Question: What is the difference between the “early intervention” and other specialty mental health services (SMHS)?

Answer: ACBHD EI SMHS Model is the start of the SMHS continuum of care, which includes the following three components: 1) Outreach 2) Access and Linkage 3) Mental Health Tx Services and Supports.

The program is intended for members whose symptoms first appear or are identified (e.g., early psychosis), and care/services are initially sought out.

Additionally, these programs: 1) serve the full age range, allowing the entire family to be incorporated and be the focus of treatment; 2) include culturally responsive and linguistically appropriate interventions and strategies to advance equity and reduce disparities, 3) include outreach services as a key part of the model, 4) do not include medication support services (these would be referred to SMHS prescriber), and 5) are time limited, generally up to 24 months.

Question: Many of the refugee communities who are currently eligible for and accessing Medi-Cal will lose Medi-Cal due to H.R. 1. This means that someone like Kiry may lose Medi-Cal and no longer access specialty mental health. Does the county have any plans to serve those who will become newly ineligible from Medi-Cal?

Answer: ACBHD EI SMHS Model is to serve 90% who have Medi-Cal or are Medi-Cal eligible. This is already flexing the DHCS Medi-Cal maximization expectations.

The program goal is to become self-sustaining via Medi-Cal Fee-for-Service (FFS) revenue, which allows for greater ability to serve Non-Medi-Cal members with remaining capacity.

Additionally, the goal is for EI programs to bill under a FFS model within 2 years. If there is a different direction given by DHCS the county will align to a new message and will communicate that to the EI SMHS providers.

Question: A holistic whole-person approach to care (psycho-social) model was mentioned, as well as trauma informed care. This brings me to the cultural and spiritual component. Which means we should look at Psycho-social-spiritual care. Can you help me understand the place of spiritual component to care?

Answer: Cultural and spiritual considerations are important when working with members and may be incorporated into their plan of care. Examples are, referrals and connection to spiritual supports, along with helping members add and successfully integrate coping skills (e.g. mindfulness, meditation, prayer) towards their wellness and recovery (i.e. Access and Linkage; MH Treatment Services & Supports).

Question: Can current preventative counseling members or past preventative counseling members be referred to this program?

Answer: Yes, prior members can be referred, if they meet SMHS criteria.

Question: Can we see members longer than 1 year during the 26-27 transition contract year? We’d like to keep the Medi-Cal members we have in the program, if appropriate, beyond a year so that we have them as we transition into a Medi-Cal contract. But we need to know if the UELP 1 year service limit for a member still applies during the transition year.

Answer: Yes, you can continue to see them longer than the 1 year under UELP. The new BHSA EI SMHS program begins July 1, 2026. At this point a UELP program no longer exists, and your funding is for a new program model. If you have Medi-Cal members that were being served under UELP and meet criteria for SMHS you can then see them under the EI SMHS model for up to a 24-month period. There can also be exceptions to this if a member has additional needs to be addressed. This will be determined on a case by case basis.

Question: Question: Can a member graduate down from SMHS to EI SMHS if they are doing well but need services to maintain from decompensating again? Or is it only one way?

Answer: Members may go up and down in level of care, including down to EI SMHS.

Question: Question: Are you saying we can’t provide services in community sites? For example, staff see members in community settings like mosques. What about places that are public like parks, libraries, etc.? In some cultures, home is problematic for confidentiality.

Answer: As long as confidentiality can be maintained, SMHS can be provided in the field, community or home.

Question: If an Asian Health Services EI Medi-Cal member meets medical necessity criteria for SMH psychiatry services, can the member receive services concurrently under both the EI SMHS Program and another SMHS Program?

Answer: Yes, as long as services are non-duplicative. If clinically appropriate, a member’s care may transition in full from the EI SMHS Program to another SMHS Program.

Question: Are we expected to serve only the UELP category type that we mainly serve in our existing UELP contract or are we able to serve other members who fall into the UELP categories within our service area? For instance, the MHSA UELP contracts 25% allowance for such situations. What will it be going forward?

