Policy Watch
AB 403 Is Dead for 2026. The CHW Medi-Cal Data Problem It Exposed Is Not.
FQHC Talent Editorial Team
FQHC Talent
Of California's roughly 15 million Medi-Cal beneficiaries, fewer than 6,000 have ever used a Community Health Worker (CHW) service, and total reimbursement is under $1 million. That's not a typo — it's a DHCS disclosure to the California Assembly Health Committee. Assemblymember Liz Ortega's AB 403, the Community Health Worker, Promotora, and Representative Medi-Cal Services Transparency Act, would have forced DHCS to publish the utilization data behind that failure. The official Legislature record now lists AB 403 as inactive for the 2025-26 session, so this is no longer a floor-vote alert. It is a useful postmortem: the bill failed, but the CHW billing, workforce, and data gap it exposed is still the FQHC operating problem.
Key Takeaways
- ✓California's CHW Medi-Cal benefit has reached fewer than 6,000 of 15 million beneficiaries since launching July 1, 2022. Total reimbursement is under $1 million.
- ✓AB 403 (Ortega) would have required DHCS, starting July 1, 2027, to publish an annual analysis of CHW utilization disaggregated by region, race, ethnicity, language, age, and managed care plan.
- ✓The official California Legislature record now lists AB 403 as inactive for the 2025-26 session. No July 1, 2027 reporting requirement exists from this bill unless similar language is revived.
- ✓FQHC action items now: audit current CHW/ECM billing as a distinct line, pair future transparency advocacy with CalBudgetCenter's 'Trusted, But Undervalued' rate case, and keep utilization reporting separate from SB 184 certification.
Medi-Cal beneficiaries (of ~15 million) who have ever used a CHW service — under $1M reimbursed
Source: DHCS disclosure to the California Assembly Health Committee (March 2024)
The Benefit Almost Nobody Is Using
California's CHW Medi-Cal benefit launched on July 1, 2022, built into the CalAIM transformation. It pays providers for outreach, health promotion, navigation, and SDOH screening delivered by trusted community workers — many of them promotoras and community health representatives with decades of trust in their neighborhoods.
A 2024 State Plan Amendment expanded the benefit, letting dental and pharmacy practices supervise CHWs and bill for their services.
On paper, this should be a transformative benefit. In practice, the numbers tell a different story. DHCS reports that the share of managed-care members statewide using any Community Support reached just 0.9% in 2024, up from 0.1% in 2022.
For CHW services specifically, the figures are starker still: fewer than 6,000 beneficiaries, less than $1 million in reimbursement, three full years after launch.
The benefit hasn't failed because CHWs aren't doing the work. They are — they always have. It has failed because the plumbing connecting the work to the billing code is leaky, and because nobody has been required to publish the data that would let us pinpoint the leaks.
What AB 403 Would Have Done
AB 403 would have done one focused thing. Starting **July 1, 2027**, if enacted, it would have required DHCS to publish an annual analysis to the Legislature and the public on CHW Medi-Cal benefit utilization.
The analysis must include an assessment of CHW capacity and beneficiary need, disaggregated by geographic region, race, ethnicity, language, age and other sociodemographic factors, and by Medi-Cal managed care plan.
In plain English: the state would finally have to show its work. Where is the benefit actually reaching people? Which counties are leaving CHW dollars on the table? Which managed care plans are dragging? Which beneficiaries — by language and ethnicity — are still being missed?
Today, advocates, providers, and even the Legislature itself are flying blind on every one of those questions.
The bill was co-sponsored by the founding organizations of the California CHW/P/R Policy Coalition: the Latino Coalition for a Healthy California, the California Pan-Ethnic Health Network, Visión y Compromiso, and The Children's Partnership. It was not the same bill as SB 184.
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Why FQHCs Are at the Center of This
FQHCs are where most CHW billing already lives. As the largest cohort of safety-net providers eligible to bill the benefit — with established ECM contracts, integrated care teams, and the cultural-linguistic match the work demands — health centers are both the biggest beneficiaries of the program and the most exposed if similar transparency language returns.
For FQHC executives, three implications are worth thinking about now, not in 2027:
- **Site-level visibility is still the logical endpoint.** Annual reporting disaggregated by managed care plan and demographics would surface which parts of the system are billing — and which are not. If your FQHC runs a robust ECM workflow but is not billing CHW services as a distinct line, that is a quiet revenue gap. Audit it while the spotlight is still hypothetical.
- **Rate advocacy still needs the data foundation.** The state cannot credibly argue that CHW rates are adequate if benefit utilization is functionally zero. The California Budget Center's Trusted, But Undervalued report calls explicitly for higher rates and better data. AB 403 failed, but the advocacy pairing remains right: utilization transparency plus rate adequacy.
