SB 874 requires BHT employee background checks and stakeholder-informed policy
Oct 11, 2026 edition · GC-2026-0252 · Published 2026-10-11 · Version 3 · Final
SB 874 combines a concrete Medi-Cal BHT employee-screening requirement with stakeholder-informed policy work. Fingerprint feasibility, coverage guidance, and later utilization publication remain separate from the enacted state and national background-check duty.
What happened
By July 1, 2027, DHCS must ensure that enrolled Medi-Cal entities providing program-paid BHT arrange state and national criminal background checks for employees who interact with patients, either directly or through a third party. Providers must retain compliance documentation and make it available on request or audit. The screening clause is not limited to a future stakeholder recommendation, and the statute does not make a blanket fingerprint method the condition for every check.
The stakeholder process addresses clinical assessment, treatment plans, service settings, supervision, credentialing, contracting quality, and feasibility of fingerprint-based checks. DHCS must maintain clear coverage and billing guidance consistent with EPSDT for people under twenty-one. By January 1, 2029 it must publish utilization data and a policy synopsis identifying feedback-driven changes and any needed program-integrity actions. These policy and publication duties complement the employee-check and recordkeeping requirement; participation in a forum alone does not demonstrate compliance with screening.
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, Compliance
- Responsible owner
- Clinical Operations
- Recorded date
- 2027-07-01
- Date type
- implementation
Why it matters
Patient-facing BHT employee screening needs documented state and national checks and auditable records. HR, clinical leadership and contracted-provider oversight should align hiring and retention controls with forthcoming DHCS implementation; participation in stakeholder work does not replace the enacted background-check duty.
Recommended action
Assign BHT compliance and HR to document state and national checks for patient-facing employees before July 1, 2027; track DHCS implementation and retain evidence for audit.
Implementation playbook
- Coordinate with HR to inventory patient-facing BHT employees and contracted entities; compare current state and national checks and record-retention controls. Internal preparation target. Compliance · Due 2026-10-25
- Assign a DHCS implementation monitor and document responsibility for auditable screening evidence and provider oversight. Internal preparation target. Compliance · Due 2026-10-25
- Reconcile issued DHCS instructions with screening procedures and close documented gaps before the statutory implementation milestone. Clinical Operations · Due 2027-07-01
Published long lead justification
The July 1, 2027 statewide implementation requires employee and contracted-entity inventories, state and national screening processes and auditable records. Early HR and provider-oversight preparation is justified despite the deadline exceeding 180 days; no human approval is claimed.
Sources
- SB874 enacted final textOfficial · California Legislature · 2026-09-27 · 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.
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