to FFS Transition?​​ ​

DHCS estimates as of August 2026, that statewide, the UIS transition will affect approximately 1,463 CCS members in Whole Child Model (WCM) counties and 5,676 CCS members in Classic counties. (These estimates are subject to change.)​​ ​

8. Which CCS members are impacted by the Medi-Cal FFS delivery system transition? What is the timeframe for the transition?​​ ​

All CCS Medi-Cal members, ages 0–20 with UIS will transition from the Medi-Cal MCP delivery system to the FFS delivery system on January 1, 2027.​​ ​

9. Will CCS members with UIS enrolled in Medi-Cal and transitioning to the FFS delivery system lose Medi-Cal eligibility and be transitioned to CCS-Only?​​ ​

No. CCS members with UIS enrolled in Medi-Cal and transitioning to the FFS delivery system will remain enrolled in CCS and Medi-Cal as long as they continue to meet Medi-Cal eligibility requirements.​​ ​

10. What are DHCS expectations for County CCS Programs to ensure members transitioning delivery systems maintain access to CCS eligible services?​​ ​

  • CCS WCM Counties – CCS members residing in WCM counties will no longer receive CCS case management from their Medi-Cal MCP. Instead, they will receive case management from the County CCS Program. CCS authorized services must be provided by a CCS-paneled and enrolled Medi-Cal FFS provider. County CCS Programs are expected to provide case management and support in navigation within the Medi-Cal FFS delivery system for the member’s CCS-eligible condition(s).​​ ​
  • CCS Classic Counties – There is no change in expectations for the case management of CCS-eligible conditions. The County CCS Program remains responsible for providing CCS case management services to CCS members with UIS enrolled in Medi-Cal FFS. As part of case management of CCS-eligible conditions, County CCS Programs will be expected to support all CCS members with navigating the Medi-Cal FFS delivery system for the member’s CCS-eligible condition(s).​​ ​
  • Independent and Dependent Counties – CCS SARs will continue to be adjudicated by the County CCS Program in Independent Counties or by DHCS in Dependent Counties.​​ ​
CCS County Type​​ ​Independent CCS​​ ​Dependent CCS​​ ​
Whole Child Model (33)​​ ​17 Counties: Butte, Humboldt, Marin, Mendocino, Merced, Monterey, Napa, Orange, Placer, San Luis Obispo, San Mateo, Santa Barbara, Santa Cruz, Shasta, Solano, Sonoma, Yolo​​ ​16 Counties: Colusa, Del Norte, Glenn, Lake, Lassen, Mariposa, Modoc, Nevada, Plumas, San Benito, Sierra, Siskiyou, Sutter, Tehama, Trinity, Yuba​​ ​
Classic CCS (25)​​ ​15 Counties: Alameda, Contra Costa, Fresno, Kern, Los Angeles, Riverside, Sacramento, San Bernardino, San Diego, San Francisco, San Joaquin, Santa Clara, Stanislaus, Tulare, Ventura​​ ​10 Counties: Alpine, Amador, Calaveras, El Dorado, Imperial, Inyo, Kings, Madera, Mono, Tuolumne​​ ​

11. How will County CCS Programs know what CCS members are impacted by the FFS transition?​​ ​

DHCS provided all County CCS Programs with a listing of impacted CCS members on October 9, 2026. DHCS plans to provide Counties updated member lists on November 20th and December 18th, so that the Counties have the most updated list as possible before January 1, 2027. Note that CCS Programs may run the CMS 39 Report in MSBI, to identify CCS members who recently lost Medi-Cal.​​ ​

12. If a UIS member gives birth while receiving restricted-scope Medi-Cal, can the infant use the mother’s coverage until the infant receives their own Medi-Cal benefits?​​ ​

Yes. The mother’s emergency Medi-Cal coverage remains valid for one year. During that time, the infant may use the mother’s emergency Medi-Cal coverage until the infant receives their own Medi-Cal benefits. If the infant is suspected to have a CCS eligible condition, a referral should be sent by the provider to the County CCS Program for consideration. County CCS Programs should follow existing application processes and direct applicants who may qualify for Medi-Cal to submit a Medi-Cal application. See the CCS Administrative Case Management Manual.​​ ​

