DHCS's draft PPS guidance RESTRICTS outreach allowability — and puts enrollment assistance by clinic or contracted staff on the non-reimbursable list, effective October 6

CORRECTION AND RESOLUTION (2026-09-12): we previously reported that the direction of this guidance was unknown. It is known, and it RESTRICTS. We obtained the notice and its attached draft from DHCS's own server and read them.

Two dates in our earlier item were also wrong: the notice's RELEASE DATE is 8/7/2026, not September 9, and the written-comment window closed August 21, 2026 — a reader relying on our earlier entry would have believed comments were still open. DHCS will still accept late comments but says they "will continue to be accepted after this date, but DHCS may be unable to assure consideration prior to finalizing the proposed guidance." 🔑 WHAT THE DRAFT DOES: the notice attaches a DRAFT FQHC/RHC OUTREACH REIMBURSEMENT POLICY that adopts the Medicare Provider Reimbursement Manual (CMS Publication 15-1) "to apply to the Medi-Cal program by reference," then gives a non-exhaustive list of SIX example reimbursable outreach activities against TWELVE non-reimbursable ones.

Its stated premise, verbatim: "Section 330 of the Public Health Service Act requires RHCs and FQHCs to conduct extended outreach and education to patients and the general population which are in some cases beyond the scope of the Medi-Cal FQHC/RHC benefit. Therefore, not all outreach and education activities performed by RHCs and FQHCs are allowable for the purposes of the Medi-Cal PPS reimbursement rate." 🔑 THE SHARPEST EDGE: "Enrollment assistance or eligibility support performed by clinic or contracted staff" is listed as NON-reimbursable, while "Referral of individuals seeking care at the RHC or FQHC, who are not enrolled in health coverage, to third-party enrollment resources" is reimbursable.

DHCS would recognize the cost of REFERRING an uninsured patient elsewhere but not the cost of a health center's own staff doing the eligibility work. Also non-reimbursable: broad public outreach (health fairs, public events, mass advertising, social media); group wellness activities; outreach partnerships or subcontracting with community organizations; cash or cash-equivalent incentives; free or subsidized non-health-related services; payments for referrals or member recruitment; publicized enrollment incentives and promotional commercials; public relations activities; staff leisure or retreat activities; unlicensed medical screenings; political or religious activities. 🔑 WHY THE MECHANISM MATTERS: this is a rate-base rule, not a billing rule.

The draft states the PPS rate "is generally calculated based on all-patient allowable costs divided by all-patient visits," so a cost ruled non-allowable leaves the numerator — the effect is a lower per-visit rate going forward, not a denied claim. Staff who split their time must document the allocation, and any time study "must comply with the Medicare Provider Reimbursement Manual (CMS Publication 15-1, section 2313.2 (E)) and must be conducted during the fiscal year under audit."

DHCS is proceeding under WIC section 14132.100(r), which lets it act "by means of a provider bulletin or similar instruction without taking regulatory action" — so there is no APA rulemaking process here. ⚠️ WHAT THIS DOES NOT ESTABLISH: the guidance is DRAFT and DHCS can revise it before October 6; both lists are described by DHCS as non-exhaustive, so neither is closed.

The document states NO dollar figure and no rate impact anywhere — do not model one. THIS ITEM MAKES NO PAYMENT OR BILLING CLAIM: nothing here says an FQHC may or may not bill any code.

One internal inconsistency in the source, recorded rather than resolved: the cover reads "RELEASE DATE: 8/7/2026" while the page-2 footer reads "DHCS PUBLIC NOTICE 8/3/2026"; the September 2 addendum states "On August 7, 2026" and is treated as authoritative. The non-reimbursable column also contains one bullet glyph with no text, so a careful reader may count thirteen; twelve is the number of actual examples.

The remaining input channel before October 6 is the stakeholder webinar on Wednesday, September 16, 2026, 4:00–5:00 p.m.