OHCA first-year provisional NOLA (labor-cost adjustment) requests still due November 16, 2026
Published November 8, 2026 · Coverage November 1–7, 2026, Pacific · High priority
California's Office of Health Care Affordability (OHCA) enforces health care spending targets set by its Health Care Affordability Board, and the law lets the Board adjust targets when non-supervisory organized labor costs are expected to grow faster than the target, through a Non-Supervisory Organized Labor Adjustment (NOLA). For the first year, OHCA must receive all requests for a provisional NOLA by November 16, 2026 (by the end of October in future years). NOLAs apply to providers and fully integrated delivery systems, not health plans; a labor union may initiate a request but the regulated entity must attest, and all NOLAs are provisional until confirmed with actual expenditure data.
Current status
OHCA's Slow Spending Growth page, read on November 10, 2026, states the November 16, 2026 deadline for first-year provisional NOLA requests and says requests can be submitted at the NOLA portal. The earlier edition reported this deadline without confirming it from an official page; this edition confirms it from OHCA's page.
Who this affects
Providers and fully integrated delivery systems subject to OHCA spending targets (not health plans), and labor unions initiating requests on their behalf
Why it matters
Inference: a hospital or system expecting non-supervisory organized labor cost growth above the target can have a provisional adjustment considered only if its request reaches OHCA by November 16. Without one, OHCA's page says an entity that misses the spending target is sent a notice of exceeding it and potential enforcement action, and then has 45 days to show that growth in non-supervisory organized labor costs caused all or part of the excess. Finance, labor relations and legal should confirm whether a request is being filed, and who attests, before November 16.
Required actions
- A provider seeking a first-year provisional NOLA must have its request received by OHCA by 2026-11-16 (NOLA portal).
Recommended action
- Decide whether to file; if a union initiates, prepare for the attestation step.
- Retain the projections and labor-agreement support, since NOLAs are provisional pending actual data.
Scope and timing
- Authority status
- Operative duty
- Responsible owner
- Finance; Labor Relations; Legal; Compliance
- Compliance date
- 2026-11-16
- Other dates
- Page last modified 2026-11-04 per the pages API of the Department of Health Care Access and Information (HCAI) site (what changed not established); future years due end of October
Not established
The site's WordPress pages application programming interface (API) lists the page as modified 2026-11-04; whether that edit touched the NOLA text is not established. The NOLA portal itself was not opened.
Earlier article: October 18, 2026 edition →
Sources
Complete edition and supplemental material
This article in the complete report →
Executive triage, source-coverage limitations, context and forward horizons remain in the complete report.
Read the entire Compliance Sweep report →