How to Track AB 109 Clients in SmartCare

Assembly Bill (AB) 109 shifted the responsibility for monitoring, tracking, and incarcerating low level offenders from state prisons to county correctional offices. This shifts rehabilitation from being done in correctional facilities in favor of community-based services. Each county determines how to best address AB 109 clients, and how funding is allocated. While some county behavioral health departments may have specific AB 109 programs, others may have AB 109-funded clients in general programs.

This means that AB 109 cannot always be tracked using a program enrollment. Instead, this is a client-level characteristic, which means it’s tracked via “Special Populations” in SmartCare.

SmartCare has two Special Population list pages to segregate SUD-specific special populations from general special populations. Since a county may choose to fund specific type of services using AB 109 funding, it’s possible that a county may use AB 109 funding solely for SUD related services. If this is the case, then this special population needs to be hidden from non-SUD staff; otherwise this would be considered a breach of 42 CFR Part 2. It’s also possible that a county may use AB 109 funding for a multitude of services, which may or may not include SUD related services. When it’s unclear whether the special population “AB 109” includes substance use disorder services or not, then this special population does not need to be hidden from staff.

In order to address all potential aspects of AB 109, CalMHSA has created two special populations for AB 109. “AB 109 SUD” will show on the SUD Special Populations list page and “AB 109” will show on the non-SUD Special Populations list page. Each county will need to determine which global code to use, based on how AB 109 is implemented in their county.

If a county’s AB 109 services always includes SUD services, then the county should use global code “AB 109 SUD” only and deactivate the global code “AB 109”. This will ensure that only SUD staff can see when a client is part of the AB 109 population.

If a county’s AB 109 services may or may not include SUD services, then the county should use global code “AB 109” only and deactivate the global code “AB 109 SUD”. This ensures that AB 109 clients are all tracked in the same manner. A staff would not be able to infer that the client is receiving SUD services solely based on the use of this special population.

Global Code Category: “Special Populations” (Code: “xSpecialPopulations”)

Global Code: “AB 109”, External Code 2 = MH, Active only in counties that do not require SUDS to be part of AB 109 services.

Global Code: “AB 109 SUD”, External Code 2 = SUD, Active only in counties that require SUDS to be part of AB 109 services.

Updated 4/25/24