Answer: The UELP program model and contract regulations will no longer be in effect as of July 1, 2026. The new EI SMHS Programs will be required to provide services to the general population who meet SMHS criteria. We also recognize that some providers who have cultural/linguistic focus may continue to serve the special populations they currently serve, as they also expand their service population.

Question: How do you bill for activities for members receiving linkage who will not become a member?

Answer: EI SMHS Model includes both member 1) access and linkage to care, and 2) treatment services.

A member’s case is opened (i.e. becomes a client) when access and linkage to care services are provided.

Additionally, a provider can use MAA billing codes for an unopened case to provide them with information on mental health services or other Medi-Cal services. This will be covered in future trainings.

Question: Is there a cap on outreach billing for example if we have one program whose role is outreach at schools through prevention presentation and through that outreach we have a linkage path for access and linkage could one staff’s primary job role be billed to outreach?

Answer: The EI SMHS Program Model is a blend of 1) Outreach, 2) Access and Linkage, and 3) MH Treatment Services. All EI SMHS programs are expected to render all components.
ACBHD will evaluate programs, establish baselines and expectations (to include accounting for specific population nuances, if needed).

Subsequent training modules (i.e. EI SMHS Program Funding & Revenue Structure; Service Procedure Modes (e.g. CPT)) will provide more detailed guidance.

Question: We are hoping to have braided funding and are applying for private grants to fund some non-Medi-Cal aspects of the program. Are there any issues with that?

Answer: Not that we are aware of. That is a common funding strategy for many agencies.

Question: With the shift to CalAIM., County is being reimbursed as a FFS. So is the goal to fund the program with Medi-Cal FFS revenue which allows to serve non-Medi-Cal members with remaining capacity?

Answer: The goal is to shift the program to a Medi-Cal treatment model. Under a fully fee-for-service (FFS) model, the program must be sustainable based upon payments for treatment services and will allow for greater ability to serve Non-Medi-Cal clients with remaining capacity.

Question: Are we able to bill for dual-eligible members (Medi/Medi)?

Answer: Yes, programs will be required to enroll in Medicare. Programs must first bill Medi-Care for dual eligible members and report the status to ACBHD-Billing and Benefits Support. Medi-Cal is the payor of last resort, meaning it will cover costs not paid by the primary insurance.

Question: Do agencies also have to register with DHCS?

Answer: All EI SMHS program sites (address, to include suite number, if applicable) must be Medi-Cal Site Certified by ACBHD and issued a DHCS Provider number.
ACBHD’s Quality Assurance team sends all the necessary site certification documentation to DHCS regarding a site’s Medi-Cal certification. Providers do not need to separately register with DHCS. ACBHD does this on behalf of the provider/program.

Question: Is a site certification needed for community sites as well? Like schools, home, faith based locations, etc.?

Answer: Medi-Cal site certification is required at any site where Medi-Cal SMHS will be provided to members; there must also be a current fire clearance in place.
This is typically a clinic, counseling center, or a public school if youth receive services there, etc. If a clinic provides primarily community-based work, Medi-Cal certification will still be required for the physical location of the program. Homes are excluded.

Question: Is the expectation that we complete the three steps here before July 1st? Or is there any transition period.

Answer: ACBHD will be working with providers to complete the three Medi-Cal Site Certification steps indicated on Module 1, MHSA to BHSA: Becoming a Medi-Cal Provider, slide 32, with the goal of having the program ready to bill Medi-Cal by July 1, 2026. We recognize that on a case-by-case basis, some providers may need additional time to complete the necessary steps.

Question: If the fire department is backed up and is not doing fire clearances right now is there a work around?

Answer: There is no workaround unfortunately, as this is a requirement per the State. Some providers reported having had good luck scheduling these appointments earlier when they have visited their fire dept in person to explain what they need and why it is needed in an expedited fashion.

Many towns have an online fire inspection request system that expedites the process. The sooner the request is submitted, the better.

