A. Purpose of the Behavioral Health Outcomes, Accountability, and Transparency Report
The Behavioral Health Services Act (BHSA) requires counties to submit Behavioral Health Outcomes, Accountability, and Transparency Reports (BHOATRs) to the Department of Health Care Services (DHCS) on an annual basis (WIC section 5963.04). The BHSA establishes the BHOATR to provide California with greater transparency into how counties spend behavioral health dollars and administer behavioral health care.
DHCS is using the BHOATR to monitor county implementation of their Integrated Plans (IPs), Annual Updates (AUs), and/or Intermittent Updates (IUs), whichever is the most current for the reporting period. The BHOATR template includes the required elements for each county to submit their BHOATR. DHCS will review and approve county BHOATRs. DHCS will post each county’s BHOATR as well as statewide BHOATR information on the DHCS website within the Behavioral Health Public County Profile (see WIC section 5963.04 subdivision (d)).
A.1 Reporting Period
A.1.1 Reporting Periods for Draft and Final BHOATRs
Reporting periods for county BHOATRs align with the fiscal year (FY). Counties are required to submit BHOATRs no later than 18 months after the end of the FY.
The first BHOATR covers FY 2026-2027. Counties must submit a draft BHOATR for FY 2026-2027 to DHCS by January 30, 2028. The draft BHOATR will not be shared publicly and is a one-time requirement that allows DHCS to provide technical assistance to counties in advance of the first final BHOATR due to DHCS by January 30, 2029.
DHCS will provide instructions for counties in the County Portal on completing the draft BHOATR.
A.2 Required Contents
A.2 Contents of the BHOATR
Per WIC section 5963.04, counties must submit a BHOATR that includes data and information on spending across funding sources for behavioral health services, service utilization, and other interventions undertaken by the county as part of their Integrated Plan including:
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Allocations of state and federal behavioral health funds
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State, federal, and county behavioral health expenditures, including:
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Spending on children and youth
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Spending across funding sources including 1991 Realignment, 2011 realignment, county general funds, state general funds, SAMHSA PATH, MHBG, SUBG, Commercial Insurance reimbursements, and Opioid Settlement Funds, among other sources
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Administrative costs
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Service utilization data, including information on services provided to individuals covered by Medi-Cal, Medicare, commercial insurance, and those who are uninsured
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County performance and outcomes measures across behavioral health delivery systems
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Data and information on populations with identified disparities
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Information on county workforce strategies and provider vacancy rates
Counties are required to submit a BHOATR that includes information on spending and service utilization across the Behavioral Health Care Continuum and BHSA Components.
The BHOATR is mainly quantitative, focused on service utilization, expenditures, and outcomes. The BHOATR mirrors the IP budget template elements and, where available, includes some county projections from IP, AU, or IU— whichever is the most current for the reporting period. Counties may include narrative descriptions to accompany data reported in the BHOATR to describe differences between projected and actual data or provide other context on data reported in the BHOATR.
A.3 Calculating Reversions
Starting in FY 2026 – 2027, the BHOATR replaces the MHSA Annual Revenue and Expenditure Report (ARER) to calculate reversion. The last reporting year of the ARER is FY 2025 – 2026 (submission to DHCS by January 30, 2027). For more information on reversion, please see Behavioral Health Services Act Policy Manual, Section 6: BHT Fiscal Policies.
B. Guidance for Completing the BHOATR
B.1 Data Requirements
DHCS collects statewide data on behavioral health utilization through Medi-Cal claims and uses Medi-Cal claims and requires counties to submit ISL encounters for all other individual-level behavioral health services beginning January 1, 2027. DHCS uses Medi-Cal claims and ISL encounters to pre-populate some information in the BHOATR.
While counties may submit ISL encounters beginning July 2026, counties are not required to submit ISL encounters to DHCS until January 2027, halfway through the first BHOATR reporting period. Therefore, DHCS is not using ISL encounter data for July – December 2026 to pre-populate elements of the FY 2026-27 BHOATR.
C.2 BHOATR Submission
C.2.1 BHOATR Submission Requirements
For a BHOATR to be considered complete, a county must include the following:
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Response to each required item in the BHOATR template
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Approval from the county board of supervisors
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Certifications from both the county behavioral health director and the County Administration Officer (or other county equivalent) or their designee certifying compliance with fiscal accountability requirements and that all expenditures are consistent with applicable state and federal law. The County Administrator may be known by other titles such as Chief Executive, County Manager, or Chief Administrative Officer. The County Administrator must be the individual who serves as the top staff member in county government and holds the highest level of administrative authority in the county or be the designee of that individual. This individual or their designee must work within the executive office of county government, and they may not be the county behavioral health director.
Additionally, in accordance with WIC section 14197.71, subdivision (c)(2), county boards of supervisors are required to attest that the county is meeting its realignment obligations, including but not limited to time and distance standards and appointment time standards set forth in WIC section 14197.7 without utilizing waitlists. This attestation must be submitted with the BHOATR.
C.2.2 County Portal
Counties must develop and submit their BHOATRs online through the DHCS county portal. The county portal allows county users to complete tasks such as filling in form-based prompts, compiling fiscal information, and completing attestations. The county portal supports DHCS and counties in integrating statewide data into each county’s BHOATR for the county’s review. The county portal supports access for multiple county users, allowing multiple county users to work concurrently to develop the BHOATR. Counties must also use the county portal support center to submit questions about BHOATR submission or requests for technical assistance.
County portal technical features include progress markers to track completion of each section of the BHOATR, support tools allowing DHCS staff to review, collaborate on, and resolve questions from counties, and functionalities to distill key information from approved BHOATRs into county profiles.
C.2.3 DHCS Review Standards
DHCS will review a county’s BHOATR for completeness and validate that all BHOATR content is aligned with guidance set forth in this Policy Manual and all BHSA statutory requirements. If a county does not submit the BHOATR by the required deadline, DHCS may impose a corrective action plan, monetary sanctions, or temporarily withhold payments to the county, per WIC section 14197.7.
DHCS will define quantitative standards for significant variance after the first IP period (FY 2026-2029). The first IP period will be used to collect data and set standards for significant variance. Starting in the second IP period (FY 2029-2032), DHCS may impose BHSA withholds or monetary sanctions if a county has significant variance in projected spending of BHSA funds between its IP and actual spending.
C.2.4 Submission for Local City Entities
The two city-operated mental health authorities receiving funds pursuant to WIC, section 5701.5 shall submit BHOATRs independently from their counties under BHSA. DHCS will grant the same flexibilities to cities when completing the BHOATR that were granted to cities completing the IP, including reporting flexibilities related to funding sources like County General Fund, FFP, and non-applicable federal funds.