History
The Behavioral Health Services Act (BHSA) requires counties to provide specific evidence-based practices (EBPs) and other services in their Full Service Partnership (FSP) and Behavioral Health Services and Supports (BHSS) Early Intervention (EI) programs. It also requires county behavioral health plans (BHPs) to claim Medi-Cal for Medi-Cal-covered services delivered to Medi-Cal members.
On October 5, 2026, DHCS released BHIN 26-031, which explains how BHPs must claim Medi-Cal for these services starting January 1, 2027. DHCS will use the required codes and modifiers to:
- identify FSP and EI services in Medi-Cal claims data,
- calculate Behavioral Health Transformation (BHT) performance measures, and
- monitor how counties are implementing the BHSA.
This BHIN builds on BHIN 25-009, which gave BHPs the option to cover ACT, FACT, CSC, and IPS as bundled Medi-Cal services. It also refers to a forthcoming BHIN on High Fidelity Wraparound (HFW).
Summary of Requirements
Effective date: The requirements apply to claims with dates of service on or after January 1, 2027.
Required services: Counties must provide the following.
- FSP:
- ACT
- FACT
- IPS Supported Employment
- FSP Intensive Case Management (ICM)
- HFW
- Assertive Field-Based Initiation for SUD
- Other FSP services, such as peer support and recovery services
- BHSS EI:
- Coordinated Specialty Care (CSC) for First Episode Psychosis
- Other EI services, including EBPs and community-defined evidence practices (CDEPs)
Claiming approach:
- Counties that opted into bundled coverage for ACT, FACT, CSC, and/or IPS use the bundled monthly codes for those services.
- Counties that did not opt in claim the appropriate unbundled SMHS, DMC, or DMC-ODS services and add the modifier for that EBP.
- All BHPs, bundled or not, must use the specified modifiers to identify FSP ICM, Assertive Field-Based Initiation for SUD, other FSP services, and BHSS EI services.
- HFW must be claimed with the monthly code H2022 by all BHPs. Unbundled claiming is not permitted for HFW.
- Bundled ACT/FACT counties may also claim unbundled SMHS with modifier TS (ACT) or X1 (FACT) when a member receives 12 or more ACT or FACT services in a month.
Additional notes:
- The modifiers are for tracking and reporting only. They will not affect how claims are adjudicated.
- DHCS will add the modifiers to Short-Doyle Medi-Cal before January 1, 2027, and will notify BHPs when they are available.
- Services delivered to non-Medi-Cal members, and FSP or EI services that Medi-Cal does not cover, should be reported through Individual Service Level (ISL) encounters according to DHCS guidance.
- Housing Interventions are required under the BHSA but are not claimed to Short-Doyle Medi-Cal.
- Final DHCS guidance on HFW coverage is forthcoming in a separate BHIN. DHCS has stated that the requirement to use monthly code H2022 for HFW will not change in the final guidance.
SmartCare Implementation
CalMHSA has configured SmartCare for BH-CONNECT ACT, FACT, CSC, and/or IPS claiming. If your county has opted in to one of these EBPs and SmartCare has not been configured, please open a HubSpot ticket with the help desk to start this process.
CalMHSA is working to address the requirements for unbundled claiming for EBPs under BHSA that go into effect on 01/01/2027. This work is currently in analysis and design.
The HFW Policy Guide has not yet been finalized by DHCS. CalMHSA is monitoring the draft guidance, and billing configuration for HFW will begin once the Policy Guide is final.
We recommend attending Billing Office Hours for specific questions and updates on how this is being addressed. This protocol will be updated once details are available.