Section 7 - BHSA Components and Requirements
A. Behavioral Health Services and Supports
A.7 Early Intervention Programs
Early Intervention funds may also be used to provide supports and services to parents and caregivers. However, these services do not count toward the 51% requirement spent on individuals who are 25 years and younger unless the service is provided as part of an Early Intervention Evidence-Based Practice and Community-Defined Evidence-Based Practice (EBP and CDEP). Services that are provided as part of Early Intervention EBPs and CDEPs that support parents and caregivers count towards the 51% requirement, even if the child/youth is not present, as long as the service is for the benefit of that child/youth. EI funds can also be used to support innovative behavioral health pilots and projects within these parameters to build the evidence base for the effectiveness of new statewide strategies.
A.7.1 Early Intervention
Early Intervention services may be provided to individuals lacking a specific diagnosis. Indicated prevention interventions focus on BHSA eligible at-risk individuals who are at risk or and experiencing early signs of a mental health or substance use disorder or who have experienced known risk factors for poor behavioral health outcomes, such as trauma, Adverse Childhood Experiences, or involvement with child welfare or corrections system. This at-risk individual may not yet meet the criteria of a diagnosable mental health or substance use disorder. Indicated prevention is the only prevention intervention that is allowable under Early Intervention, as shown in Figure 7.A.1. Examples of indicated interventions include, but are not limited to, outreach, training, and education for high-risk individuals and/or families who are at risk and or experiencing early signs of a mental health or substance use disorder. Indicated interventions are preventive and often provided before an individual receives or meets diagnostic criteria for a behavioral health diagnosis. Case identification includes assessment, diagnoses, brief interventions, and activities needed to create access and linkages to care that connect individuals to the appropriate care.
A.7.6 Biennial List of Evidence-based Practices and Community-Defined Best Practices
DHCS will developed a non-exhaustive list of Early Intervention EBPs and CDEPs. The biennial list is an optional reference tool to support each county behavioral health department’s community planning process discussions regarding which practices to implement locally. The biennial list of EBPs and CDEPs can be found in Appendix E.
The only EBP that counties are required to provide as a part of Early Intervention is a CSC for FEP program, beginning July 2026. However, DHCS may require a county to implement a particular EBP or CDEP from the DHCS biennial list.
Counties can include other county-specific CDEPs and can innovate and implement emerging and promising practices that are not included on the biennial list of EBPs and CDEPs provided by DHCS in their IP.
An Early Intervention EBP or CDEP on the biennial list may include population-based prevention elements. Counties will still be able to fund EBPs and CDEPs that may have very limited population-based prevention components in full with BHSS funds only if the EBP or CDEP is on the biennial list developed by DHCS.
EBPs and CDEPs included on this list address mental health, substance use, and co-occurring disorders. The EBPs and CDEPs on this list address at least one aspect of the required BHSA EI program components which include outreach, access and linkage to care, and mental health and substance use disorder treatment services and supports.
To develop this list, DHCS drew from the sources below:
DHCS leverages the following sources to identify EBPs and CDEPs:
Children and Youth Behavioral Health Initiative’s (CYBHI) EBPs and CDEPs grant program
The Athena Forum created by Washington State Health Care Authority
Evidence-based Practices Resource Center developed by the Substance Abuse and Mental Health Services Administration
The Cognitive-Behavioral Interventions for Substance Use curriculum designed by the University of Cincinnati
The County of Los Angeles Department of Mental Health, Prevention and Early Intervention EBPs, Promising Practices, and CDEPs Resource Guide 2.0. created by the California Institute for Mental Health
DHCS also solicited input from CDPH, the Commission for Behavioral Health, stakeholders representing behavioral health providers, California’s tribal communities, county departments of behavioral health and public health, and other subject matter experts. DHCS assessed the proposed EBPs and CDEPs based on the following criteria for inclusion in the biennial list:
Availability of public materials and information about the EBP or CDEP, including an overview of the evidence base, details on how the program or intervention is structured, and information on how to implement.
Availability of trainings on implementing the EBP or CDEP or sufficient informational resources for counties to replicate locally. While CDEPs may not specifically offer training information, those included in this list provide enough information for counties to be able to adapt the EBP or CDEP for their local needs.
