Position Category: MHAC

MHAC Letter RE: Feedback on WET Plan Findings and Recommendations

October 27th, 2025

Ashneek Nanua
Health Program Specialist II
The California Behavioral Health Planning Council
MS 2706 P.O. Box 997413
Sacramento, CA 95899-7413

RE: Feedback on WET Plan Findings and Recommendations

Greetings Ashneek,   

Mental Health America of California (MHAC) serves as a member of the steering committee for the Council’s Workforce and Employment Committee (WEC) and attended virtually the WEC meeting on October 15, 2025, where the California Department of Health Care Access and Information (HCAI) presented its findings and recommendations for the 2026-2030 WET plan. MHAC requests the California Behavioral Health Planning Council consider the following in the creation and adoption of the WET plan:

  1. Enhanced Outreach to Schools in Rural Communities

Rural communities across California struggle to recruit and keep a behavioral health workforce that meets their needs. Enhanced outreach to schools in rural communities will expose youth early on to various behavioral health career opportunities. This targeted outreach will support long-term workforce development of behavioral health professionals that are reflective of the community they serve and reduce rural health disparities.

  • Relocation Benefit and Incentive   

A significant consideration of employment is the location of the employer. Individuals seeking employment will commonly look for opportunities close to where they live, due to the costs of relocation. Providing financial aid or a hiring bonus for relocation increases access to employment opportunities that were previously unavailable to job seekers. This benefit will also significantly help rural communities recruit qualified and experienced providers.

  • Online Education and Training Investments

Online or virtual education and training offer a non-traditional schooling choice for the non-traditional student, supporting individuals who need to work while going to school or people needing to change careers. Online training options also provide flexibility to current providers needing to complete continuing education requirements. Additionally, individuals living in rural locations, without access to a college or university, can benefit substantially from virtual programs. These investments will allow individuals to choose between a variety of career pathways or pipelines and continuing education programs that best meet their needs.

  • Regional Provider Network/Cohort

Behavioral health encompasses a wide range of fields, roles, and specializations. A Regional Provider Network/Cohort (RPN/C) will help connect behavioral health providers within a certain region and offer opportunities for mentorship, streamline warm-handoffs or referrals, and support cross sector collaboration to serve individuals with co-occurring mental health and substance use challenges. The RPN/C would also help connect providers with other professionals that are trained to deliver culturally responsive services for the LGBTQ+, Immigrant/Refugee, Black, and Indigenous communities. For instance, an LGBTQ+ RPN/C would allow a community’s gender affirming providers to establish a network that would allow for appropriate gender-affirming care referrals for clients while also allowing LGBTQ+ affirming providers the opportunity to network with and support other similar providers.

  • Medi-Cal Behavioral Health Scholarship Service Obligation Relief

Future HCAI dollars to train Peer Support Specialists requires those who receive scholarships to become Medi-Cal Certified Peer Support Specialists to work full time for 3 years at qualified Medi-Cal serving facilities. Failure to meet this service obligation will force individuals to pay back the entire scholarship. This requirement is burdensome and disincentivizes peer entry into the behavioral health workforce. HCAI must secure funding to allow peer training organizations to train peers who intend to work part time, or work in settings that see non-Medi-Cal clients. Additionally, we encourage HCAI to develop systems that provide relief to scholarship recipients who are unable to complete the 3-year full time service obligation.

  • Other Considerations

Shifts in the Behavioral Health Services Act allocations have significantly limited the revenue available for Behavioral Health Supports and Services (BHSS), requiring counties and community-based organizations to do more with less funding and resources. This is already leading to the elimination of services and displacement of providers. Furthermore, the renewed focus on Medi-Cal billing creates an extreme administrative burden for local community-based organizations to become Medi-Cal certified and puts those organizations who are unable to bill Medi-Cal at a disadvantage. Together, these challenges result in a loss of vital behavioral health services provided by CBOs. This loss of services represents a significant workforce issue that should be addressed in the HCAI WET Plan.

