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AB 2161

Medi-Cal: redeterminations and work or community engagement.

2025-2026 Regular Session Introduced by Cecilia Aguiar-Curry and 4 co-sponsors

AB 2161 implements six-month Medi-Cal redeterminations starting no earlier than 2027 and adds federally aligned work or community engagement requirements to maintain coverage.

From committee: Do pass and re-refer to Com. on APPR. (Ayes 8. Noes 2.) (July 1). Re-referred to Com. on APPR.
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WeVote Research Nonpartisan
Bill Summary · AB 2161

Summary – AB 2161 (2025-2026) Medi-Cal: redeterminations and work or community engagement

Note: This summary covers the bill as introduced/amended through the 2025-26 session and focuses on the substantive provisions, timelines, and likely impact.

1) Purpose and intent

  • Align California Medi-Cal redetermination and work/community engagement requirements with federal changes enacted in 2025.
  • Implement (and in some aspects defer) federal work or community engagement requirements for Medi-Cal beneficiaries, while seeking to minimize administrative burden and maintain continuous coverage where possible.
  • Establish a state framework to administer six-month redeterminations for certain populations and to begin implementing federally required work/community engagement provisions, subject to federal approvals and system readiness.

2) Key provisions and changes

A. Redetermination frequency and scope

  • For Medi-Cal beneficiaries, the bill changes the standard redetermination cadence from annually (12 months) to every six months for those subject to six-month redeterminations beginning no sooner than January 1, 2027, as required by federal law.
  • Applies to individuals enrolled under 42 U.S.C. 1396a(a)(10)(A)(i)(VIII) (Medi-Cal expansion population) and excludes individuals not required by federal law to have six-month redeterminations (with other exemptions remaining intact).

B. Renewal notices and forms

  • Expands delivery methods for renewal forms to include telephone, online, or other electronic means (in addition to in-person/mail).
  • Allows counties to accept signatures via electronic means.
  • When redetermination cannot be completed with available information, counties must provide a renewal form prepopulated with data they already have and specify additional information needed. The renewal form must meet accessibility standards (language access and disability considerations).

C. Data, information collection, and ex parte reviews

  • Counties must gather information from existing records (Medi-Cal, CalWORKs, CalFresh, and other accessible data sources) before contacting beneficiaries.
  • Emphasizes ex parte (data-based) review to determine continued eligibility where feasible, and to minimize beneficiary data requests.
  • If ex parte review cannot determine compliance, counties may request data from Medi-Cal managed care plans before asking the beneficiary for information.

D. Work or community engagement requirements (target implementation)

  • Beginning no sooner than January 1, 2027, an “applicable individual” must demonstrate work or community engagement as a condition of Medi-Cal eligibility under federal law.
  • An applicable individual must demonstrate engagement for one month in a specified period relative to their application or redetermination.
  • Demonstrated engagement can be satisfied by:
    • 80+ hours of work
    • 80+ hours of community service
    • 80 hours in a work program
    • enrollment in an educational program at least half-time
    • any combination totaling 80 hours or more
    • income meeting a threshold (minimum wage times 80 hours), or six-month average income meeting the threshold (seasonal workers)
  • Exclusions: certain groups are exempt from the monthly work/community engagement requirement (e.g., individuals under 19, Medicare enrollees, certain dependents, inmates, medically frail individuals, pregnant persons, and others exempt under federal law or approved waivers).
  • Short-term hardship exemptions may count as compliant for a month.

E. Compliance, notices, and enforcement

  • If an applicable individual is deemed noncompliant, counties must issue a notice of noncompliance and provide a 30-day window to demonstrate compliance or be deemed compliant through other means.
  • Continuation of Medi-Cal benefits during the 30-day noncompliance period is required, with specific rules for applicants and renewals to avoid gaps.
  • If no satisfactory showing is made after the 30-day period, counties may deny or disenroll, following due process (including consideration of other eligibility pathways).
  • If eligibility is denied/disenrollment occurs, counties must first assess other eligibility options and provide hearing rights.

F. Departmental/regulatory actions and reporting

  • The Department of Health Care Services (DHCS) must adopt regulations by July 1, 2028.
  • Beginning July 1, 2027, DHCS must provide semiannual status reports to the Legislature on implementation, continuing until regulations are adopted.
  • Implementation is contingent on DHCS confirming that systems are programmed to support the new processes and that federal approval and participation are in place.

G. Implementation mechanics and costs

  • The bill creates state-mandated local program obligations for counties.
  • It requires coordination with managed care plans and other state agencies for data sharing and continuity of coverage.
  • Reimbursement obligations under the California Constitution are referenced if the bill imposes costs on local agencies.

3) Who would be affected

  • Medi-Cal beneficiaries, particularly the expansion population age 19-64, and those subject to six-month redeterminations.
  • Counties and county eligibility workers responsible for redeterminations, renewal notices, and administration of work/community engagement.
  • Medi-Cal managed care plans, which may need to share data to verify compliance or exemptions.
  • DHCS, which would implement regulations, oversee system changes, and report on implementation progress.

4) Procedural and timeline aspects

  • Effective dates: Six-month redeterminations become required no sooner than January 1, 2027, with broader implementation contingent on federal approvals and system readiness.
  • Regulatory timeline: DHCS must adopt regulations by July 1, 2028.
  • Reporting: Semiannual implementation status reports to the Legislature begin July 1, 2027, until regulations are adopted.
  • Operative condition: Provisions operate only while federal law (MAGI-based rules for the expansion population and related work requirements) remains operative and pending DHCS confirmation of system readiness.

Overall, AB 2161 aims to modernize Medi-Cal redeterminations, align state law with federal changes, introduce work/community engagement requirements for eligible individuals beginning in 2027, and implement mechanisms to minimize administrative burden while preserving access to coverage.

Compiled from official sources — confirm details with the bill’s official record.

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