Two Million Medi-Cal UIS Patients Transitioning to FFS September 30, 2026 Educational, Practice Management Two Million Medi-Cal UIS Patients Transitioning to FFS Updated September 29, 2026 ACCMA hosted a “townhall” meeting on September 24th with our local Medi-Cal managed care plan CEOs about a significant change in how approximately 2 million Californians receive care. Beginning January 1, 2027, Medi-Cal patients with “unsatisfactory immigration status” (UIS) will transition from managed care to the Medi-Cal fee-for-service (FFS) system. The transition follows 2025 federal guidance that California has interpreted as prohibiting this population in Medicaid managed care risk-based contracts. Affected patients will remain enrolled in Medi-Cal, but their medical care will no longer be provided through their managed care plan or its network. To continue caring for these patients, physicians must have the appropriate Medi-Cal FFS enrollment and be prepared to use its billing and authorization processes. If you missed last week’s discussion or would like to revisit the information presented: Watch the meeting recording: Zoom Recording Passcode: eJLt?04. View the presentation slides: Alameda Alliance for Health Contra Costa Health Plan What Physicians Should Do Now 1. Verify your Medi-Cal fee-for-service enrollment Participation in a Medi-Cal managed care network does not necessarily mean you are ready to provide and bill for FFS services. Confirm that you are actively enrolled under your individual Type 1 National Provider Identifier (NPI), with the appropriate enrollment to support reimbursement for the care you provide. If enrollment is needed, apply promptly through the Provider Application and Validation for Enrollment (PAVE) system. Physician enrollment applications can take up to 90 days to process. An ordering, referring and prescribing (ORP)-only enrollment does not authorize reimbursement for services you provide directly to patients. Physicians planning to treat patients transitioning to FFS should ensure their enrollment supports the ability to bill for services. 2. Prepare your billing and authorization processes Beginning January 1, services provided to affected patients will no longer be reimbursed under your managed care contract. Claims will instead be submitted through the Medi-Cal FFS system and paid according to the Medi-Cal FFS fee schedule. Review these changes with your billing staff or billing service, including claims submission procedures, applicable payment rates and Treatment Authorization Request (TAR) requirements. Do not assume that managed care billing or authorization procedures will carry over to FFS. 3. Coordinate with health plans to protect continuity of care DHCS is requiring managed care plans to communicate with contracted providers serving affected patients about the transition, enrollment requirements and steps to maintain continuity of care. Practices should review plan communications, identify patients whose ongoing care may be disrupted and seek guidance on pending authorizations, referrals and treatment extending into 2027. Give particular attention to patients receiving complex treatment or relying on multiple providers. Monitor the DHCS transition webpage for additional implementation guidance. Alameda Alliance Provider Relations: 510-747-4510 or providerservices@alamedaalliance.org CCHP Provider Relations: 877-800-7423, option 6 or Online 4. Help patients understand what is changing Patients should understand that this transition changes how they access care; it does not, by itself, end their Medi-Cal eligibility. They will need providers who accept Medi-Cal FFS and should renew/revalidate their coverage on time. Let affected patients know whether your practice will continue seeing them through FFS. Remind them to bring their Medi-Cal Benefits Identification Card to appointments beginning January 1, rather than relying on their managed care plan card. DHCS has posted patient notices, outreach materials and other resources on its transition webpage. Patients needing help finding an FFS provider can call the Medi-Cal Help Line at 1-800-541-5555. Additional FFS Requirements to Review Keep your provider directory information current With more patients seeking FFS providers, accurate directory information will be especially important. Enrolled FFS providers must review and update their directory information at least quarterly - in January, April, July and October. The next review is due in October. Required information includes office phone numbers, acceptance of new patients, telehealth availability, languages, disability accommodations and a website, if available. Billing providers should use the Medi-Cal Provider Portal, selecting “Manage Organization” and then “Public Fee-for-Service Provider Directory.” Organization Administrator or NPI Administrator permissions are required. Individual non-billing providers should complete the Provider Directory Survey linked on the DHCS directory requirements webpage. Updating your enrollment record in PAVE does not satisfy this separate directory requirement. Prepare for ordering, referring and prescribing enrollment enforcement Separately, DHCS will begin phased enforcement of Medi-Cal ORP enrollment requirements in February 2027. Physicians and other eligible practitioners who order, refer or prescribe services for Medi-Cal patients must be enrolled under their individual Type 1 NPI; an organizational Type 2 NPI does not satisfy this requirement. Physicians should verify their enrollment now. Those already enrolled under their individual NPI as a billing, rendering or other qualifying FFS provider do not need a separate ORP-only application. Those who only order, refer or prescribe may use the ORP-only pathway through PAVE. As CMA has reported, enforcement will vary by provider and service type, and the detailed phase schedule has not yet been publicly posted. Practices could encounter claim denials involving an unenrolled ordering or referring provider before enforcement reaches their own physicians’ ORP activity. See the DHCS ORP enrollment information page for instructions. Enrollment questions may be directed to ORP@dhcs.ca.gov.