We appreciate your consideration of our concerns. If you have any questions, or if MHAC can provide any help in the development of the WET Plan, please do not hesitate to contact me at  kvicari@mhac.org or contact our Public Policy Coordinator Danny Thirakul at dthirakul@mhac.org

In Community,

Karen Vicari
Director of Public Policy
Mental Health America of California

Coalition Support Letter – Re: ACR 16 (Mike Fong) Opportunity Youth in California

March 13, 2023

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

Re: ACR 16 (Mike Fong) Opportunity Youth in California – SUPPORT

Dear Assemblymember Al Muratsuchi,

On behalf of a diverse coalition of advocates, we are writing to express our strong support of ACR 16 Opportunity Youth in California.

Opportunity Youth (OY) are individuals between the ages of 16 and 24 that are not in school or working, including youth and young adults involved with the foster care, juvenile justice, and homelessness systems of care. They face unique employment, education, and training barriers that often do not align with efforts that center adults. Opportunity Youth facing socio-economic and systemic barriers are oftentimes disconnected from education and workforce training opportunities, preventing young people of color from accessing our state’s prosperity.

Data collected from the 2021 American Community Survey (ACS) of the U.S. Census shows that in California there were 572,756 youth ages 16-24 who were neither in school nor at work (12.5% disconnection rate). Data also indicated the disconnection rate of Black teens and young adults (ages 16-24) was more than twice that of their White peers (22.3% and 10.9%, respectively). Black and Latinx adolescents not only are disproportionately more likely to come from low-income households and have experienced past trauma but are also faced with discrimination that can derail their physical and mental well-being. Additionally, despite declines in youth incarceration, significant gaps remain as youth of color are overrepresented in our criminal justice system. Prioritizing OY will not only expand their education and workforce opportunities but also expand the pool of talent that employers can access to meet their workforce needs.

ACR 16 encourages the State of California to create pathways to success for OY and the need to develop a statewide comprehensive plan that will reduce persistent economic inequities, and prioritize: (1) investments in education and workforce training programs that create pathways to good jobs; (2) expand innovative “earn and learn” opportunities such as apprenticeships, pre-apprenticeships, and work-based learning opportunities; (3) advance dual enrollment implementation to allow OY to earn college credit while earning their high school equivalency; (4) ensure inclusivity of OY in the Cradle-to-Career Data System; (5) remove barriers to access student financial aid programs; and (6) protect social safety net investments that support basic needs such as food, housing, internet access, transportation, childcare, health, and mental health care – enabling OY to complete their education and training goals.


For these reasons, we strongly support ACR 16 and we look forward to our state leader’s support for this important resolution.


If there are any questions, please contact Anna Alvarado at aalvarado@caedge.org.


Sincerely,


Alliance for Children’s Rights
Erica Hickey
Policy Fellow

Bill Wilson Center
Josh Selo
CEO

California Alliance of Boys & Girls Clubs
Sarah Bedy
Director

California Children’s Trust
Alex Briscoe
Principal

California EDGE Coalition
Zima Creason
Executive Director

California Forward Action Fund
David Nelson
Executive Director

California Hospital Association
Peggy Wheeler
Vice President of Rural Health & Governance

California Opportunity Youth Network (COYN)
Sean Hughes
Policy Director

California Workforce Association
Bob Lanter
Executive Director

California Youth Empowerment Network (CAYEN)
Heidi L. Strunk
President & CEO

Center for Employment Training
Pascal Do
COO

Children Now
Danielle Wondra
Senior Policy & Outreach Associate, Child Welfare

City of San Jose
Sarah Zárate
Director, Office of Administration, Policy, and Intergovernmental Relations, City of San Jose

Civicorps
Tessa Nicholas
Executive Director

Coalition for Humane Immigrant Rights (CHIRLA)
Rita Medina
Deputy Director, State Policy & Advocacy

Coalition for Responsible Community Development
Mark Wilson
President & CEO

EntreNous Youth Empowerment Services
Sara Silva
Co-Founder & Co-Executive Director

