Policy Recommendations for California in the Wake of Free Care

California’s School-Based Health Alliance has released a report which focuses on the expanded role that schools can play in the overall health delivery system following the reversal of CMS’ free care rule.

The report makes the following recommendations based on extensive interviews with California’s Department of Health Care Services (DHCS), Department of Education (CDE), LEAs, and other key stakeholders:

  1. Request a federal waiver of the third-party liability requirements;
  2. Strengthen the role of CDE in the LEA Medi-Cal Billing Option Program;
  3. Improve communication between DHCS and vendors on program policy and procedures;
  4. Address data sharing issues; and
  5. Develop and promote models for integrating school health services into the health care delivery system.


As DHCS moves toward a full roll-back of free care, which will allow California LEAs to bill for the Medi-Cal services they provide to non-IEP and non-IFSP students, we believe that these recommendations could greatly aid the process and outcome.