California’s Enhanced Care Management (ECM) program connects Medi-Cal members with complex needs to coordinated, community-based support. On September 16, 2026, the Department of Health Care Services (DHCS) released an updated ECM Policy Guide addressing managed care plan oversight, service intensity, and reporting.
For community-based organizations and behavioral health providers, these updates offer an opportunity to review how services are staffed, documented, monitored, and supported through health plan partnerships.
Understanding ECM’s Role
ECM provides comprehensive care management across a member’s physical health, behavioral health, and social needs. Its community-based approach helps members navigate services and coordinate care across organizations.
Effective implementation depends on relationships: between members and care managers, between providers, and between community organizations and managed care plans. Clear workflows help those relationships translate into timely support.
Clearer Expectations for Service Intensity
The updated guide emphasizes an average of three or more encounters per month, while recognizing that appropriate service intensity varies according to the member’s needs and population of focus. It also expects managed care plans to align payment and oversight with the intensity and quality of services delivered.
BHTPI recommends reviewing how your organization plans and documents member engagement. A useful internal review can ask:
Does each encounter address a documented care-plan need?
Can staff distinguish completed services from unsuccessful outreach?
Do caseloads allow consistent, meaningful engagement?
Are barriers to participation documented and addressed?
These questions help teams assess service quality alongside encounter volume.
Expanded Managed Care Plan Oversight
DHCS highlighted expanded guidance on managed care plan responsibilities, including program integrity, credentialing, network adequacy, timely member transfers, and utilization management.
The guide also adds a section clarifying managed care plans’ utilization management authority, including authorization timelines, service duration, and reassessment schedules, consistent with applicable requirements.
BHTPI recommends confirming operational expectations with each contracted health plan. Providers should have clear points of contact for authorization questions, member transfers, documentation concerns, and payment issues. Written procedures can help staff resolve problems consistently and preserve continuity of care.
Reporting Moves to a Monthly Format
DHCS announced that the Quarterly Implementation Monitoring Report was retired on August 14, 2026. ECM and Community Supports reporting now moves to monthly submissions through a streamlined electronic format.
The guide describes managed care plan submissions through a monthly JSON monitoring process. Provider organizations should confirm which information their contracted plans need, along with submission deadlines and formats.
BHTPI recommends building a monthly data review into routine operations. Assign responsibility for checking enrollment records, encounters, missing information, and discrepancies before submitting data to a health plan. Addressing errors throughout the month can reduce last-minute corrections.
Connecting Service Delivery and Financial Sustainability
DHCS’s emphasis on payment reflecting service intensity makes documentation and contract review particularly relevant.
BHTPI recommends comparing the work required to deliver ECM with the resources available to support it. That review can include staff time, travel, member engagement, coordination, supervision, and administrative work.
Organizations should bring documented questions about payment terms and service expectations to their managed care partners. A clear understanding of the contract helps leaders plan realistic caseloads and sustainable staffing.
Preparing Your Organization
BHTPI recommends five practical steps:
Review the September policy guide with program, clinical, billing, and data leaders.
Confirm health plan expectations for authorization, reporting, payment, and member transfers.
Assess staffing and caseloads against the needs of the members served.
Strengthen documentation workflows so records show the services delivered and their connection to care-plan goals.
Train staff on updated procedures and create a process for resolving implementation questions.
These are organizational recommendations intended to support implementation. Specific responsibilities should be checked against current DHCS guidance and each organization’s health plan agreements.
BHTPI supports workforce development, leadership training, and organizational capacity building for California’s behavioral health and community service organizations.
For information about BHTPI’s services, contact info@bhtpi.org or visit www.bhtpi.org.
Policy resource: DHCS Enhanced Care Management Policy Guide — September 2026