Envision Your Pathway
Kendra Fujino O’Donoghue
Executive Director

Excite Credit Union
John Hogan
Vice President Community Relations

Foster Care Counts
Jeanne Pritzker
President

Foster Greatness
Colette Smith
Executive Director

GO Public Schools
Darcel Sanders
CEO

Goodwill Southern California
Dr. Luis B. Castañón
Strategic Impact Officer

Groundwork Social Sector Consulting
Joe Herrity
Principal

Growing Big Ideas
Shawna N Weir-Wright
Chief Possibilities Officer

iFoster
Serita Cox
CEO

John Burton Advocates for Youth
Amy Lemley
Executive Director

Juma Ventures
Adriane Armstrong
CEO

Kids in Common
Dana Bunnett
Executive Director

Lighthouse Silicon Valley
Quency Phillips
Executive Director

Linked Learning Alliance
Anne Stanton
President & CEO

Mental Health America of California
Heidi L. Strunk
President & CEO

New Door Ventures
Kevin Hickey
Chief Program Officer

New Ways to Work
Robert Sainz
President & Executive Director

Pivotal
Matt Bell
CEO

Regional Economic Association Leaders (REAL) Coalition
Cynthia Murray
REAL Coalition Education & Workforce Development Chair

San Diego Workforce Partnership
Nick DeVico
Director of Strategic Youth Initiatives

San Jose Conservation Corps and Charter School
Mayra Mejia
Director, CFET Youth Programs & Support Services

Santa Clara County Youth Action Board
Jocelyn Arenas
Board Member

Seen&Heard
Regan Williams
CEO

Small Business Majority
Bianca Blomquist
Political Director

Soledad Enrichment Action
Nathan Arias
President & CEO

The RightWay Foundation
Franco Vega
Founder & CEO

Alliance for Boys & Men of Color
Eric Morrison-Smith
Executive Director

UNITE-LA
Alysia Bell
President & CEO

Urban Strategies Council
David A. Harris
President & CEO

VOICES
Amber Twitchell
Director

Youth Will
Safia Haidari
Director of Policy Advocacy & Organizing

The Unity Council
Chris Iglesias
CEO

Coalition Letter Re: Threat to Consumer Mental Health and Substance Use Disorder Coverage Laws Under SB 855 (Chapter 151, 2020)

July 26, 2023

To:
Assembly Speaker’s Office
Senate Pro Tem’s Office
Assembly Health Committee
Senate Health Committee
Governor Newsom’s Office

Re: Threat to Consumer Mental Health and Substance Use Disorder Coverage Laws Under
SB 855 (Chapter 151, 2020)

Dear Members of the Legislature:

Our organizations, which are committed to ensuring that Californians are able to access medically necessary mental health and substance use disorder (MH/SUD) treatment, write to you to express concerns about an attempt to weaken Senator Wiener’s landmark bill, SB 855 (Chapter 151, 2020), which enacted nation-leading MH/SUD coverage protections. We would oppose amendments to SB 855 to allow use of criteria developed by for-profit entities, which is why we were concerned to learn the MCG, one of the primary licensors of for-profit proprietary criteria, has been seeking amendments to do just that.

Under SB 855, Californians in fully-insured, state-regulated health plans have the most comprehensive consumer protections governing coverage of MH/SUD care in the country.

This critical law requires that health plans cover all medically necessary MH/SUD treatment and requires health plans to make medical necessity determinations in accordance with generally accepted standards of care (GASC) for MH/SUD. Prior to SB 855, there was no requirement under California law that health plans make these determinations consistent with GASC.


SB 855 also requires health plans to exclusively use nonprofit clinical specialty association criteria for medical necessity determinations to ensure (1) compliance with GASC and (2) that decisions are not tainted by financial conflicts of interests. Again, prior to SB 855, plans could essentially use whatever criteria they wished, including non-transparent proprietary criteria that put plans’ financial interests ahead of patients’. Such criteria stand in stark contrast to criteria established by nonprofit clinical specialty associations, which are developed through a transparent, consensus-based process. Renowned clinical specialty associations such as the American Psychiatric Association, the American Psychological Association, the American Society of Addiction Medicine (ASAM), the American Academy of Child and Adolescent Psychiatry (AACAP), and the American Association of Community Psychiatry (AACP) go through rigorous processes to ensure that the guidelines and criteria they create reflect GASC and are broadly accepted by MH/SUD clinicians, ensuring that patients’ medical needs come first.

