Behavioral-health data sharing needs separate MCP and county implementation phases
Oct 11, 2026 edition · GC-2026-0327 · Published 2026-10-11 · Version 3 · Final
January consent and county implementation requirements accompany earlier managed-care obligations. DHCS offers an October learning session, while the actual directives preserve distinct deadlines and federal privacy limits.
What happened
APL 26-004 required managed-care plans to implement clarified exchange procedures by April 1, 2026. BHIN 26-013 gives behavioral-health plans and DMC counties until January 1, 2027 for the specified procedural updates; both systems must adopt ASCMI by January 1. Core care-coordination duties already apply. The October 14 learning collaborative is voluntary technical assistance, with one registration per county/plan dyad, rather than a substitute for implementation. January also marks focused monitoring and potential corrective or monetary enforcement.
The directives require bidirectional care-coordination information and ADT notifications without intentional delay, supported by at least monthly up-to-date rosters. Required reporting exchanges need not occur in real time. Part 2 roster information requires valid consent, and CalAIM permissions do not override federal privacy rules. ASCMI standardizes required consent without making every disclosure permissible. A signed revocation received by the provider protects information not yet shared, including earlier-collected data; it does not undo disclosures already made in reliance on consent. Plans must support consent storage and communicate obligations downstream.
Scope and timing
- Authority status
- Final
- Applicability
- Directly applicable
- Audience
- Health systems, Provider networks
- Jurisdiction
- California
- Affected functions
- IT, Compliance, Managed Care, Clinical Operations, HIM/CDI
- Responsible owner
- IT
- Recorded date
- 2027-01-01
- Date type
- implementation
Why it matters
Monthly rosters and bidirectional ADT notifications support coordination, but required reporting exchange need not be real time. Part 2 roster disclosures require valid consent. CalAIM permissions do not override federal privacy restrictions, and revocation protects information not yet disclosed.
Recommended action
IT, Compliance and Managed Care should test exchange with each county partner, reconcile the earlier MCP phase, implement consent ingestion and revocation controls, and communicate requirements to network providers. Participation in the voluntary session does not replace implementation.
Implementation playbook
- Test partner rosters and ADT exchange and identify any overdue MCP procedural changes. Internal target. IT · Due 2026-10-25
- Complete ASCMI adoption, valid Part 2 consent and prospective revocation controls; counties complete applicable procedural updates. Compliance · Due 2027-01-01
Sources
- Stakeholder News, October 5, 2026Official · California Department of Health Care Services · 2026-10-05 · Source review 2026-10-11
- All Plan Letter 26-004, Medi-Cal Managed Care Plan Responsibilities for Behavioral Health Data-SharingOfficial · California Department of Health Care Services · 2026-03-16 · Source review 2026-10-11
- Behavioral Health Information Notice 26-013, CalAIM Real Time Behavioral Health Data Sharing PolicyOfficial · California Department of Health Care Services · 2026-03-16 · Source review 2026-10-11
Complete edition and supplemental material
This finding in the complete approved report →Regulatory horizons, CIA trends and implementation trackers remain in the full report.
Read the entire Medicare & Medicaid report →