Medi-Cal’s January 2027 Fee-for-Service Transition: A Practice Billing Checklist

Beginning January 1, 2027, Medi-Cal members affected by DHCS’s “unsatisfactory immigration status” (UIS) transition will move from managed care to fee-for-service (FFS), where Medi-Cal pays providers for individual services. UIS is DHCS’s program term for specified groups that do not meet federal Medicaid eligibility criteria. This is not a transition for every Medi-Cal patient, and it does not mean affected members automatically lose coverage. For practices caring for these patients, the immediate billing questions are enrollment, eligibility, claim routing and authorization.

Your first preparation steps

• Confirm whether your practice and rendering providers are enrolled for Medi-Cal FFS.

• Review upcoming appointments using current eligibility information and member notices.

• Check the FFS billing and authorization rules for the services you provide.

• Assign responsibility for claims that span the transition and for follow-up on unresolved payments.

DHCS’s provider transition FAQ is the starting point for the official requirements. The steps below translate those issues into a practical billing work plan.

Which patients and specialties should practices review?

Use official eligibility records and transition notices to establish whether each patient is affected and which billing arrangement applies.

Family medicine, internal medicine, pediatrics and specialty offices—including gastroenterology practices—caring for affected patients should review their workflows. Those specialties are operational examples; the transition is based on member eligibility, not a specialty list.

DHCS’s member fact sheet explains that members continue using their Beneficiary Identification Card. Pharmacy remains through Medi-Cal Rx, and specialty mental health and substance use disorder treatment remain with county behavioral health plans. Enhanced Care Management and Community Supports are not available in FFS, so staff should avoid telling patients that every part of their managed care arrangement remains identical.

Is your existing enrollment enough?

DHCS directs providers to check enrollment through PAVE and keep screening and revalidation current. Participation in a managed care network alone should not be treated as confirmation that the practice is ready to bill FFS.

Horizon recommends recording the enrollment status, provider identifiers and unresolved follow-up for each clinician and location involved. Resolve a missing or unclear status before relying on expected January collections.

This is separate from ordering, referring and prescribing enrollment checks. If those apply to your services, review our Medi-Cal ORP enrollment article alongside the transition preparation.

What changes for claims and authorizations?

DHCS says affected FFS claims will be billed directly to DHCS and that some services require Treatment Authorization Requests (TARs). Do not assume a managed care authorization automatically satisfies FFS requirements.

For each ongoing treatment, Horizon recommends keeping the service dates, existing authorization details, applicable FFS requirement and next action together. Confirm any transition-specific handling in the current guidance before resubmitting or requesting authorization.

Keep December and January services distinguishable in your billing work queues. Verify the payer responsibility for the date of service, and preserve the original submission and acknowledgment history. A blanket payer change across every open balance can make older claims harder to trace.

How can you spot problems early?

Review the first FFS claims for acceptance, adjudication and payment posting. Separate enrollment, eligibility, authorization, coding and routing problems so the correction addresses the actual cause. Assign an owner and follow-up date to unresolved items.

DHCS’s transition resource page links to current policy guidance and the FFS Provider Toolkit. Include a final source check in your preparation rather than treating an early checklist as the complete transition policy.

How Horizon Can Help With the Medi-Cal Billing Transition

Horizon can help practices organize enrollment follow-up, review claim routing, investigate denials and reconcile payments as part of our billing and credentialing support. We work with the billing software your practice already uses.

Call (408) 444-8845 or request a complimentary billing review to identify enrollment, authorization or claim-routing gaps that could delay collections during the transition.