California Sent CMS a Medi-Cal BHT Amendment Effective July 1. Approval Is Pending.

California's Department of Health Care Services (DHCS) has submitted State Plan Amendment 26-0033 to CMS. The September 2026 letter says the SPA makes "technical amendments" to the behavioral health treatment (BHT) section of the state plan "to clarify policy, including utilization management controls, and support enhanced program integrity efforts aimed at reducing potential fraud, waste, and abuse." DHCS asks for an effective date of July 1, 2026, more than three months before the submission. The approval date on the form is blank, so it hasn't been approved. A companion Alternative Benefit Plan amendment, 26-0034, was noticed with it.

What the amended text says

The new Attachment 3.1-A and 3.1-B pages (18b, 18b.1 and 18c) describe BHT this way:

• Covered as medically necessary for Medi-Cal members under 21 on the recommendation of a licensed physician or licensed psychologist, under EPSDT.
• ABA is "a subset of specialized services under BHT" and "may be covered on an individual, case-by-case basis" for members with an autism diagnosis or another clinically appropriate diagnosis for which a licensed physician, surgeon or psychologist determines ABA is medically necessary. That recommendation must be documented.
• Services must be "provided, observed, and directed" under an approved behavioral treatment plan developed by a QAS provider, and delivered by a QAS provider, professional or paraprofessional.
• The plan is not used for respite, day care, recreational or educational services, and none of those is reimbursable.
• No reimbursement to a parent, legal guardian or legally responsible person for their participation under the treatment plan.

What we can't tell you

DHCS calls the changes technical, and the notice projects no added cost. We read the new text but could not retrieve the prior approved pages (SPA 24-0031) to compare line by line, so we can't say which of the provisions above are new. The "case-by-case" wording for ABA is the one to watch for how plans apply it.

What to do this week

• Owners and clinical directors: pull five Medi-Cal treatment plans and check that each states the plan isn't being used for respite, day care, recreation or education, and that the physician or psychologist recommendation is in the file. For any client without an autism diagnosis, the recommendation naming ABA as medically necessary matters most.
• Billers: confirm no claim bills a parent's or guardian's participation to a rendering line.
• Everyone: ask each Medi-Cal plan you contract with whether its ABA authorization criteria changed after July 1. The SPA is the state's language; plans apply it.