SB 855’s nonprofit medical necessity criteria requirements are critical because such criteria are:

  • Fully transparent and accessible. Consumers, providers, and other stakeholders can
    readily access the criteria being used to determine whether specific MH/SUD services
    are, in fact, appropriate to meet individual patient needs.
  • Developed through a consensus process that protects against conflicts of interest.
    The authors and reviewers of nonprofit criteria are publicly identified. Credentials,
    expertise, and potential conflicts of interests can be evaluated by the public.
  • Externally validated. Nonprofit clinical criteria are subject to rigorous peer review,
    validation studies in real-world clinical settings, and are reviewed in professional and
    scholarly journals.

    In fact, as early as 1997, research published in the American Journal of Psychiatry, the official, peer-reviewed journal of the American Psychiatric Association, sounded warning bells, concluding that: “Our findings underscore the necessity of determining the validity of all criteria used to assess the appropriateness of medical care. Wide acceptance of an instrument is clearly not sufficient to justify its use . . . The need for validation studies is particularly great when proprietary criteria are not available for public scrutiny.”1

    We note that in 2021, the nation’s largest insurer, United Healthcare (UHC) claimed to have voluntarily switched to nonprofit clinical association criteria by ASAM, AACP, and AACAP throughout the United States for all its level of care determinations. Under its brand name “Optum,” UHC explained why it switched to nonprofit clinical criteria for mental health and substance use disorders:2
  • The criteria were “[e]xternally validated”
  • The criteria used a “Common Language [That] Drives Improved Care”
  • “The six dimensions [of the guidelines] provide a more holistic view of acuity and chronicity of behavioral health condition, thereby promoting more appropriate care for patients and a better overall experience.” (emphasis added)

    UHC further noted that the nonprofit clinical specialty association criteria were better than proprietary criteria such as those created by for-profit publishers like MCG (formerly “Millman”) and InterQual, because these nonprofit clinical criteria “adopted a systems of care approach” that was “tailored to the specific age of the member” and better incorporated “the use of wrap-around services.”3 We agree.

    Use of the nonprofit clinical specialty association criteria sets a clear, unambiguous standard that protects patients. For example, if a level of care assessment using “The ASAM Criteria” indicates that an individual needing substance use disorder treatment is most appropriately treated in a Clinically Managed Residential Withdrawal Management (ASAM Level 3.2-WM) facility, under California law, the insurer must cover this level of treatment. Or if a young person with early psychosis symptoms needs Coordinated Specialty Care, as is clearly recommended by the American Psychiatric Association’s “Practice Guideline for the Treatment of Patients With Schizophrenia,” the health plan must cover these life-saving services.

    The centrality of SB 855’s non-profit clinical criteria requirements is why we were alarmed to learn that MCG is pushing for amendments to SB 855’s clinical criteria provisions. MCG seeks to amend SB 855 so that its proprietary criteria, which it sells to providers on a subscription basis, will also be considered acceptable in California for making medical necessity determinations. Though skeptical, our organizations agreed to meet with MCG. However, in order to allow us to fully review and evaluate its MH/SUD criteria after this initial meeting, MCG insisted that our organizations execute Non-Disclosure Agreements. We refused, because such a constraint and lack of transparency only play into the numerous problems inherent in secret, for-profit clinical criteria that broadly impact public health.

