Coalition Re: Mental Health and Substance Use Disorder Coverage Requirements

April 11, 2025

California Department of Insurance

Attn: Stesha Hodges, Assistant Chief Counsel, Kayte Fisher, Attorney V

Health Equity and Access Office
300 Capitol Mall, Suite 1700
Sacramento, CA 95814

Via email <CDIRegulations@insurance.ca.gov>

Re: Mental Health and Substance Use Disorder Coverage Requirements, Article 15.2 (commencing with section 2652.1) of Subchapter 3 of Chapter 5 of Title 10 of the California Code of Regulations, pursuant to the authority granted by Insurance Code sections 10144.4, 10144.5, 10144.51, 10144.52, 10144.53, and 10144.57

We thank the California Department of Insurance for its ongoing progress towards finalizing its Mental Health and Substance Use Disorder Parity in Health Insurance Rulemaking (REG-2021-00008), to implement Senate Bill 855 (Wiener, Chapter 151, 2020) and Assembly Bill 988 (Bauer-Kahan, Chapter 747, 2022). We are grateful for the Department’s continued engagement with us on numerous issues related to implementation of the law and its drafted regulations. The Department’s proposed Rule lessens the possibility that disability insurers will exploit ambiguities to inappropriately limit insureds’ access to mental health and substance use disorder (MHSUD) care.

We encourage this comprehensive Rulemaking to be finalized as soon as possible and offer support for the Department’s April 3, 2025 additions to its drafted Rulemaking dated May 24, 2024. Specifically, we are supportive of the following key additions, as currently drafted:

  • Network adequacy monitoring. We support the Department’s added clarity as to what an insurer needs to do once someone has requested assistance identifying a health care provider including by adding that if an insurer cannot identify more than three in-network providers, that it must refer the person to those three and notify the Department of the service requested, type of provider, and location. This is an important mechanism for ensuring the Department has proactive insight into possible weakening parts of networks that could lead to or show existing network inadequacies. We applaud the Department for this forward-thinking change which we believe will protect insureds.
  • Defining coordinated specialty care. Providing a definition of Coordinated Specialty Care makes it much harder for insurers to deny or partially deny medically necessary services for individuals experiencing first and early episodes of psychosis. We applaud the Department’s further defining of these life-saving but seldom reimbursed services.

We encourage the swift promulgation of comprehensive regulations. Once promulgated, we encourage the Department to issue notices, bulletins, and/or general opinion letters regarding particular areas of enforcement concern. Our organizations stand ready to assist you in the identification of MH/SUD access issues and comprehensive implementation of the Rule in any way we can.

If you have any questions, please contact Lauren Finke (lauren@thekennedyforum.org). For matters requiring physical or printed communication, please send to 1121 L Street, Sacramento, California 95814 suite #300.

Sincerely,

Adrienne Shilton
California Alliance of Child and Family Services

Robb Layne
California Association of Alcohol and Drug Program Executives, Inc

Joy Alafia
California Association of Marriage and Family Therapists

Chad Costello
California Association of Social Rehabilitation Agencies

Carli Stelzer
California Behavioral Health Association

Tyler Rinde
California Psychological Association

Paul Yoder
California State Association of Psychiatrists

Danny Thirakul
California Youth Empowerment Network

Alison Ivie
REDC Consortium
Eating Disorders Coalition for Research, Policy, & Action

Karen Fessel
Mental Health & Autism Insurance Project

Heidi Strunk
Mental Health America of California

Héctor Hernández-Delgado
National Health Law Program

Benjamin Eichert
NUHW

Samia H. Rafeedie
Occupational Therapy Association of California

Randall Hagar
Psychiatric Physicians Alliance of California

Tara Gamboa-Eastman
Steinberg Institute

Lauren Finke
The Kennedy Forum

CC:
Ricardo Lara, Stesha Hodges, Kayte Fisher, Department of Insurance
Senator Scott Wiener
Assemblymember Bauer-Kahan

SB 531 (RUBIO) Student Mental Health Education – Support

March 3, 2025


The Honorable Senator Sasha Renée Pérez
Chair, Senate Education Committee
1021 O Street, Room 6740
Sacramento, CA 95814

Subject: Support Letter for SB 531 (Rubio) Student Mental Health Education

Dear Senator Pérez,

Our organizations are proud to support Senate Bill 531 by Senator Susan Rubio.