13. Will FFS providers receive a reimbursement bump or other financial augmentation for services rendered to CCS members?​​ ​

There is no change to this policy: CCS-paneled physicians who provide services to CCS members in FFS will continue to receive the 39.7% augmentation rate.​​ ​

14. What options are available to CCS members in the event Private Duty Nursing (PDN) providers cannot be located in FFS?​​ ​

Families can use a combination of one or more home health agencies and/or Independent Nurse Providers (INP). In addition, Pediatric Day Health Care (PDHC) may be substituted for hours authorized for in-home nursing services. Counties and/or families can also seek out nurses and if they are willing to accept the Medi-Cal rate. DHCS encourages these nurses to enroll as Medi-Cal FFS providers. Please see CCS NL 02-0626 EPSDT – Private Duty Nursing Case Management Services NL for additional guidance.​​ ​

15. What are DHCS’ expectations of MCPs associated with the FFS transition?​​ ​

Please refer to the Policy Guide for Transition of the Unsatisfactory Immigration Status Population from Managed Care to Medi-Cal Fee-For-Service (See Version 3.0 DHCS Policy Guide and Refer to DHCS APL 26-016 and CCS UIS NL 03-0926 for additional details.)​​ ​

By October 15, 2026, all MCPs (Classic and WCM) were required to submit to DHCS a Transition Plan for all transitioning CCS members. The Transition Plan provides details on the planning efforts MCPs are undertaking including:​​ ​

  • Transition of authorized services​​ ​
  • Provider Communication to enable continuity of provider access to CCS paneled providers and specialty care centers actively treating CCS members​​ ​
  • Member Outreach​​ ​

In addition, by November 9, 2026, WCM MCPs must provide the County CCS Program with a CCS Transition of Care Plan for each CCS member with UIS who will be transitioned out of the WCM MCP. The CCS Transition of Care Plan will assist the County CCS Program in providing continuation of CCS Program-covered services to CCS members with UIS. The County CCS Program and WCM MCP are required to work together to establish a mutually agreed format for sending the CCS Transition of Care Plans. The County CCS Program must work with the WCM MCP’s CCS liaison to resolve any questions or concerns about the CCS Transition of Care Plan. The CCS Transition of Care Plan must include:​​ ​

  • Most recent care management plan(s), including Transition to Adulthood care plans;​​ ​
  • Plan for each member’s care. The plan for each member’s care must identify if care will continue with each of their existing providers or require new providers. If a new provider is required, the plan must include the information of each new provider(s). If this is not yet available on November 2, 2026, this information must be made available prior to December 31, 2026;​​ ​
  • Current authorized CCS services and treatment including clinical documentation supporting the services; and​​ ​
  • A list of DME and provider contact information.​​ ​

Note: For one-time DME authorizations, the WCM MCP must ensure CCS members with UIS receive their approved DME by December 1, 2026. Subsequent or recurring DME must be authorized by December 31, 2026. The WCM MCP is responsible for payment and delivery of DME when authorized on or before December 31, 2026, even in cases where the DME is delivered after January 1, 2027.​​ ​

County CCS Programs may request the following additional documentation from WCM MCPs for continuation of CCS Program covered services for these categories:​​ ​

  • Authorizations issued for CCS-eligible conditions;​​ ​
  • Clinical documentation submitted in support of authorizations issued for CCS-eligible conditions;​​ ​
  • Care plans; and​​ ​
  • Member contact information.​​ ​

By December 1, 2026, WCM MCPs must submit to DHCS a signed Attestation confirming that the CCS individualized Transition of Care Plans and supporting clinical documentation for the CCS-eligible condition was submitted to the County CCS Program directly.​​ ​

16. When do WCM County CCS Programs assume responsibility for CCS members with UIS impacted by the UIS transition?​​ ​

January 1, 2027. WCM MCPs are responsible for providing case management and diagnostic and treatment services to assigned CCS members through December 31, 2026. The effective date of transition to the FFS delivery system is January 1, 2027. As of that date, all County CCS programs will provide case management to its CCS members with UIS. Independent Counties are expected to adjudicate SARs, and DHCS will provide the same for Dependent Counties, as of this date. WCM County CCS Programs should reference the WCM MCP-provided Transition of Care Plan to identify CCS member needs, including actions needed in relation to CCS SARs.​​ ​