QA has not heard of many delays in fire departments’ abilities to conduct fire inspections. On the rare occasion, we have seen delays for programs located outside of Alameda County when there were fires in certain counties and it was unsafe for fire departments to conduct inspections.

Question: Will providers be asked/need new Program IDs for the transition from PEI to EI?

Answer: If you are a current provider with a SmartCare Program ID, we will use this and add the additional codes needed to make your program an EI SMHS program.

Question: Those who are already utilizing SmartCare, are they going to continue using SmartCare or are they required to use a different platform (i.e. Therapy Notes) for members’ files, treatment plans etc.?

Answer: Yes, SmartCare and Clinician’s Gateway (CG) will be used. For providers who are not already utilizing SmartCare and Clinician’s Gateway we highly recommend that your program use these systems as they provide the technology and security needed to adhere to HIPAA regulations.

Question: Do programs with existing certified clinics need to file a PCRF for this change or are we good to go and can skip this step since we’re already certified?

Answer: If a program already has a valid Medi-Cal site certification, they may not need to go through the site certification process again. Once ACBHD has confirmed the service function codes and procedure codes required for EI SMHS (with our internal SMAs), the Contracts Unit will complete the PCRF and send through DocuSign for signatures. If QA identifies service functions on the PCRF that are not certified for the EI SMHS program site, they will contact the provider to recertify the program including conduct a site visit, if appropriate.

Question: Don’t schools manage their own site certification for Medi-Cal?

Answer: ACBHD currently works with CBOs that provide SMHS within public schools to ensure those schools go through the Medi-Cal site certification process. ACBHD works directly with those CBOs to obtain the necessary site certification documents, then submits those documents to DHCS on behalf of the CBO. The schools themselves are not involved in the process.

Question: When a child/youth joins outpatient SMHS and then provider determines following an assessment that interventions would be best provided in the community, meaning at the child’s school site, does the school site need to be certified or is this considered a field visit?

Answer: If a program provides SMHS at a school, this can be considered a field visit which would not require the school to be Medi-Cal certified. If the provider chooses to have the school become a dedicated site (a site listed in their contract), then it would require that site to have a Medi-Cal certification.

Question: Don’t community members need to be qualified for “specialty mental health” criteria for us to enroll as client?

Answer: Yes, due to California Advancing and Innovating Medi-Cal (CalAIM) access criteria, the threshold to qualify for SMHS is lower.

Of note, a suspected mental disorder that has not yet been diagnosed qualifies for SMHS, and services rendered during the assessment period remain reimbursable even if the assessment ultimately indicates the member does not meet criteria for SMHS.

Please reference Module 1, MHSA to BHSA: Becoming a Medi-Cal Provider, slides 19-22.

Question: Does an individual have to meet SMHS Access Criteria and Medi-Cal eligibility?

Answer: Yes, SMHS Medi-Cal Necessity/Access Criteria has to be met. Reference MHSA to DHCS Transition: Becoming a Medi-Cal Provider, slides 19-22. EI SMHS Programs are expected to serve 90% who have Medi-Cal. When a program becomes self-sustaining via Medi-Cal Fee-for-Service (FFS) revenue, there is greater ability to serve non-Medi-Cal clients with remaining capacity.

Question: Does this mean that we do not need to diagnose, we just need to suspect there may be a diagnosis?

Answer: No, an actual diagnosis is expected upon assessment completion. Upon case opening, as assessment begins and continues, a suspected mental disorder is Medi-Cal billable/claimable.

Providers operating within their scope of practice should complete a thorough assessment and diagnostic evaluation. Proper and accurate diagnosing continues to be an important component to providing quality clinical care. However, for the purposes of access to outpatient SMHS, there are options based on the presentation of the individual that do not necessitate a diagnosis.

All Medi-Cal claims are required to be submitted with a HIPAA-compliant ICD-10-CM code and that has to be established by a provider working within their scope of practice and all SMHS has to be “under the direction” of a licensed behavioral health clinician.

Question: Will we need to do assessments and treatment plans for individuals in the EI SMHS program?

Answer: Standard SMHS outpatient documentation requirements and establishment of medical necessity apply.

