The CalAIM Waiver Expires December 31, 2026. Here's What ECM and Community Supports Providers Should Actually Do.
August 21, 2026
Quick summary: California's CalAIM Section 1115 demonstration and companion 1915(b) waiver expire on December 31, 2026. DHCS submitted a five-year renewal request to CMS in May 2026 for a proposed 2027–2031 term, and approval is broadly expected late in December 2026 — essentially at the deadline. The important thing for providers to understand is that ECM and most Community Supports do not depend on 1115 authority to continue. The uncertainty is real, but it is narrower than the headlines suggest.
What's actually expiring
CMS approved the CalAIM Section 1115 demonstration and the CalAIM Section 1915(b) waiver in December 2021, both effective through December 31, 2026. DHCS submitted its five-year Section 1115 renewal request to CMS in May 2026, proposing a renewed term running January 1, 2027 through December 31, 2031, and has indicated it will submit the 1915(b) renewal separately.
Both requests were informed by DHCS's Continuing the Transformation of Medi-Cal concept paper, released in July 2025, and by stakeholder input from public and Tribal comment periods.
The expected timeline is uncomfortable but not unusual: negotiations between CMS and DHCS spanning most of 2026, with approval anticipated late December 2026 for January 1, 2027 implementation.
What continues regardless of the waiver
This is the part that gets lost.
ECM does not require Section 1115 authority. DHCS's own position, stated in its concept paper, is that ECM is authorized under federal Medicaid managed care regulations as part of managed care plans' care coordination and continuity of care responsibilities. No Section 1115 or 1915(b) authority is needed for California to operate ECM.
Most Community Supports do not either. DHCS has indicated that Section 1115 authority is not needed to continue ECM and the large majority of Community Supports, which can operate as in lieu of services under managed care authority. As part of the renewal, California proposed transitioning several CalAIM initiatives to alternative Medi-Cal coverage authority and sunsetting 1115 authority for them — a deliberate move to reduce dependence on the demonstration.
Transitional Rent runs on a different waiver entirely. Transitional Rent was authorized under the BH-CONNECT Section 1115 demonstration, which runs through 2029. It is not tied to the CalAIM waiver's December 2026 expiration.
DHCS has publicly reaffirmed that Community Supports remain unaffected and will continue operating.
What is genuinely uncertain
Being accurate about the risk matters more than being reassuring, so here is the honest version.
The federal environment has tightened. In June 2026, CMS released a State Medicaid Director Letter setting new budget neutrality guidelines for 1115 waivers, requiring states to provide more detailed cost-impact analyses earlier in the approval process and expanding the categories of cost CMS considers. In July 2025, CMS announced it would no longer approve or extend waivers for continuous eligibility beyond statutory requirements, and issued notice that it would stop approving existing workforce-related 1115 components such as student loan repayment and workforce training — which affected California's BH-CONNECT waiver.
Health-related social needs provisions face case-by-case treatment. CMS has signaled that HRSN provisions will be considered on a case-by-case basis in future waiver negotiations, and analysts have flagged that federal officials have indicated reluctance to approve new funding for rent assistance and medically tailored meals in future waiver applications.
Infrastructure funding is a separate question from service funding. Federal matching funds that previously helped finance CalAIM infrastructure investments — the capacity-building money that helped many CBOs stand up as ECM and Community Supports providers in the first place — are a different line item from the services themselves, and one under more pressure.
DHCS's renewal posture is deliberately conservative. The concept paper signals sustainability rather than expansion — no major new programs or populations. Analysts have read this as a credibility move for the federal negotiation. It is a reasonable strategy, and it also means providers should not plan around new benefit categories arriving in 2027.
The realistic read
Strip out the noise and the picture looks like this:
- ECM: very likely continues under managed care authority, independent of the waiver outcome.
- Most Community Supports: very likely continue, with the operative variable being plan-level election rather than federal authority.
- Transitional Rent: authorized separately under BH-CONNECT through 2029.
- Housing-related and infrastructure components: the genuine pressure points, both federally and in the state budget.
- Timing: approval expected late December 2026, which means providers will be planning FY2027 without final terms.
What providers should do between now and December
Don't pause. Don't over-invest in one line. Both are overreactions to the same uncertainty. The organizations that get hurt are the ones that either freeze — and lose contracted capacity to competitors — or expand aggressively into whichever Community Support is most exposed.
Concretely:
1. Know which of your services rest on which authority. If your revenue is concentrated in ECM, your exposure to the CalAIM 1115 outcome is low. If it is concentrated in a Community Support that DHCS is proposing to move to alternative authority, your exposure is about transition mechanics rather than continuation. Map it.
2. Build the outcome data now. DHCS's renewal case is built on programs with data demonstrating health outcomes and reduced costs. That logic doesn't stop at the state level — plans make the same calculation when deciding which providers to keep and expand. If you cannot currently produce clean utilization, engagement, and outcome data by member and by service, that is a gap that will matter in contract renegotiation long before it matters in Sacramento.
3. Diversify across Populations of Focus, not away from CalAIM. An ECM provider serving one Population of Focus for one plan has concentration risk that has nothing to do with the waiver.
4. Assume documentation scrutiny increases, not decreases. Budget-constrained programs get audited harder. Whatever your audit posture is today, the direction of travel is toward more.
5. Watch the 1915(b) submission and the CMS negotiation, not the commentary. DHCS's waiver page is the authoritative source.
The thing worth internalizing
Every one of the actions above is really the same action: know, in structured and retrievable form, what your organization delivered, to whom, under what authorization, and with what result.
Providers who can answer that in an afternoon are in a fundamentally different position — with plans, with auditors, and in any renegotiation — than providers who need three weeks and a spreadsheet. The waiver timeline just makes that gap expensive at a specific date.
Where CareAutomate fits
CareAutomate is an operations platform for Medicaid and HCBS providers. The reason we bring this up in a post about federal waiver authority is that the practical response to policy uncertainty is operational readiness, and readiness is mostly a data-structure problem.
CareAutomate consolidates intake, member profiles, care plans, service documentation, timestamped electronic signatures, and per-member unit tracking into one platform, with services and codes configured per client and per contract. When a code set changes or a service moves to a different authority, that is a configuration change your team controls — not a rebuild.
Because everything is captured at the point of service, the audit trail and the outcome reporting are the same asset viewed two ways: you can show a plan what you delivered and what it achieved, and show an auditor that it was authorized and documented. Documented services convert into billing-ready output, including a compliant 837P generated directly from the service records.
If you're heading into 2027 planning and can't currently pull that picture quickly, book a walkthrough.
This article summarizes publicly available information from DHCS's Section 1115 waiver pages, DHCS's Continuing the Transformation of Medi-Cal concept paper (July 2025), CMS guidance issued in 2025 and 2026, and published analysis of the renewal process. The renewal outcome was not final at the time of writing — confirm current status on DHCS's waiver page.