    That other states are following California’s lead demonstrates the importance of having one set of allowed clinical criteria – the criteria that are developed by the leading nonprofit clinical specialty associations. After SB 855’s enactment, Illinois and Oregon enacted nearly identical language requiring the use of nonprofit clinical association criteria for MH/SUD medical necessity determinations. And, in reviewing health plans’ mental health level of care criteria, the New York State Office of Mental Health rejected all 69 plans’ guidelines as flawed and inconsistent with GASC. Critically, New York State automatically deemed mental health criteria from AACP and AACAP as automatically compliant. Numerous other states have also mandated nonprofit criteria such as The ASAM Criteria.4

    Lastly, it is important to note that SB 855 purposely addresses gaps in situations that are not expressly addressed by existing nonprofit clinical association criteria. The use of for-profit clinical criteria is permitted if they (1) are outside the scope of the relevant nonprofit professional criteria or(2) relate to advancements in technology or types of care not covered by the nonprofit criteria. However, efforts to open the door to for-profit criteria within the scope of nonprofit criteria invites profound confusion and will undermine the creation of a common language necessary to improve access to quality care.

    Therefore, we request that you oppose any effort to change SB 855’s provisions relating to medical necessity criteria. Amending SB 855 will hinder the state’s response to the ongoing mental health and addiction crisis and invite new arbitrary denials that California has come so far in trying to prevent. It’s not only patients that have a lot to lose, but taxpayers who must pay for the cost when insurers inappropriately deny needed treatment – exactly the point that the California Department of Justice took in a recent federal amicus brief.5

    Thank you for your efforts to improve access to life-saving care. We hope that you’ll oppose efforts to weaken California’s nation-leading laws.

    Sincerely,

    Lauren Finke
    The Kennedy Forum

    Jared L. Skillings, PhD, ABPP
    American Psychological Association

    Adrienne Shilton
    California Alliance of Child and Family Services

    Robb Layne
    California Association of Alcohol and Drug Program Executives

    Chad Costello
    California Association of Social Rehabilitation Agencies

    Paul Yoder
    California State Association of Psychiatrists

    Danny Thirakul
    California Youth Empowerment Network

    Katelin Van Deynze
    Health Access California

    Heidi Strunk
    Mental Health America of California

    Karen Fessel
    Mental Health & Autism Insurance Project

    Danny Offer
    National Alliance on Mental Illness California

    Fred Seavey
    National Union of Healthcare Workers (NUHW)

    Joy Burkhard
    Policy Center for Maternal Mental Health

    Randall Hagar
    Psychiatric Physicians Alliance of California

    Tara Gamboa-Eastman
    Steinberg Institute

1 Goldman RL, Weir CR, Turner CW, Smith CB. Validity of utilization management criteria for psychiatry. Am J Psychiatry. 1997 Mar;154(3):349-54. doi: 10.1176/ajp.154.3.349. PMID: 9054782.

2 The mental health criteria UHC voluntarily switched to were the Level of Care Utilization System (LOCUS),which is developed by AACP, for adults; the Child and Adolescent Level of Care/Service Intensity Utilization System (CALOCUS-CASII), which is developed jointly by AACP and AACAP, for children and adolescents ages 6-18; and the Early Childhood Service Intensity Instrument (ECSII), which is developed by AACAP, for children ages 0-5. UHC also voluntarily switched to using The ASAM Criteria, but the notice to providers (see note 2) was specifically related to the mental health nonprofit criteria.

3 Optum. “Optum Clinical Criteria for Behavioral Health Conditions Change to LOCUS, CASII, ECSII: Frequently Asked Questions.” (2021). https://public.providerexpress.com/content/dam/opeprovexpr/us/pdfs/clinResourcesMain/guidelines/optumLOCG/locg/LCE-FAQs.pdf.

4 Legal Action Center and Partnership to End Addiction. “Spotlight on Medical Necessity Criteria for Substance Use Disorders.” November 2020. Note, this report predated enactment of SB 855 or the laws in Illinois or Oregon.

5 See https://oag.ca.gov/news/press-releases/attorney-general-bonta-files-brief-support-access-mental-healthcare-services.