SB 531 will help empower young Californians and destigmatize mental health challenges by requiring all California students in grades 1-12 be provided with an age-appropriate mental health education.

From the aftereffects of the COVID 19 pandemic, the pervasiveness of social media, and the rise in school threats, to the current fears and traumas California students are experiencing because of recent wildfires and changes in immigration policy, today’s students are confronted by an unprecedented scope of mental health challenges. Half of all lifetime cases of mental illness begin by age 14. Worldwide, mental health challenges are among the leading causes of illness and disability among young people, and in California, about one-third of adolescents have experienced psychological distress.

According to data from the Centers for Disease Control and Prevention, anxiety problems, behavior disorders, and depressions are the most commonly diagnosed mental disorders in children – and among children ages 3-17 with a current mental health condition, only 53% received treatment or counseling from a mental health professional in the past year. There are gaps in treatment to support youth: 20% of adolescents age 12-17 report having unmet mental health care needs, and 40% of high school students reported persistent feelings of sadness or hopelessness in the past year. 20% of high school students reported seriously considering attempting suicide in the past year.

Health literacy, including mental health literacy, can serve as both a risk and protective factor for health and wellbeing. Mental health education is critical to building knowledge and skills to increase awareness, tackle stigma, and encourage help-seeking behavior. Young people spend the majority of their time in schools, and education systems are well-positioned to play an integral role in fostering positive youth development. Schools can help cultivate non-stigmatizing, safe, and supportive environments where youth are informed and able to seek needed mental health care.

SB 531 will ensure that students receive age-appropriate mental health education in elementary, middle, and high schools by amending existing law to include age-appropriate mental health education within the existing requirement that health instruction be taught in grades 1-6, and by requiring that mental health education be taught in grades 7-12.

For these reasons, we are proud to support SB 531.

Sincerely,

Kerry Ahearn
Chief Executive Officer
Aldea

Sarah Bridge
Vice President, Advocacy & Strategy
Association of California Healthcare District

Tom Bakaly
Chief Executive Officer
Beach Cities Health District

Mary Jo Ramirez
Executive Director
California Family Life Center

Nazeehah Khan
Policy Director
Californians for Justice

Sergio J. Morales
Executive Director
California School-Based Health Alliance (CSHA)

Danny Thirakul
Public Policy Coordinator
California Youth Empowerment Network
(CAYEN)


Terry Kim
Director of Government Relations & Advocacy
Children’s Institute

Jeff Farber
Executive Director
Helpline Youth Counseling

Stacey Roth
Chief Executive Officer
Hillsides

Allison Becwar
President & Chief Executive Officer, LCSW
Lincoln Families

Steve Gunther
President & Chief Executive Officer
Maryvale

Alex Briscoe
Principal, Strategy and Systems Change
Public Works Alliance

Lorna Little
President & Chief Executive Officer
St. Anne’s Family Services

Cc: Honorable Members, Senate Education Committee
The Honorable Senator Susan Rubio

AB 908 (SOLACHE) LGBTQ+ Inclusion in LCAP – Support

March 24th, 2025

The Honorable Al Muratsuchi
Chair, Assembly Education Committee  
1020 N Street, Room 159 
Sacramento, CA 95814

RE: Support for Assembly Bill 908 (Solache)

Dear Chair, 

The California Youth Empowerment Network (CAYEN) is pleased to support Assembly Bill 908 (Solache), a bill that would ensure school districts prioritize the education and well-being of LGBTQ+ pupils by requiring a state priority in their local control and accountability plans (LCAP) that describes the school district’s implementation of supportive policies and initiatives for LGBTQ+ pupils. 