Primary focus of the EBP or CDEP is on EI, as defined in the BHT Policy Manual, and fits in a category of Indicated (prevention) or Case Identification (treatment) on the Institute of Medicine’s Continuum of Care and Spectrum of Early Intervention Services, as shown in Figure 7.A.1. EBPs and CDEPs may include some population-based prevention or treatment/recovery elements but are primarily focused on key areas of EI for individuals. Counties will still be able to fund EBPs and CDEPs that may have very limited population-based prevention components or treatment/recovery elements in full with BHSS funds only if the EBP or CDEP is on this list.
The EBPs and CDEPs are organized into the following categories based on population served: Children and Youth; Family-Centered; Adults and Older Adults; and General. In addition, within those categories, EBPs and CDEPs are organized by condition addressed: Mental Health; Substance Use; and Co-Occurring. Counties may innovate and implement emerging and promising practices that are not included on this list. Programs listed with an asterisk indicate a CDEP.
B. Full Service Partnership
B.3 Full Service Partnership Program Requirements
B.3.4 Full Service Partnership Exemptions
Fiscal Year (FY) 2026-2029 Integrated Plan
State law permits counties with a population of less than 200,000 to request an exemption from the FSP requirements in W&I Code section 5887, subdivision (a)(2). For the first Integrated Plan covering FYs 2026-2029, all counties, regardless of their size, will be exempt from the EBP fidelity requirements for ACT, FACT, IPS Model of Supported Employment, and HFW. Therefore, counties do not need to request an exemption from FSP EBP requirements in their first Integrated Plan. DHCS will make available training, technical assistance, and fidelity monitoring supports for counties as they implement FSP EBPs: ACT, FACT, IPS and HFW. Counties are still required to begin offering the required EBPs by July 1, 2026.
To meet FSP EBP requirements, between July 1, 2026, and June 30, 2029, all counties must:
Participate in ongoing training and technical assistance for all FSP EBPs.
Understand gaps to fidelity for each FSP EBP by December 31, 2027.
Complete full fidelity reviews and demonstrate counties are implementing all FSP EBPs with fidelity by June 30, 2029.
DHCS will make available training, technical assistance, and fidelity monitoring supports for counties as they implement FSP EBPs: ACT, FACT, IPS and HFW.
FY 2029-2032 Integrated Plan
Subject to DHCS approval, for the second Integrated Plan covering fiscal years 2029- 2032, small counties (population less than 200,000) may request an exemption from the ACT and FACT EBP. Small counties may also request an exemption from IPS and HFW[71] EBP fidelity requirements.
State law permits counties with a population of less than 200,000 to request exemptions from these requirements for ACT, FACT, and/or IPS, consistent with W&I Code section 5887, subdivision (a)(2). Exemptions are not available for HFW because it is a mandatory Medi-Cal service pursuant to the Early Periodic Screening Diagnostic and Treatment (EPSDT) benefit.
The criteria for FSP exemption requests include:
Limited workforce (e.g., qualified providers)
Limited need (e.g., the estimated population with a clinical need for an EBP
number of individuals eligible is too small for the county to support the required EBP staffing for fidelity)Other
considerationshardships, subject toevidence requirements andDHCS review
Counties may use the findings from COE fidelity reviews and other data to determine whether they will seek an exemption in fiscal year 2029. Exemption requests must include: documentation demonstrating that one or more of the criteria for exemption are met (e.g., workforce or county demographic data, information from a COE informational fidelity review findings consultation). Counties must request exemptions from each FSP EBP (ACT, FACT, and/or IPS) individually and provide corresponding documentation.
A description of how counties will work towards improving fidelity scores or for counties that may never meet fidelity requirements, an explanation of why.
B.6 Foundational Requirements for Full Service Partnership Evidence Based Practices
To meet FSP EBP requirements, counties must begin offering FSP EBPs by July 1, 2026 (to fidelity not required) and demonstrate they are implementing FSP EBPs with fidelity by June 30, 2029.
In addition to the FSP EBP requirements in Section B.3.4 Full Service Partnership Exemptions, counties must do all of the following:
Complete county consultations with the respective Center of Excellence (COE) for each EBP;
Ensure practitioners meet specified training, technical assistance, fidelity monitoring, and data collection standards; and
Meet specified implementation milestones to demonstrate services are delivered with fidelity to the evidence-based models.
