May Revise CONFIRMS PATH $1.85B Sunset Dec 31, 2026 — CalAIM ECM/CS Capacity Funding NOT Extended

California's May Revise does NOT propose extending the PATH (Providing Access and Transforming Health) initiative beyond its scheduled December 31, 2026 sunset. PATH funded $1.85B over 5 years for ECM and Community Supports provider capacity-building at FQHCs and CBOs — payments to providers for outreach, technology, infrastructure, and workforce. This compounds the CalAIM 1115 waiver expiration (Dec 31, 2026, CMS approval pending) creating a December 2026 dual cliff for FQHC ECM/CS infrastructure. PATH-funded positions disproportionately concentrated in: housing navigators, CHWs supporting CalAIM populations, community supports coordinators, and IT/EHR integration roles. Strategic implication for FQHC CFOs and ECM/CS program directors: (1) Audit which staff roles, technology investments, and CBO partnerships are PATH-funded (vs. PPS-funded or APM-funded); (2) Model FY27 budget under 'no PATH replacement' scenario; (3) Engage CPCA + Aurrera Health Group on the CalAIM 'sustainability concept paper' (released March 2026); (4) Hold off on PATH-dependent expansion until late-2026 visibility on CMS waiver decision. Combined with CHC Fund December 2026 CR cliff = triple December cliff for FQHCs (PATH + CalAIM + CHC Fund).