CAYEN is a youth-led statewide network comprised of TAY Action Teams and CAYEN Board members which engages, empowers and represents Transitional Age Youth (TAY), ages 15-26, in mental health advocacy on issues that directly affect TAY. Since CAYEN’s inception in 2006, CAYEN has taken many forms of action to empower TAY in their personal lives and spark progressive change in public policy.  

Schools are essential public institutions that support youth in their social and emotional learning. However, disparities in school connectedness pose a significant risk factor for developing mental health and substance use challenges.[1] A recent study by UCLA’s Williams Institute also found that 10% of public middle and high school students identify as LGBTQ+ in California. These students reported lower levels of school connectedness compared to their non-LGBTQ+ peers.[2] By requiring school districts to describe their implementation of support services for LGBTQ+ youth in their local control and accountability plans, schools can easily identify where the gaps in support are and efficiently address the lack of support or services provided to LGBTQ+ youth.

By requiring school districts to document these efforts, AB 908 will help ensure LGBTQ+ students receive the support they need and prevent behavioral health challenges from developing. For these reasons, we support AB 908 (Solache). If you have any questions, or if CAYEN can provide assistance on this bill or any other behavioral health legislation, please do not hesitate to contact me at dthirakul@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.

Sincerely,

Danny Thirakul
California Youth Empowerment Network
Public Policy Coordinator


[1] Centers for Disease Control and Prevention. (2024). Substance use among youth. Centers for Disease Control and Prevention.  

[2] Choi, S.K. Baams, L., & Wilson, B.D.M.  (2017). LGBTQ Youth in California’s Public Schools: Differences across the State. Los Angeles: The Williams Institute  

AB 727 (GONZÁLEZ) Pupil Identification Cards – Support

March 24th, 2025

The Honorable Al Muratsuchi
Chair, Assembly Education Committee   
1020 N Street, Room 159  
Sacramento, CA 95814 

RE: Support for Assembly Bill 727 (González)

Dear Chair, 

The California Youth Empowerment Network (CAYEN) is pleased to support Assembly Bill 727 (González), legislation that would require schools and institutions of higher education to provide the Trevor Project’s suicide hotline and text line on their students’ identification cards.

CAYEN is a youth-led statewide network, comprised of TAY Action Teams and CAYEN Board members, that engages, empowers, and represents Transitional Age Youth (TAY), ages 15-26, in mental health advocacy on issues that directly affect TAY. Since 2006, CAYEN has actively worked to empower TAY and drive meaningful change in public policy, particularly in increasing access to vital mental health supports.

This bill improves timely access to crisis support and culturally responsive services for youth facing mental health challenges by ensuring a suicide hotline and text line is readily available to them. This will help reduce information barriers and empower them to take control of their health and wellness. For these reasons, CAYEN supports AB 727 (González) and asks you to vote “Aye.” If you have any questions, or if CAYEN can provide assistance on this bill or any other behavioral health legislation, please do not hesitate to contact me at dthirakul@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.

Sincerely,

Danny Thirakul

California Youth Empowerment Network
Public Policy Coordinator

AB 0579 (CASTILLO) Yaeli’s Law – Oppose

March 24th, 2025

The Honorable Ash Kalra
Chair, Assembly Judiciary Committee 
1020 N Street, Room 104
Sacramento, CA 95814

RE: Opposition to Assembly Bill 579 (Castillo)

Dear Chair, 

The California Youth Empowerment Network (CAYEN) respectfully opposes Assembly Bill 579 (Castillo), legislation that puts transgender youth at greater risk of potential child abuse and neglect by changing statute to explicitly state that misgendering a child or denying them gender-affirming medical care are not forms of child abuse or neglect.

CAYEN is a youth-led statewide network, comprised of TAY Action Teams and CAYEN Board members, that engages, empowers, and represents Transitional Age Youth (TAY), ages 15-26, in mental health advocacy on issues that directly affect TAY. Since CAYEN’s inception in 2006, CAYEN has actively worked to empower TAY and drive meaningful change in public policy.  Youth deserve to live as their authentic selves and should not be subjected to neglect and abuse impacting their overall health and wellness.