17. What resources is DHCS providing to Counties to support the increased administrative workload associated with the UIS transition?​​ ​

DHCS will allocate an additional $1.9 million total for the first six months of 2027 to WCM County CCS Programs to support the case management activities anticipated with the shift from Medi-Cal MCPs to Medi-Cal FFS. This additional funding will be allocated based on UIS caseload and will be issued for January 2027 and represent the six-month impact for the shift in workload. DHCS is not providing additional allocations to Classic County CCS Programs. DHCS is working to release the funding to WCM counties as soon as possible prior to January 1, 2027.​​ ​

18. What if our County CCS Program does not have adequate capacity to absorb the additional caseload and work associated with the FFS transition?​​ ​

DHCS acknowledges County CCS Programs have limited capacity for increased workload. WCM Counties will receive an additional allocation to support the increased workload. DHCS anticipates minimal impact in Classic CCS Counties because counties currently perform case management and administrative activities. Please note that DHCS is working to establish care management functions to support all UIS members who are part of this transition, following 1/1/2027. More details will be forthcoming and available on the Transition to Medi-Cal Fee-for-Service webpage.​​ ​

19. With the increased reliance on Medi-Cal FFS providers, what steps is DHCS taking to ensure an adequate Medi-Cal FFS network of CCS-paneled providers?​​ ​

Existing CCS provider paneling requirements remain applicable regardless of whether a provider is enrolled in a Medi-Cal MCP network or in the Medi-Cal FFS delivery system. DHCS is conducting an analysis of CCS-paneled providers that are enrolled in and currently submit claims for payment through the Medi-Cal FFS delivery system (results to be provided by end October). DHCS will conduct outreach to CCS-paneled providers that currently only participate as Medi-Cal MCP network providers to encourage their participation in the FFS claiming/payment system. County CCS Programs are expected to assist CCS members and their families navigate the Medi-Cal FFS delivery system for CCS-eligible conditions. Visit the Medi-Cal FFS Provider Listing webpage for a comprehensive listing of Medi-Cal FFS providers available.​​ ​

20. For durable medical equipment (DME) authorized and/or ordered leading up to the January 1, 2027, effective date, which payer should be billed? For example, DME was ordered by the WCM MCP provider in December 2026, but it was not delivered to the CCS member until January 2027. Is the WCM MCP responsible for paying the provider or does the provider need to bill Medi-Cal FFS?​​ ​

The WCM MCP is responsible for payment and delivery of DME when authorized on or before December 31, 2026, even in cases where the DME is delivered after January 1, 2027.​​ ​

21. If a CCS-paneled provider is in contract with a Medi-Cal MCP but is not a Medi-Cal FFS-participating provider, what happens to the authorization that was issued to the MCP provider? Will a new request need to be initiated by an FFS provider? What steps do County CCS Programs need to take in this situation?​​ ​

A new SAR should be issued on or after January 1, 2027, to the new FFS CCS-paneled provider. If a new FFS CCS-paneled provider has not been identified upon transition, the County CCS Program will work with the CCS member and family to find a new FFS CCS-paneled provider. For more information see the DHCS Provider Finder Hub and the CCS Paneled Provider List.​​ ​

22. Will the transition from managed care to the FFS delivery system impact CCS redetermination dates for CCS members with UIS?​​ ​

No, CCS members will not experience impacts to their CCS Program Eligibility End Date. CCS members with UIS impacted by the FFS transition will have their CCS Program annual medical review (AMR) conducted by the County CCS Program at the member’s regularly scheduled interval, and Medi-Cal eligibility will be determined by County Social Services Department at the member’s regularly scheduled renewal date.​​ ​

23. Who will be responsible for providing notices to CCS members that will be impacted by the FFS transition?​​ ​

DHCS will mail one notice to CCS members that will be impacted by the FFS transition. CCS members are expected to receive the notice by December 1, 2026. Notices will be issued via U.S. mail and translated into Medi-Cal’s 19 threshold languages and into alternative formats, if requested. DHCS will begin a text message campaign, providing information on the FFS transition to all Medi-Cal UIS members. Text messaging is set to start October 9th and recur monthly through December. The text message will be in the member’s preferred language. MCPs are required to send a CCS member notice to impacted members no later than December 1, 2026.​​ ​