Details about each of these requirements for ACT, FACT and IPS are in the DHCS EBP Training, Technical Assistance, Fidelity Monitoring and Data Collection Policy Guide (link forthcoming). Details about requirements for HFW are forthcoming.
B.6.1 FSP EBP Service Capacity
Counties that do not qualify for or receive exemptions must establish teams of behavioral health practitioners to deliver each FSP EBP. Counties will use the IP and Annual Update (AU) to project the number of multidisciplinary ACT, FACT, IPS, and HFW teams the county will establish between 2026 and 2029.
DHCS recognizes that counties are starting from different places and have varying resources available to implement FSP EBPs. DHCS also understands it takes time to implement high-quality EBP programs to fidelity. Counties should assess internal capacity, use available data, and work with COEs to determine an appropriate number of ACT, FACT, IPS, and HFW teams the county aims to staff and train over the first IP period.
DHCS provided counties with data-driven estimates of the total number of BHSA-eligible individuals in the county who may have a clinical need for each EBP, and the number of FTE practitioners and multidisciplinary teams that would be required to serve that entire population. These estimates are one data point to support county planning. The estimates do not account for county-specific resources and the time it takes to recruit, hire and train behavioral health practitioners. DHCS is not requiring counties to staff the number of teams required to serve the entire BHSA-eligible population with a clinical need for each EBP.
In the 2026 IP, counties must project the number of FTE practitioners (including county-operated and county-contracted providers) and multidisciplinary teams they will staff to provide ACT, FACT, IPS and HFW in FYs 2026-2027, 2027-2028, and 2028-2029. Counties may adjust staffing projections as needed as part of the AU process. Projected staffing must account for both current practitioners and new practitioners the county intends to hire and/or contract with to deliver FSP EBPs. Counties that are requesting an exemption from ACT, FACT and/or IPS should input “0” for the projected number of FTE practitioners and teams for those EBPs in the IP/AU.
B.6.2 FSP EBP Fidelity Standards
The projected number of teams identified in the IP/AU for FY 2026-2027 must achieve Fidelity Designation as defined in the DHCS EBP Training, Technical Assistance, Fidelity Monitoring and Data Collection Policy Guide (link forthcoming) on the following timeline:
The FY 2026-27 projected number of teams delivering each EBP must complete baseline fidelity assessments and receive Baseline Fidelity Designation no later than December 31, 2027;
The FY 2026-27 projected number of teams delivering each EBP must complete their first fidelity assessments and achieve Minimum Fidelity Designation no later than June 30, 2028; and
The FY 2026-27 projected number of teams delivering each EBP must complete a second fidelity assessment and achieve Full Fidelity Designation no later than June 30, 2029.
Counties must ensure all teams of practitioners delivering EBPs also meet the training, technical assistance, fidelity monitoring, and data collection requirements outlined in the DHCS EBP Training, Technical Assistance, Fidelity Monitoring and Data Collection Policy Guide (link forthcoming).
Counties that are unable to ensure their projected teams of practitioners meet the fidelity requirements for the respective EBPs must consult with the respective COEs and establish county-specific EBP fidelity plans to meet DHCS’ fidelity standards.
For example, if a county projects that it will have four ACT teams in FY 2026-2027 but only one ACT team completes a baseline assessment before December 31, 2027, the county must work with the ACT COE to establish a plan for expanding their ACT program and completing the requisite fidelity assessments for the remaining three teams. If a county projects that it will have four ACT teams in FY 2026-2027 and four ACT teams complete the baseline assessment in 2027, but only one ACT team achieves Minimum Fidelity Designation by June 2028, the county must also work with the ACT COE on a county-specific EBP fidelity plan to improve fidelity implementation for the remaining three teams. Counties must be prepared to share their county-specific EBP fidelity plans with DHCS upon request.
In the IP/AU, counties must also project the number of teams they will staff for each EBP for FYs 2027-2028 and 2028-2029. DHCS does not expect all teams established after FY 2026-2027 to achieve Full Fidelity Designation by June 2029; rather, all new teams must progress through the Fidelity Designation levels at the intervals specified in the DHCS EBP Training, Technical Assistance, Fidelity Monitoring and Data Collection Policy Guide (link forthcoming).