As a TAY-led network run for and by TAY, public policy solutions that address the needs of youth are most effective when youth voices are at the center of decision-making, especially when policies directly impact them. CAYEN has led successful statewide policy campaigns on mental health education, the Office of Suicide Prevention, and substance use harm reduction, all developed and driven by youth leadership.[1] In contrast, AB 579 disregards the voices of transgender youth, ignoring their right to exist safely and potentially exposing them to continued neglect and abuse from individuals who should be supporting and caring for them.

A 2022 report from The Trevor Project found that suicide attempts among transgender youth increased by 72% between 2018 and 2022. This alarming rise is linked to the growing wave of anti-transgender laws in 19 states, restricting access to gender-affirming care, bathroom use, and school participation.[2] AB 579 would disregard a youth’s identity. As a result, transgender youth will suffer serious harm, facing a significant risk of experiencing a mental health crisis and suicide.

Transgender youth are asking to be recognized and supported in safe environments that affirm their identity. For these reasons, CAYEN must oppose AB 579 (Castillo) and ask you to vote “No.” If you have any questions, or if CAYEN can provide assistance on this bill or any other behavioral health legislation, please do not hesitate to contact me at dthirakul@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.

Sincerely,

Danny Thirakul
California Youth Empowerment Network
Public Policy Coordinator


[1] California Youth Empowerment Network. (2024). Advocacy Across California.

[2] News, T. (2025, February 11). Anti-transgender laws cause up to 72% increase in suicide attempts among transgender and nonbinary youth, study shows. The Trevor Project.  

ACR 23 (QUIRK-SILVA) Peer Appreciation Resolution – Support

March 24th, 2025

The Honorable Sharon Quirk-Silva 
California State Assembly 
1021 O Street, Room #4210
Sacramento, CA 95814 

RE: Support for ACR 23 (Quirk-SIlva)

Dear Assemblymember Quirk-Silva,

The California Youth Empowerment Network (CAYEN) is proud to support Assembly Concurrent Resolution 23, a resolution that would recognize the third week of May 2025 (Mental Health Awareness Month) as Mental Health Peer Appreciation Week.  

CAYEN is a youth-led statewide network comprised of TAY Action Teams and CAYEN Board members which engages, empowers and represents Transitional Age Youth (TAY), ages 15-26, in mental health advocacy on issues that directly affect TAY. Since CAYEN’s inception in 2006, CAYEN has taken many forms of action to empower TAY in their personal lives and spark progressive change in public policy.  

As California faces a growing demand for children and youth mental health services, CAYEN recognizes the critical role of young Peers, youth with lived experience navigating California’s behavioral healthcare system. Their firsthand knowledge is invaluable in shaping policies and ensuring services truly meet the needs of youth. As local and statewide leaders make decisions about mental health services for children and youth, it is essential that youth Peer voices are included. Their perspectives ensure that policies reflect the realities of those most impacted, ultimately strengthening the effectiveness and accessibility of mental health programs across the state.

Furthermore, youth Peers can leverage their lived experience to enter the behavioral health workforce as Medi-Cal Certified Peer Support Specialists. To become certified, they must be at least 18 years old, obtain a high school diploma or GED, complete the required training, and pass the Peer Support Specialist Certification Exam. As certified Peers, they can work within their local communities and schools to support others facing mental health, addiction, or trauma challenges. By sharing their lived experience, they offer hope, encouragement, and guidance, serving as role models for other youth in recovery.