24. Who will be responsible for providing notices to CCS-paneled providers about the FFS transition?​​ ​

DHCS will send out a provider bulletin with information on the FFS transition.​​ ​

25. How will the FFS transition impact access to maintenance and transportation related to a CCS-eligible condition?​​ ​

In Classic Counties, there is no change to the maintenance and transportation process. In WCM Counties, requests for maintenance and transportation on or after January 1, 2027, are to go to the County CCS Program for review and approval. DHCS offers additional guidance and services for FFS members. Please see Medi-Cal FFS Member Reimbursement and the DHCS FFS Transportation Reimbursement FAQ.​​ ​

26. What services are not available under FFS that CCS members with UIS will no longer be able to access?​​ ​

Enhanced Care Management (ECM), Complex Care Management (CCM), Transitional Care Services (TCS), and Community Supports are not available under the Medi-Cal FFS delivery system. Providers are encouraged to leverage available case management and care management billing codes as well as other services that allow for care management and case management to the extent they can do so within Medi-Cal billing rules.​​ ​

27. What case management or care management services will the CCS members with UIS be able to continue accessing? What are the case management and care management billing codes?​​ ​

County CCS Programs will provide medical case management services for the CCS-eligible condition(s). For non-CCS-eligible conditions and needs, Medi-Cal FFS providers are able to bill for the following services:​​ ​

  • Community Health Worker Services (CHW): CHWs will continue to be available to members in Medi-Cal FFS following the transition. CHW billing codes are CPT 98960, HCPCS G0019, HCPCS G0022. Refer to the Medi-Cal Provider Manual for billing guidance. Psychiatric Collaborative Care Management: Psychiatric collaborative care management services are reimbursable when billed by the treating physician or other qualified health professional for treatment of a patient’s mental health or substance use disorder. Refer to Evaluation & Management (E&M) for billing guidance.​​ ​
  • Comprehensive Perinatal Service Program: Comprehensive psychosocial services and health education services are reimbursable under program guidance. Refer to Pregnancy: Comprehensive Perinatal Services (CPSP) List of Billing Codes for billing guidance.​​ ​

28. Would the state consider a special expansion to cover CCS youth, age 21 years or older, who are undocumented?​​ ​

Given budget and other constraints, DHCS is not extending CCS coverage for individuals 21 years old or older. It is important to note that only a subset of UIS individuals (undocumented) who are newly applying to Medi-Cal would receive emergency or restricted-scope Medi-Cal. Undocumented children who age out of CCS, but are grandfathered in state-only full-scope Medi-Cal prior to January 1, 2026 (and meeting all renewal requirements thereafter) or UIS individuals in PRUCOL or lawfully permanent residents under the 5-year bar will still continue on state-only full-scope Medi-Cal. Members continuing on state-only full-scope Medi-Cal should not experience impacts to their Medi-Cal coverage, if all eligibility requirements continue to be met.​​ ​

Work and Community Engagement Requirements under H.R.1​​ ​

Federal H.R. 1 requires certain Medi-Cal members to demonstrate compliance with work or community engagement requirements (WCER) to remain eligible for Medi-Cal coverage, effective January 1, 2027.​​ ​

29. H.R. 1 requires states to impose work and community engagement requirements on beneficiaries ages 19-64 as a condition of eligibility for Medi-Cal beginning January 1, 2027. How will this requirement impact CCS Medi-Cal members?​​ ​

Medi-Cal members in the New Adult Group must demonstrate compliance with WCER or qualify for an exemption from the requirements to be determined eligible for Medi-Cal. Recent federal guidance specifies that the medical frailty exemption must “significantly impair” an individual’s ability to work. DHCS is reviewing CCS eligibility as a categorical exemption on the basis of medical frailty. However, in 2027, if DHCS’ approach is not considered compliant, CCS members may self-attest that their condition limits their ability to work.​​ ​

