What ECM and Community Supports Providers Must Do Before the January 2027 Medi-Cal FFS Transition
[!NOTE] Quick summary: Beginning January 1, 2027, Medi-Cal members with Unsatisfactory Immigration Status will move from managed care to Medi-Cal fee for service. Their full-scope Medi-Cal coverage can continue if they renew on time, but ECM and Community Supports are not available in fee for service. DHCS's October provider toolkit adds concrete steps for FFS enrollment, eligibility verification, Treatment Authorization Requests and continuity planning.
[!NOTE] Important: Providers should act only on official DHCS or managed care plan information. Do not determine a member's immigration category or give immigration advice.
What changes on January 1 2027
Affected members will no longer receive covered services through a Medi-Cal managed care plan. They will use Medi-Cal fee for service and may see providers enrolled in FFS. Providers will bill DHCS directly when the service is covered, and authorizations that require review will use the DHCS Treatment Authorization Request process rather than the managed care plan process.
The transition changes the delivery system, not automatic Medi-Cal eligibility. DHCS says affected members retain full-scope coverage if they renew on time. However, ECM, California Integrated Care Management, Community Supports, Complex Care Management and Transitional Care Services are not available in Medi-Cal FFS.
Confirm fee for service enrollment now
A provider's managed care contract does not automatically create FFS enrollment. DHCS says providers that want to continue furnishing FFS-covered services must be enrolled in Medi-Cal FFS. Already enrolled billing providers do not need a new application solely for this transition. Providers that are not enrolled must initiate the correct enrollment pathway, generally through PAVE for eligible provider types, and DHCS warns that processing takes time.
Provider Portal administrators must also keep acceptance status current. The toolkit says updating whether the organization is accepting new FFS patients is required quarterly. Enrollment does not obligate a provider to accept every member, but the status must be accurate.
Treatment Authorization Requests can begin November 1
DHCS says it will accept TARs beginning November 1, 2026 for affected members and dates of service on or after January 1, 2027. A special-handling pathway is available when DHCS has an approved managed care authorization on record and an enrolled FFS provider requests authorization for the same service.
The provider must still submit an electronic TAR that meets minimum requirements. When an approved MCP authorization is available in DHCS records, supporting attachments for medical justification will not be required under the special-handling process. Providers should not assume every authorization transferred. Confirm member, service, dates, rendering provider and authorization status before scheduling care.
How eligibility verification changes
Beginning January 1, affected members will present their Benefits Identification Card rather than relying on the former plan card. DHCS says members will not automatically receive a replacement BIC because of the transition. Providers can verify eligibility through the Automated Eligibility Verification System or an available point-of-service method and should retain the verification result in the record.
The ECM and Community Supports transition list
Use official plan or DHCS rosters and notices. For each identified member, track:
- Current ECM, Community Supports and other care-management enrollments, authorizations and planned end dates.
- Open referrals, scheduled services, care-plan goals, housing, food, transportation, clinical and behavioral health risks.
- The member's FFS providers, whether those providers are enrolled, and any capacity or appointment barriers.
- TAR responsibility, submission status, DHCS or MCP reference numbers and decision dates.
- Member and representative notices, language needs, contact attempts, outcome and unresolved questions.
- Final managed care service notes, encounters, invoices and claims for dates before transition.
- Referrals to available community resources and the person responsible for follow-up.
What support may remain available
DHCS identifies other FFS services that may support some needs, including Community Health Worker services, psychiatric collaborative care management, Comprehensive Perinatal Services Program services, doula services, dyadic services, asthma preventive services and certain Targeted Case Management. Coverage, provider qualifications and billing rules differ. The toolkit explicitly warns that the examples do not guarantee that every provider type can bill each code.
DHCS is also working to identify additional care-management billing codes. That statement is not a commitment that ECM or Community Supports will continue under different codes. Providers should wait for written billing authority and not relabel a discontinued benefit.
Eight actions to complete before January
-
Verify FFS enrollment and revalidation status for every billing and rendering provider involved.
-
Update Provider Portal acceptance and capacity information and establish the quarterly review owner.
-
Confirm the affected member roster with each MCP and record the source and date of every transition flag.
-
Identify services that end December 31 and needs that can transition to a covered FFS or community resource.
-
Prepare eligible TARs beginning November 1 and reconcile them with existing MCP authorizations.
-
Test eligibility verification and document the BIC, AEVS or point-of-service workflow before go-live.
-
Complete managed care documentation, encounters and billing promptly and retain plan-specific cutoff instructions.
-
Document member communication, referrals, accepted or declined support, remaining risks and final responsibility.
Frequently asked questions
Will affected members lose full scope Medi Cal?
Not solely because of this delivery-system transition. DHCS says members can keep full-scope coverage if they renew on time.
Will ECM or Community Supports continue in FFS?
No. DHCS lists both as unavailable in Medi-Cal FFS.
When can transition TARs be submitted?
DHCS says November 1, 2026 for impacted members and dates of service beginning January 1, 2027.
Does an MCP authorization automatically become a TAR?
No. The FFS provider still submits an eTAR. Special handling may reduce supporting attachments when DHCS has the approved MCP authorization on record.
Will members receive a new BIC?
Not automatically. DHCS says they should continue using the existing BIC unless a replacement is otherwise needed.
How CareAutomate can support the transition
CareAutomate supports centralized member records, authorizations, tasks, outreach documentation, service notes, transition checklists and billing preparation. Providers can use these workflows to track service end dates, TAR status, referrals, member contacts and unresolved risks. CareAutomate does not determine immigration status, Medi-Cal eligibility or whether a service is payable in FFS. Book a demo to map the transition workflow and confirm what is available today versus what requires configuration.
Official sources
- DHCS FFS Provider Toolkit
- DHCS Stakeholder News - October 19, 2026
- DHCS Medi-Cal Fee-for-Service Transition
Delivering CalAIM ECM or Community Supports?
Take members from enrollment → care plan → monthly contacts → clean PMPM submission. Purpose-built for California CalAIM and housing providers.