As California continues to address youth mental health needs, investing in and prioritizing youth Peers must remain central to the conversation. For these reasons, we proudly support ACR 23. If you have any questions, or if CAYEN can provide assistance on this resolution or any behavioral health legislation, please do not hesitate to contact me at dthirakul@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org

Sincerely, 

Danny Thirakul
California Youth Empowerment Network
Public Policy Coordinator 

AB 309 (ZBUR) Hypodermic Needles and Syringes – Support

March 24th, 2025

The Honorable Mia Bonta
Assembly Health Committee
1020 N Street, Room 390
Sacramento, CA 95814

RE: CAYEN Support for Assembly Bill 309 (Zbur)

Dear Chair,   

The California Youth Empowerment Network (CAYEN) is pleased to support AB 309 (Zbur), legislation that would allow a physician or pharmacist to continue providing hypodermic needles and syringes to individuals 18 years or older without a prescription or permit.

CAYEN is a youth-led statewide network comprised of TAY Action Teams and CAYEN Board members which engages, empowers and represents Transitional Age Youth (TAY), ages 15-26, in mental health advocacy on issues that directly affect TAY. Since CAYEN’s inception in 2006, CAYEN has taken many forms of action to empower TAY in their personal lives and spark progressive change in public policy.  As CAYEN champions the mental health and well-being of TAY, it is essential to address the specific challenges faced by youth in recovery from substance use disorders.

Youth who use substances requiring hypodermic needles face numerous challenges and should not be further harmed while working towards recovery. Access to clean syringes is a proven harm reduction strategy that prevents the transmission of HIV, viral hepatitis, and other bloodborne diseases, ultimately improving public health and safety.[1] The distribution of safe and clean needles and syringes ensures that youth in recovery can stay safer and healthier, even if they face setbacks.

This bill is a critical step toward reducing preventable harm and protecting community health. For these reasons, CAYEN supports AB 309 (Zbur) and asks for your “Aye” vote. If you have any questions, or if CAYEN can provide assistance on this bill or any other behavioral health legislation, please do not hesitate to contact me at dthirakul@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.  

Sincerely,  

Danny Thirakul 

California Youth Empowerment Network 

Public Policy Coordinator 


[1] Centers for Disease Control and Prevention. (n.d.-b). Syringe Services Programs. Centers for Disease Control and Prevention.

SB 0492 (MENJIVAR) Youth Housing Bond – Support

March 14th, 2025

The Honorable Aisha Wahab
Senate Housing Committee
1021 O Street, Room 3330
Sacramento, CA 95814

RE: Support for Senate Bill 492 (Menjivar)

Dear Chair,

The California Youth Empowerment Network (CAYEN) is pleased to support Senate Bill 492 (Menjivar) the Youth Housing Bond Act of 2025, legislation that would issue bonds for the purpose of developing local youth centers and youth housing.

CAYEN is a youth-led statewide network comprised of youth action teams and a youth advisory board which engages, empowers and represents Transitional Age Youth (TAY), ages 15-26, in mental and behavioral health advocacy on issues that directly affect TAY. As many TAY continue to experience homelessness and barriers to mental and substance use services and supports, CAYEN stands committed to advocating for these vital community-based resources.

Stable housing is one of many social determinants of health that have lifelong impacts on one’s health and wellness. With over 9,000 unaccompanied youth in California currently experiencing homelessness, there is an immediate need to provide targeted housing interventions for TAY.[1]  Furthermore, county prevention funds under the Behavioral Health Services Act (2024) have been eliminated. Counties no longer have designated prevention funding to invest in, develop and sustain youth centers, a behavioral health prevention strategy that meets youth where they are to offer voluntary supports and services to address their mental and substance use challenges.

The Youth Housing Bond Act of 2025 helps address the housing insecurity TAY face and increases access to vital community-based services and support.  It is for those reasons that CAYEN supports SB 492 (Menjivar) and asks for your “Aye” vote. If you have any questions, or if CAYEN can provide assistance on this bill or any other legislation, please do not hesitate to contact me at dthirakul@mhac.org. 

