ECM Presumptive Authorization: How California Providers Can Start Serving Members Before the MCP Approves
August 21, 2026
Quick summary: Under DHCS policy, select ECM providers already contracted in an MCP's network can directly authorize ECM for an eligible member and be paid for services delivered during a 30-day window, without waiting for the plan's authorization decision. You still have to submit the referral for full authorization inside that 30 days. Separately, standardized ECM Referral Standards limit what plans can ask referring entities to provide. Together these two policies removed most of the historical excuses for authorization delay — but only if your documentation can keep up.
The problem these policies were built to fix
ECM serves the highest-need members in Medi-Cal: people exiting incarceration, families losing housing in the next 30 days, members discharged from a hospital with nowhere to go. For those members, a four-week authorization delay is not an administrative inconvenience. It is the whole intervention, missed.
DHCS policy has long directed plans to complete these authorization decisions quickly, and in practice the process regularly took far longer. DHCS's response was two coordinated policies, both effective January 1, 2025.
Policy one: standardized ECM Referral Standards
The ECM Referral Standards define the set of information all MCPs collect through an ECM referral. Before this, an organization referring members across three plans in two counties was navigating three different forms with three different data requirements.
The operative constraint for providers is what plans cannot ask for. Under the standards, MCPs may not require documentation beyond the information in the ECM referral — DHCS specifically names ICD-10 codes, supplemental checklists, and Treatment Authorization Request (TAR) forms as examples of what plans can no longer demand for ECM.
That last one matters. TARs remain part of the Community Supports world at many plans. They are not supposed to be a gate on ECM.
A few other things the standards preserve:
- Referring partners keep multiple submission options — electronic, EMR-based, or hard copy. DHCS prefers electronic referrals but built PDF form templates for community entities that can't submit any other way.
- Members and their families can continue to self-refer to ECM through the plan's Member Services. This is true across every Population of Focus.
Policy two: expanded presumptive authorization
Presumptive authorization allows specific contracted ECM providers, for designated Populations of Focus, to directly authorize the initial ECM service for a period of 30 calendar days and be paid for services delivered in that window while the plan's decision is pending.
Three things to understand about how this actually works:
It is not open to everyone. DHCS established required pairings of ECM provider types and Populations of Focus that plans must extend presumptive authorization to. Those pairings are a floor, not a ceiling — plans are free to extend presumptive authorization to more providers and more Populations of Focus, and some do. Whether you have it depends on your contract and your Population of Focus. Ask your plan directly, in writing.
You still have to submit the referral. Presumptive authorization is not a waiver of the referral process. Providers operating under it must still submit a referral to the MCP for full authorization within the 30-day window. Miss that and you have delivered a month of unauthorized care.
The 30 days run from initiation, not from a convenient reset point. Your system needs to be counting from the day services started, and it needs to be visible to the person responsible for submitting the referral — not buried in a note.
A related rule: MCPs cannot add eligibility criteria
This one comes from the ECM Policy Guide rather than the authorization guidance, and it is worth knowing because it gets violated informally.
DHCS states that plans must use the Population of Focus eligibility criteria as written and may not impose additional eligibility requirements for authorization of ECM. DHCS gives a specific example: a plan may not require that the ECM provider have a certain number of contacts with the member as a condition of authorization.
If a plan is telling you a member won't be authorized until you've documented some minimum number of touches, that is not a DHCS requirement.
What presumptive authorization demands from your documentation
Here's the uncomfortable part. Presumptive authorization transfers risk to you.
When the plan authorizes first, the plan has effectively confirmed eligibility before you spend anything. When you authorize presumptively, you are asserting that the member meets a Population of Focus definition — and you will need to show it. If the full authorization is later denied on eligibility grounds, the conversation about that 30 days is one you want to have with a record, not a recollection.
So the documentation bar is:
- Eligibility basis captured at the point of initiation. Which Population of Focus, and which specific criterion within it. "Homeless" is not a record. "Adult experiencing homelessness under criterion (a)(1)(v) — will imminently lose housing within 30 days, eviction notice dated [X]" is.
- The 30-day clock, tracked and visible. With the referral-submission deadline surfaced before it expires, not after.
- Every encounter in the window documented to full ECM standard — staff type, modality, date, and content — because if authorization comes through, those encounters are billable and need to be codeable.
- Outreach attempts recorded individually, since initiation outreach is separately reportable and both successful and unsuccessful attempts count.
The other clock: closed loop referrals
DHCS's Closed Loop Referral policy adds a further expectation on the plan side — that a referral to ECM or Community Supports gets resolved and the underlying member need gets addressed rather than disappearing into a queue. DHCS has indicated it may request ad-hoc documentation, conduct audits, or introduce other measures to verify this is happening.
For providers, the practical read is that referral disposition is now a monitored data point. If your organization refers members into Community Supports or receives referrals from community partners, keeping a record of what happened to each referral is no longer just good practice.
What to do this quarter
- Confirm in writing whether you have presumptive authorization, and for which Populations of Focus. Many providers assume they don't have it and have never asked.
- Audit your last 20 authorizations for turnaround time. If they are routinely taking weeks, you have a documented pattern to bring to your plan's provider relations team.
- Check whether any plan is still asking for ICD-10 codes, checklists, or TARs on ECM referrals. If so, cite the ECM Referral Standards.
- Find out where your 30-day clocks currently live. If the answer is "a care manager remembers," that's the gap.
Where CareAutomate fits
CareAutomate is an operations platform for Medicaid and HCBS providers. For ECM teams working under presumptive authorization, the value is that the whole chain lives in one place: intake and eligibility basis, the authorization window and its deadline, member profiles, encounter documentation with timestamped electronic signatures, and per-member unit tracking against the authorization — configured per plan contract, so your team isn't chasing three different plans' rules across three systems.
That consolidation is also what produces a defensible record. When a plan asks why you initiated ECM on a given date, the answer is a structured record with the eligibility criterion, the outreach attempts, and every encounter that followed — captured at the point of service rather than reassembled afterward. Documented encounters convert into billing-ready output, including a compliant 837P generated from the service data itself.
If you're operating under presumptive authorization and tracking those 30-day windows manually, book a walkthrough.
This article summarizes DHCS's ECM Referral Standards, ECM presumptive authorization policy, and the CalAIM ECM Policy Guide (updated January 2026). Presumptive authorization availability varies by provider type, Population of Focus, and plan — confirm your specific arrangement with your MCP.