AB-220 Medi-Cal: subacute care services
Sep 27, 2026 edition · GC-2026-0055 · Published 2026-09-27 · Version 2 · Proposed
Pending AB 220 would limit extra pediatric subacute criteria and duplicate authorization forms, with specific protections for return from an acute-hospital bed hold.

What happened
AB 220 would prevent a Medi-Cal managed care plan from imposing additional pediatric subacute eligibility criteria when the provider substantiates one of the listed statutory pathways. Those pathways describe particular technology and skilled-nursing dependencies; the medical-necessity determination is expressly for a potentially eligible patient transferring from acute care to subacute care. The proposal does not make every medically complex child eligible without the specified evidence. At this edition’s cutoff, it remains a proposal rather than an operative new plan requirement.
If DHCS develops a standard authorization or reauthorization form for pediatric or adult subacute services, plans would have to accept it as sufficient and could not demand their own separate form. The bill also bars a subsequent treatment authorization request when a patient returns from the specified bed hold for acute hospitalization. DHCS could sanction violations of those form and return-authorization provisions. Clinical criteria, the conditional standard-form rule and the bed-hold protection therefore address separate steps in a transfer and authorization workflow.
Scope and timing
- Authority status
- Proposed
- Applicability
- Potentially applicable
- Audience
- Health systems, Provider networks
- Jurisdiction
- California
- Affected functions
- Utilization Management, Managed Care, Compliance, Legal, Clinical Operations
- Responsible owner
- Utilization Management
Why it matters
A transfer can be delayed by an extra clinical screen, a duplicate form or a repeat authorization request. Each proposed limit has a different trigger and scope.
Recommended action
Compare pediatric subacute criteria, authorization forms and acute-hospital bed-hold return procedures with the proposal. Monitor the bill and DHCS instructions; do not apply the proposed changes as enacted coverage.
Sources
- AB220 proposed bill text, historical selected versionOfficial · California Legislature · 2026-09-03 · Source review 2026-10-15
- AB220 official bill historyOfficial · California Legislature · Source review 2026-10-15
Complete edition and supplemental material
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