- **Distinct from SB 184.** AB 403 was about utilization of the benefit. SB 184 is about the CHW certification credential — a separate workstream that has been stalled since November 2023 without DHCS guidance. Do not conflate them in board memos, union conversations, or advocacy. They move on different tracks.
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Explore Scope of Practice to see how CHW roles fit into your FQHC's delegation matrix — and where Medi-Cal reimbursement is still being left on the table.
Trusted, But Undervalued — The Workforce Underneath the Bill
The benefit's underuse isn't an indictment of CHWs. It's an indictment of the system around them. A 2026 JAMA Network Open analysis on strengthening Community Health Worker and Promotora workforce capacity reinforces what frontline organizations have said for a decade: this is essential workforce, it is overwhelmingly women of color, and it is chronically underpaid.
The California Budget Center frames it sharply: CHWs, promotoras, and representatives are the connectors California's safety-net depends on, yet a major challenge in evaluating and expanding the workforce is the lack of reliable, centralized data on who is delivering services, who they are reaching, and what outcomes they are producing.
AB 403 would not have fixed the rate. It would not have fixed the credential. What it would have fixed is the data — and without that data, neither of the other fixes is politically easy.
There is a quiet through-line here that FQHC leaders should name out loud: a benefit reaching fewer than 6,000 of 15 million beneficiaries is not the workforce's failure. It is a policy failure that the workforce has been asked to carry. A future AB 403-style transparency bill remains the smallest plausible step toward changing that.
What to Do After AB 403 Failed
If you lead an FQHC, sit on a board, or represent the CHW workforce, the operating question is no longer whether AB 403 clears a floor deadline. It is how to preserve the useful parts of the bill for the next policy window.
- **AB 403 status** — The California Legislature bill page lists AB 403 as inactive for the 2025-26 session. There is no current July 1, 2027 DHCS reporting requirement from this bill.
- **Next policy window** — Treat the AB 403 text as a template. If the coalition revives the language, the core ask should stay narrow: annual public utilization reporting by region, race, ethnicity, language, age, and Medi-Cal managed care plan.
- **SB 184 (CHW certification)** — Separate bill, paused since late 2023. Don't expect movement in this session; don't tie your AB 403 advocacy to it.
- **CHW Medi-Cal rate** — Watch budget and trailer-bill language for an actual rate increase. Transparency language makes the case but is not itself a rate change.
- **Site-level prep** — Audit your current CHW/ECM billing this quarter. Is your ECM team billing CHW services as a distinct code where appropriate? Are pharmacy and dental sites taking advantage of the 2024 expansion? Are you tracking patient language and ethnicity in a way that would hold up if DHCS eventually publishes a disaggregated dataset?
A benefit that reaches fewer than 6,000 of 15 million people is not a benefit. It is a promise California made and then quietly stopped checking on. AB 403 did not survive, but the check still has to happen.
Sources
- AB 403 Bill Text — Medi-Cal: community health worker services — California Legislature, 2025-2026 Session. Would have required DHCS to publish an annual analysis of CHW benefit utilization starting July 1, 2027 if enacted.
- Assemblymember Liz Ortega Introduces AB 403 to Shine a Light on Gaps in Access to CHW Medi-Cal Services — Latino Coalition for a Healthy California, March 12, 2025. Source for the <6,000 of 15M beneficiaries stat; under $1M reimbursed (DHCS disclosure to Assembly Health Committee).
- Community Health Workers — Medi-Cal Benefit — California Department of Health Care Services, 2025. Benefit launched July 1, 2022; Community Supports utilization 0.1% (2022) → 0.9% (2024).
- FAQs for Medi-Cal Community Health Worker Services — DHCS, October 2024. Confirms the 2024 SPA expansion allowing dental and pharmacy supervision of CHWs.
- Trusted, But Undervalued: Community Health Workers, Representatives, & Promotoras — California Budget & Policy Center, 2026. Analytical framework: CHW/P/Rs underpaid, lack of centralized data; rate-increase recommendations.
- Strengthening Community Health Worker and Promotora Workforce Capacity — JAMA Network Open, 2026. Peer-reviewed analysis on building and sustaining CHW/promotora workforce capacity.
- State Community Health Worker Policies: California — National Academy for State Health Policy (NASHP), 2025. Status of SB 184 (CHW certification), paused since November 2023.
- AB 403 Bill Status & Tracking — California Legislature, 2026. Official page showing the bill as inactive for the 2025-26 session.
- Community Health Workers, Promotores & Representatives — California Department of Health Care Access and Information (HCAI), 2025. CHW/P/R workforce initiatives and HCAI funding context.
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