DHCS Introduces New Requirements for Alternative Format Plans for California Public Schools

On February 1, 2023, the California Department of Health Care Services (DHCS) released PPL 23-004, notifying LEAs and regional agencies participating in the LEA Billing Option and/or Medi-Cal Administrative Activities (MAA) programs that they must establish an Alternative Format Plan by August 1, 2023. This PPL is the second of two PPLs released on this topic - the first was PPL 21-017R back in 2021. This requirement is part of DHCS's efforts to ensure that individuals with disabilities have equal access to healthcare information and communications in an appropriate and accessible format, in compliance with state and federal laws.

These requirements align with the wrap-around services that many California public schools are already providing to students with disabilities, by ensuring that students have access to their information and communications in a format that is accessible to them. For example, if a student has a disability that affects their ability to access information in traditional formats, such as print, they may require materials in an alternative format, such as audio, electronic, or Braille.

To facilitate compliance with these new requirements, DHCS is sharing alternative format requests in the eligibility lookup return files for the school programs and has created a portal for Providers to report any new alternative format requests. LEAs are now required to check for alternative format requests for students that have already been reported by another Medi-Cal Provider (e.g., student's primary care physician), and to report alternative format requests to Medi-Cal that have not yet been filed.

In order to comply with these requirements, California public schools must establish an Alternative Format Plan by August 1, 2023, and share it internally and with Medi-Cal program coordinators. Students and their families should also be informed of the plan's existence and provided with information on how to access alternative formats of healthcare information and communications as needed.

To assist its client LEAs with getting started with articulating their plans, Paradigm has developed a tool that provides recommended processes for checking the eligibility lookup files and reporting new data to DHCS. Looking ahead, Paradigm will be working to make alternative format requests transparently available in its EHR platform in real-time, while ensuring compliance with privacy and confidentiality requirements. This will streamline the compliance process and ease the burden on Medi-Cal billing program coordinators.

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