SB 874 sets Medi-Cal behavioral treatment employee checks and stakeholder duties
Oct 4, 2026 edition · GC-2026-0252 · Published 2026-10-04 · Version 2 · Final
SB 874 requires patient-facing Medi-Cal behavioral treatment employee checks by July 1, 2027 and directs stakeholder, billing and reporting work.
What happened
California approved and filed SB 874 on September 27. By July 1, 2027, DHCS must ensure that each enrolled Medi-Cal entity providing reimbursed behavioral health treatment conducts, or has a third party conduct, a state and national criminal background check on employees who interact with patients. Providers must keep documentation available to DHCS on request or for a state or federal audit. This is a dated employee-check provision, distinct from the law’s separate stakeholder consideration of whether fingerprint-based checks should be required. As of October 4, teams should plan for the July milestone and confirm the implementing process rather than assume every form of fingerprint checking is already mandated.
DHCS must use existing forums for feedback on behavioral treatment coverage and billing, including assessment and reauthorization, treatment plans and outcomes, service settings, supervision, credentialing and quality-focused contracting. The guidance must remain consistent with EPSDT for people under 21. By January 1, 2029, DHCS must publish utilization data, a coverage-policy synopsis, feedback-driven changes and recommendations needed to align reimbursement with federal program-integrity requirements. Implementation is through letters, bulletins or similar instructions. The stakeholder process informs policy, while the enacted background-check and documentation provisions require a separate operational plan.
Scope and timing
- Authority status
- Final
- Applicability
- Potentially applicable
- Audience
- Health systems, Provider networks, Health-tech
- Jurisdiction
- California
- Affected functions
- Clinical Operations, Managed Care, Revenue Cycle
- Responsible owner
- Clinical Operations
- Recorded date
- 2027-07-01
- Date type
- compliance
Why it matters
Behavioral treatment organizations need employee-screening evidence and audit readiness alongside participation in the agency’s policy work.
Recommended action
Inventory patient-facing employees, existing state and national checks, third-party arrangements and documentation retention. Track DHCS implementation for July 1, 2027 and participate in coverage and billing forums.
Published long lead justification
The chapter expressly sets July 1, 2027 for DHCS to ensure enrolled BHT entities conduct state and national checks of patient-facing employees. Advance workforce inventory, screening arrangements and audit documentation are necessary before this date beyond the ordinary 180-day horizon.
Sources
- SB874 enacted final textOfficial · California Legislature · 2026-09-27 · Source review 2026-10-05
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