While a diagnosis may not be required to access SMHS in some situations, completing a thorough MH assessment and diagnostic evaluation are important to providing quality clinical care.

Treatment and discharge planning remain as important clinical activities that should be done as clinically appropriate. With CalAIM, the requirement for standalone treatment plans was eliminated for most services. More information will be provided regarding these requirements during the Documentation training module.

Question: Where should the EI member be referred to if they need further medication treatment?

Answer: Depending on the age of the member there are many options available within the outpatient SMHS system, and within the larger health system for psychiatric medication treatment.

Members needing an evaluation for psychiatric care can be referred to psychiatrists within the SMHS system, or through the MCP, FQHCs, primary care, or other providers able to prescribe psychotropic medications. For a full list of providers within SMHS, please refer to our provider directory.

Providers can reach out to ACCESS for these referrals.

Question: What screening tools can be used in the Access and Linkage component? Is the DHCS screening tool a requirement? Can we develop our own tool? We don’t want to have a big screen that we then have to repeat during the intake and assessment phases.

Answer: Standardized Screening tools were developed by DHCS to help call centers determine whether services should be provided by SMHS (mental health plan) or non-SMHS (managed care plan). guide referrals to the Medi-Cal mental health delivery system, Managed Care Plan (MCP) or Mental Health Plan (MHP). The tools are not required for use with:

• Members who are currently receiving mental health services, or
• Members who contact mental health providers directly to seek mental health services.

For additional information, see ACBHD memo: https://bhcsproviders.acgov.org/providers/QA/memos/2022/Provider-Memo-re-Draft-Screening-Tools-2022.12.19.pdf

Question: Can members be served through outreach and engagement through a group modality? If so then can the group members not yet have a working DX?

Answer: SMHS Medi-Cal offers several types of group services such as therapy, rehab, peer, and family groups. Claims for Medi-Cal members participating in allowable SMHS group services are submitted the same as individual claims, but with specific group codes. If a member does not yet meet criteria for a DSM diagnosis, but meets access criteria for SMHS, other codes, such as Z codes, may be used for claiming.

Question: Does the Lay Counselor cover the peer specialist requirement?

Answer: Lay Counselors can more immediately be classified under SMHS Medi-Cal as either Mental Health Rehabilitation Specialist (MHRS) or Other Qualified Provider types. Another route is to become a Certified Peer Support Specialist (CPSS), which requires training and passing a certification process through California Mental Health Services Authority (CalMHSA), a Joint Powers Authority, providing support to county mental health departments.

Question: What role can Interns (currently in grad school) play on the Tx team? Assuming that they are under the supervision of a LMHP.

Answer: Please  to ACBHD Policy 1603-3-3 “ACBHD Clinical Trainee Policy” (8/28/24) for information about utilizing clinical trainees within BH Medi-Cal programs.

Question: What category would Chaplains who provide spiritual care fall under?

Answer: BH Medi-Cal does not include chaplains as an allowable provider type.

Question: Providing Spiritual Support – What is your response for making referral to a spiritual community or a certified chaplain’s work?

Answer: A chaplain providing spiritual support is not a SMHS service type and can’t be claimed. If a chaplain meets qualifications for a SMHS provider type (e.g., Other Qualified Provider) and they perform a SMHS activity allowed for that provider type (e.g., Rehabilitation), that service could be billed to Medi-Cal. The DHCS SMHS Service Table provides information about allowable SMHS provider types and which procedure codes they can use.

Question: For those who completed the CPSS course where can they sign up for the test?

Answer: CalMHSA manages peer certification for Medi-Cal peer support specialists. Here is their website: https://www.calmhsa.org/peer-certification/

Question: Will EI services be subject to SMHS QA criteria, or will these be later developed?

Answer: Yes, EI will be subject to SMHS criteria.

Question: Are we expected to report the number of members under EI, as we did with PEI, in addition to Medi-Cal billing hours?

Answer: Your data will be entered in SmartCare and Clinician’s Gateway by billing hours per client.