30. Will individuals who lose Medi-Cal eligibility due to not meeting work requirements still be eligible for CCS-Only?​​ ​

No. Not meeting or not reporting WCER work, study, or volunteer hours is a procedural reason for losing Medi-Cal. Upon discontinuance of Medi-Cal coverage, CCS Medi-Cal will also be discontinued. Members who lose Medi-Cal for a procedural reason are not eligible for CCS-Only and must restore or reapply to Medi-Cal before CCS coverage can be considered.​​ ​

31. Will individuals who lose Medi-Cal eligibility due to not meeting work requirements be able to restore their Medi-Cal eligibility?​​ ​

In accordance with DHCS Policy, and All County Welfare Directors Letter (ACWDL) 25-30 Existing Medi-Cal members who cannot meet the work and community engagement requirement may return to Medi-Cal coverage without a new application during the 90-day cure period once they provide information to the County Social Services Department demonstrating compliance with the requirement. Medi-Cal coverage, including Medi-Cal CCS coverage, is discontinued at the end of the Medi-Cal renewal date if the member does not procedurally comply with Medi-Cal renewal or Medi-Cal work and community engagement requirements. Reference DHCS guidance for additional information on work and community engagement requirements​​ ​

32. How will County CCS Programs know the date and the reason(s) a CCS member loses Medi-Cal eligibility due to work requirements?​​ ​

County CCS Programs can identify the date and reason for termination by running the CMS 39 Active Cases with Recently Terminated Medi-Cal Coverage report in MSBI.​​ ​

33. If a CCS parent, or legal guardian, loses Medi-Cal due to noncompliance of work or community engagement requirements, would Medi-Cal eligibility need to reassess for the child independently?​​ ​

Individuals’ Medi-Cal eligibility is determined at the individual level. A child whose parent/legal guardian is disenrolled will maintain coverage if otherwise eligible.​​ ​

Gia hạn sáu tháng​​ ​

Federal H.R. 1 requires Medi-Cal members ages 19–64 in the New Age Group to have their Medi-Cal eligibility determined every six months instead of every 12 months, effective January 1, 2027.​​ ​

34. Beginning January 1, 2027, H.R. 1 requires states to conduct Medi-Cal eligibility redeterminations every six months (instead of every year) for Medi-Cal Members who gained coverage through the Affordable Care Act (ACA) adult expansion. How will this requirement impact CCS Medi-Cal members?​​ ​

CCS members with Medi-Cal ages 19–20 who are in the New Adult Group will be subject to H.R. 1 six-month Medi-Cal renewal requirements. County Social Services Departments will continue to determine Medi-Cal eligibility. CCS members with Medi-Cal ages 0-18 will continue to have 12-month renewal cycles.​​ ​

35. Will DHCS offer any extensions if more time is needed to submit documentation to renew Medi-Cal at the six-month renewal date?​​ ​

Medi-Cal coverage, including Medi-Cal CCS coverage, will be discontinued if Medi-Cal renewal paperwork is not submitted by the renewal deadline. If the member’s coverage is discontinued but the member completes the Medi-Cal renewal within the 90-day cure period, Medi-Cal coverage can be reinstated retroactively with no gap in coverage. After that 90-day period, members who lose coverage due to procedural noncompliance must restore Medi-Cal eligibility before CCS coverage can be considered.​​ ​

36. Will individuals who lose Medi-Cal eligibility due to six-month renewals still be eligible for CCS-Only?​​ ​

CCS members ages 19–20 in the New Adult Group who lose Medi-Cal because they did not complete their renewal have a 90-day cure period to complete their paperwork. If they complete the renewal within this 90-day cure period and are still eligible, Medi-Cal is reinstated with no gap in coverage. If they do not complete the renewal within the cure period, they have lost Medi-Cal for a procedural reason and are not eligible for CCS-Only; they must reapply to Medi-Cal before CCS coverage can be considered.​​ ​

Members whose completed renewal finds them no longer eligible (eligibility reason), such as being over the income limit, may be assessed by the County CCS Program for CCS-Only. County CCS Programs should educate CCS members ages 19–20 on the importance of completing Medi-Cal renewals on time.​​ ​

