Medi-Cal's UIS Members Go Fee-for-Service Jan. 1. Plan-Only ABA Groups Must Enroll

On January 1, 2027, California moves Medi-Cal members with unsatisfactory immigration status (UIS) out of managed care and into fee-for-service. DHCS defines the group as undocumented members, some green-card holders in the five-year federal waiting period, and people residing in the U.S. under color of law. They keep full-scope Medi-Cal; what changes is who pays you and who authorizes the work.

Neither DHCS document we read names BHT or ABA. The FAQ says all medically necessary Medi-Cal covered benefits continue. The BHT rules below are our reading of what follows, not a DHCS statement about ABA.

The dates

Now. DHCS’s Provider Toolkit (version 1.0, October 14) says a provider who is already enrolled in Medi-Cal fee-for-service as a billing provider “doesn’t need to do anything new.” One who is not “must submit your application by January 1, 2027 to bill for these members.” Enrollment runs through the PAVE portal and “can take time to process.” DHCS’s September provider FAQ is blunter: providers who bill only through a managed care plan “will not be able to care for UIS members after December 31, 2026.”

November 1. DHCS starts accepting Treatment Authorization Requests (TARs) for these members, for dates of service on or after January 1. Where a plan authorization is on record for the same service, the new “special handling” option still requires an electronic TAR, but supporting attachments “will not be necessary.” For authorizations a plan received before January 1, the plan may keep processing them or send you to DHCS.

What the BHT manual says about fee-for-service

The Medi-Cal Provider Manual’s BHT section describes fee-for-service BHT for members under 21. They can use a Regional Center, or an enrolled Medi-Cal provider if they don’t qualify, were declined, or prefer to. ABA codes 97151 through 97158 bill directly with modifier U7 or 99. The manual also says “authorization is required to continue providing BHT services and/or modify existing BHT services” after the QAS Provider’s review, which it requires at least every six months, and that unauthorized services “shall not be considered for payment.” It doesn’t say how that authorization is obtained, or whether the Regional Center route is open to a UIS child. Neither DHCS document does.

What you must know or do

• Owners: Look your group up in PAVE today. If it has no Medi-Cal fee-for-service enrollment, file the application this week, not in December. Then ask each plan you contract with which of your clients are in the UIS group. DHCS says plans “are required to notify contracted providers” about the transition, so a plan that hasn’t should be asked why.
• Billing leads: List every UIS client whose plan authorization runs past December 31. Ask the plan in writing whether it will keep processing it or send you to a DHCS TAR. Ask the Provider Helpline, (800) 541-5555, whether BHT is covered by special handling, and get the answer on paper.
• Clinical directors: Check when each affected child’s six-month treatment-plan review falls, because the manual ties authorization to continue services to that review.
• If you won’t enroll: DHCS says to help each member move to an enrolled provider. Start before December 31.