AB 432 (BAUER-KAHAN) Improve insurance coverage and continuing medical education for menopause – Support

September 15th, 2025

The Honorable Gavin Newsom 
California State Governor 
1021 O Street, Suite 9000 
Sacramento, CA 95814

RE: Request for Signature of Assembly Bill 432 (Bauer-Kahan)

Dear Governor Newsom,   

Mental Health America of California (MHAC) is pleased to support Assembly Bill 432 (Bauer-Kahan), legislation that would require health plans to cover services for the evaluation and treatment of perimenopause and menopause.

MHAC is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. The mission of MHAC is to assist and encourage communities, families, and individuals to experience hope, wellness and recovery from mental health and substance use disorder issues. The people and communities we aim to serve include those of all ages; sexual orientation, gender identity, or expression; language, racial and ethnic backgrounds, national origin, and immigration status; spirituality and religious affiliations; or socioeconomic status. In alignment with our mission, MHAC supports expanding coverage of physical health care to prevent related mental health challenges from developing.

Women going through menopause can see shifts in their hormone levels, putting them at elevated risk for depression and anxiety. According to the Anxiety & Depression Association of America, between 45% and 60% of women experience depression during menopause.[1] Expanding coverage for perimenopause and menopause services would allow women to access care in a timely manner, reducing the risk of associated mental health challenges. This bill ensures that health plans will cover these services, leading to improved mental health outcomes for women.

It is for these reasons MHAC supports AB 432 (Bauer-Kahan) and asks for your signature. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at kvicari@mhac.org or our Public Policy Coordinator, Danny Thirakul, at dthirakul@mhac.org.

 In Community, 

Karen Vicari
Director of Public Policy
Mental Health America of California

[1] Spencer, E. D., & Witkin, M. (2025, April 1). Menopause and mental health: Understanding the connection and recommendations for treatment | anxiety and depression association of america, ADAA. https://adaa.org/learn-from-us/from-the-experts/blog-posts/consumer/menopause-and-mental-health

MHAC Recommendation on Innovation Partnership Fund Working Framework Version 3.0

September 24, 2025

Commissioner Rayshell Chambers
Client, Family, and Community Inclusion, Lived Experience, and Diversity Advisory Committee
Behavioral Health Services Oversight and Accountability Commission
1812 9th Street
Sacramento, CA 95811

RE: Recommendation on Innovation Partnership Fund Working Framework Version 3.0

Dear Chair Chambers,   

Mental Health America of California (MHAC) is reaching out regarding the recently released Innovation Partnership Fund (IPF) Working Framework Version 3.0. To ensure efficacy of the IPF, we recommend the following changes:

Recommendation 1: Innovation Partnership Fund (IPF) Framework Should Prioritize Behavioral Health Services and Supports (BHSS)

The current IPF framework focuses on populations with the highest behavioral health needs. As a result, IPF proposals would center around Full Service Partnership and Housing Intervention programs. However, BHSS funds are not limited to individuals with the highest behavioral health needs. This component of the Behavioral Health Services Act (BHSA) also supports the following:

  1. Services pursuant to Part 4 (commencing with Section 5850) for the children’s system of care and Part 3 (commencing with Section 5800) for the adult and older adult system of care, excluding those services specified in paragraphs (1) and (2).
  2. Early intervention programs in accordance with Part 3.6 (commencing with Section 5840).
  3. Outreach and engagement.
  4. Workforce education and training.
  5. Capital facilities and technological needs.
  6. Innovative behavioral health pilots and projects.

Shifts in BHSA allocations have significantly limited the revenue available for BHSS (formerly Community Services and Supports), requiring counties to do more with less funding and resources. The IPF presents an opportunity to support county programing in these areas while innovating to meet the needs of “Other populations, as determined by the Behavioral Health Services Oversight and Accountability Commission.” Therefore, the framework should reflect this opportunity and prioritize BHSS.

Recommendation 2: Small-Scale Funding Grants and Request for Applications

With the lack of available funding counties receive to support BHSS, it is vital for IPF grants to reflect the potential for community investments that do not require significant amounts of funding. Through our CBH-funded work with Local Level Entities throughout California, these entities have identified multiple innovative solutions for community needs that could be implemented for under $250,000. Thus, in addition to some larger IPF investments, we strongly recommend that the CBH offer small-scale funding grants to meet specific innovative community needs. These small-scale funding grants could be distributed through an application process rather than a request for proposal to reduce administrative burden and increase community access to these funding opportunities.