37. How will County CCS Programs know the date and the reason(s) a CCS member loses Medi-Cal eligibility due to six-month Medi-Cal renewals?​​ ​

In the same way Counties can do this now with the 12-month renewal cycle. The County CCS Program can run the CMS 39 Active Cases with Recently Terminated Medi-Cal Coverage report in MSBI.​​ ​

38. What can the County do to help CCS members and families keep their Medi-Cal CCS?​​ ​

Reiterate the importance of completing their Medi-Cal renewal paperwork on time and refer them to their County Social Services Departments for assistance with completing their Medi-Cal application. . Counties can also provide education and resources to CCS members and families on the H.R. 1 and Budget changes. DHCS Medi-Cal changes can be found on the Medi-Cal Changes webpage.​​ ​

Retroactive Medi-Cal Reimbursement Changes​​ ​

Federal H.R. 1 limits the ability of Medi-Cal to retroactively cover medical bills prior to a Medi-Cal application, effective January 1, 2027. Instead of the three-month retroactive coverage that Medi-Cal members receive today, adults 19–64 in the New Adult Group are limited to one month of retroactive coverage while all other members (including children, seniors, disabled individuals and non-MAGI groups) are limited to two months. This reimbursement change pertains to the period before the Medi-Cal application, and is not pertaining to the 90-day Expansion Grace Period for Undocumented Adult Expansion Freeze nor the 90 day cure period for the 6-Month Renewal (or the Annual Renewals) as outlined above.​​ ​

39. How will retroactive Medi-Cal reimbursement changes impact CCS members?​​ ​

Pursuant to H.R. 1’s eligibility changes that are effective January 1, 2027, CCS members ages 19–20 who are in the New Adult Group may only have one month of past medical bills covered by Medi-Cal, while all other Medi-Cal CCS members will be limited to two months. This is a change from the current 3-month retroactive reimbursement coverage period prior to the Medi-Cal application month.​​ ​

UIS Monthly Premiums​​ ​

Beginning July 1, 2027, certain Medi-Cal members with UIS will be required to pay a monthly premium to retain their full-scope Medi-Cal.​​ ​

40. How will Medi-Cal premiums be assessed on UIS members ages 19–59? Who will be responsible for determining compliance with this requirement?​​ ​

Medi-Cal CCS members with UIS ages 19–20 will be subject to a monthly premium as a condition of eligibility for Medi-Cal beginning July 1, 2027. The monthly premium amount is anticipated to be between $30 and $50 and will be finalized as part of the 2027 State Budget process. DHCS anticipates providing further guidance on this topic at a later date.​​ ​

41. UIS Medi-Cal members who miss more than three months of premium payments are subject to disenrollment from full-scope Medi-Cal. If a CCS member misses three months of premium payments and loses full-scope Medi-Cal eligibility, what happens with this CCS member?​​ ​

Not paying required premiums is a procedural reason for losing Medi-Cal, and Medi-Cal CCS coverage would end as of the date of Medi-Cal discontinuance. Members who lose Medi-Cal for a procedural reason are not eligible for CCS-Only. Members with UIS must reapply to Medi-Cal before CCS coverage can be considered. Because of the enrollment freeze, undocumented members who reapply will only qualify only for restricted-scope Medi-Cal, and the County CCS Program may then assess them for CCS-Only eligibility.​​ ​

Medi-Cal Asset Limit​​ ​

For certain members who obtain Medi-Cal coverage through non-Modified Adjusted Gross Income (MAGI) processes, Medi-Cal will count assets to determine if an individual can get or keep Medi-Cal coverage. Effective July 1, 2027, asset limits will be lowered from the current $130,000 per individual ($195,000 per couple) to $21,000 per individual and $31,000 per couple. (See the Medi-Cal Asset Limit FAQ for additional details)​​ ​

42. The Medi-Cal asset limit will be lowered to $21,000 per individual and $31,000 per couple beginning July 1, 2027. How will this policy change impact CCS members with Medi-Cal coverage?​​ ​

If a member loses Medi-Cal due to asset limits, which is considered an eligibility reason (rather than a procedural reason),then the member could potentially still qualify for CCS-Only. The member should be assessed for CCS-Only eligibility by the County CCS Program.​​ ​