Sincerely,

Danny Thirakul
California Youth Empowerment Network
Public Policy Coordinator


[1] HUD CoC Homeless Populations and Subpopulations Reports (2024)

AB 0068 (ESSAYLI) Armed School Resource Officers – Oppose

February 26th, 2025

The Honorable Al Muratsuchi
Chair, Assembly Education Committee
California State Assembly
1020 N Street, Room 159
Sacramento, CA 95814

RE: OPPOSE AB 68 (Essayli)

Dear Assemblymember Maratsuchi,

The California Youth Empowerment Network (CAYEN) respectfully opposes Assembly Bill 68 (Essayli), a bill that would require an armed resource officer on all school campuses.

CAYEN is a youth-led statewide network comprised of youth action teams and a youth advisory board which engages, empowers and represents Transitional Age Youth (TAY), ages 15-26, in mental and behavioral health advocacy on issues that directly affect TAY. Since CAYEN’s inception in 2006, CAYEN has taken many forms of action to empower TAY in their personal lives and spark progressive local and statewide change in public policy.  On the Margins, our current youth action team in Sonoma County, is currently working on removing school resource officers off campuses and reallocating those funds to support youth mental and behavioral health services.

Armed resource officers are not a mental or behavioral health intervention strategy. They fail to provide meaningful mental or behavioral health support to youth, diverting critical funding from programs and services that are better equipped to address behavioral challenges. In addition, school disciplinary measures disproportionately impact youth of color, specifically Black and Latin(x) youth. The use of armed school resources officers would expose the same population to elevated risks of experiencing a violent and potentially deadly altercation.[1]    Investments into wellness centers, peer support, and other prevention services provide better outcomes that resources officers, especially armed ones, cannot accomplish.

It is for those reasons that CAYEN must oppose this legislation and ask for your “no” vote. If you have any questions, or if CAYEN can provide assistance on this bill or any other legislation, please do not hesitate to contact me at dthirakul@mhac.org. 

Sincerely,

Danny Thirakul
California Youth Empowerment Network
Public Policy Coordinator


[1] Armed School Resource Officers and the Safety of California’s Black and Latine(x) Youth: Policies and Recommendations (2024)

AB 0020 (DEMAIO) End Housing First – Oppose

February 28, 2025

The Honorable Mia Bonta
Chair, Assembly Health Committee
1020 N Street, Room 390
Sacramento, CA 95814

RE: OPPOSE AB 20 (DeMaio)

Dear Chair Bonta,

The California Youth Empowerment Network (CAYEN) respectfully opposes Assembly Bill 20 (DeMaio), a bill that would repeal and end the Housing First model. Housing First is a policy that addresses homelessness by addressing an individual’s primary social determinant of health, stable housing. This approach prioritizes housing regardless of an individual’s substance use, treatment history, or engagement in services. By providing permanent supportive housing for unhoused individuals, it ensures they have the foundation needed to address other determinants, leading to long-term positive health outcomes.

CAYEN is a youth-led statewide network comprised of youth action teams and a youth advisory board which engages, empowers and represents Transitional Age Youth (TAY), ages 15-26, in mental and behavioral health advocacy on issues that directly affect TAY. This includes advocating for housing supports for the over 9,000 unaccompanied unhoused youth in California.[1]

The Housing First model is successful in reducing homelessness because it recognizes housing as a foundational support in someone’s health and wellness journey. When asked about their thoughts on ending Housing First, CAYEN Board member Caleb Merril, 24, explained that “The stability that housing provided, gave me the space to breathe and begin to see what I could achieve. Without that opportunity, I wouldn’t have been able to truly focus on my recovery and build the foundation I needed to grow. Housing First works because it treats housing as a right, not something conditional on being ‘ready’. Everyone deserves the chance to find stability and safety, and dismantling this model would deny countless people the opportunity to heal and thrive, just as I have.”

It is for those reasons that CAYEN must oppose this legislation and ask for your “no” vote. If you have any questions, or if CAYEN can provide assistance on this bill or any other legislation, please do not hesitate to contact me at dthirakul@mhac.org. 

Sincerely,

Danny Thirakul
California Youth Empowerment Network
Public Policy Coordinator


[1] HUD 2024 Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations (2024)