A. Overview
Behavioral Health Individual Service Level (ISL) encounter reporting captures all individual level behavioral health services provided directly to clients by city agencies (Berkeley and TriCity Mental Health) and county behavioral health systems (collectively referred to as “counties”), and county provider networks (collectively referred to as “providers”). These reporting requirements apply only to services that are not reimbursable through the Medi-Cal program.
Pursuant to WIC sections Pursuant to WIC sections 5963.04(a)(2)(H) and (I), 5963.04(b), and 5897(d)), effective January 1, 2027, counties are required to submit ISL encounters for all services delivered on and after January 1, 2027 to DHCS.
Beginning July 1, 2026, counties may begin submitting ISL encounters to DHCS for services delivered between July 1, 2026, and December 31, 2026. This period will be used for testing and technical assistance (TA) purposes only. DHCS will not utilize data submitted during this six-month period for county performance measures or monitoring; data submitted will solely be used for purposes of refining and strengthening ISL reporting. Counties that do not submit ISL encounters during this time period will not be required to submit those encounters retroactively.
Starting January 1, 2027, counties must submit ISL encounters for services delivered to individuals:
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Not enrolled in Medi-Cal at the time-of-service delivery who receive any county-operated or contracted behavioral health services or expenditures
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Enrolled in Medi-Cal who receive any county behavioral health services or expenditures not claimed for Medi-Cal reimbursement by counties
At a minimum, counties must submit ISL encounters to DHCS annually, no later than 90 days after the close of the fiscal year (FY) in which services were rendered. All encounters must be aligned with DHCS’ ISL guidance and technical resources.
County behavioral health Medi-Cal covered services delivered to a Medi-Cal-enrolled individual must be billed through Short Doyle and CA-MMIS and should not be reported as ISL encounters.
B. ISL Encounter Reporting Technical Resources
The ISL Code Library, the ISL Encounter Fields, and the ISL Validation Rules Catalog, together comprise the core technical resources for ISL reporting.
B.1. ISL Code Library
The ISL Code Library is a comprehensive list of service codes that must be reported through ISL encounter reporting. All service codes that are billable via Short Doyle and CA-MMIS are included in the ISL Code Library.
For services reported through ISL that are also a covered Medi-Cal benefit but not claimed for Medi-Cal reimbursement, counties must submit the service as an ISL encounter using the same Healthcare Common Procedure Coding System (HCPCS) or Current Procedural Terminology (CPT) code and modifier combination that would be used for Medi-Cal billing.
For services reported through ISL that do not have existing HCPCS or CPT codes, counties must submit ISL encounters using DHCS-defined ISL service codes and modifiers. These codes are specifically designed to capture non-Medi-Cal-funded behavioral health services that are not otherwise represented in existing coding schemas.
B.2. ISL Encounter Fields
The ISL Encounter Fields are the data elements that counties will be required to submit for each encounter through ISL reporting. ISL encounters leverage a subset of American National Standards Institute (ANSI) X12 837 data elements that counties currently submit through Medi-Cal Specialty Mental Health Services (SMHS), Drug Medi-Cal (DMC), and Drug Medi-Cal Organized Delivery System (DMC-ODS) claims.
B.3. ISL Validation Rules
The ISL Validation Rules Catalog describes rules and logic used by DHCS to process encounters. It defines field dependencies, data element specifications, and data reference tables, and establishes the criteria used to conduct encounter processing.