Recommendation 3: Focus on Community-Based Organization

Partnerships with local Community-Based Organizations (CBOs) provide an opportunity for counties to deliver BHSS with the limited funding they receive. CBOs are local organizations with a pre-existing relationship and an established trust with the community and surrounding population and can bring in additional funding to support county programing. The IPF framework must call out and prioritize CBO involvement. The current proposal references community-based services and providers. However, those are different from prioritizing local CBOs. IPF grants must include these local organizations to align with local programming needs and behavioral health goals. This can be done by expanding interpretation of the Cross Cutting Elements: Lived Experience and Community Leadership and Public-Private Partnerships to include CBOs and Peer-Run Organizations.

Recommendation 4: Provide Guidance on “Other Populations as determined by the Behavioral Health Services Oversight and Accountability Commission”

Counties are responsible for serving numerous diverse communities using the BHSA component that provides the most flexibility, the BHSS. However, the scarce funding for this component must be spread out among various programs and populations. To better support county innovation around these programs, IPF grants should be inclusive of specific populations. The current framework lacks clarity on which population the commission has determined will be served under the IPF. It also does not outline the process the commission will take to make such determinations. MHAC requests the framework provide guidance on how the commission intends to identify these populations prior to the release of request for proposals or applications. Furthermore, MHAC request that the following populations be recognized transition aged youth, the LGBTQIA+ community, and the Immigrant/Refugee population.

These four recommendations will enhance innovation for the BHSA component in need of most support, improve access to grant funding, ensure coordination with local stakeholders, and ensure populations with significant behavioral health disparities are not excluded.

If you have any questions, or if MHAC can provide any assistance, please do not hesitate to contact me at kvicari@mhac.org or our Public Policy Coordinator, Danny Thirakul, at dthirakul@mhac.org. 

In Community,   

Karen Vicari
Director of Public policy

SB 27 (UMBERG) Care Court Expansion – Oppose

September 15th, 2025

The Honorable Gavin Newsom 
California State Governor 
1021 O Street, Suite 9000 
Sacramento, CA 95814

RE: Request for Veto of Senate Bill 27 (Umberg)

Dear Governor Newsom, 

Mental Health America of California (MHAC) respectfully opposes Senate Bill 27 (Umberg), legislation that would expand forced behavioral healthcare treatment by expanding CARE Court eligibility to individuals with Bipolar 1 Disorder. This bill would also prioritize CARE Court over other proven mental health diversion programs for individuals found incompetent to stand trial.

MHAC is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. MHAC envisions a society in which all communities, families and individuals can enjoy full, productive and healthy lives free from discrimination of all kinds regardless of previous or current issues with their mental health or substance use issues. Every person deserves access to appropriate, voluntary services that are delivered in their local community with compassion and respect for everyone’s dignity and autonomy.

We request you Veto SB 27 for the following reasons:

Increases Involuntary Treatment

CARE Court is a legal mechanism to force individuals into court-ordered, and thus involuntary, behavioral health care. Individuals are forced to participate or face potential conservatorship. Currently, CARE Court eligibility is limited to individuals with schizophrenia spectrum disorders with a prevalence in the U.S. ranging between 0.25% and 0.64%.[1] This bill expands eligibility to individuals with Bipolar 1 Disorder with psychotic features. Given that approximately 4.4% of U.S. adults experience bipolar disorder in their lifetime, this bill would represent a substantial increase in CARE referrals.[2] If individuals do not form a CARE agreement or do not comply with their CARE plan individuals are subject to additional hearings and may be referred to conservatorship.

Costly to Taxpayers & Ineffective

In the CARE Court Early Implementation Report released in November 2024, the Department of Health Care Services reported only a total of 100 participants statewide[3][4]. With only 100 people enrolled in CARE Court, it costs an estimated $713,000 per person a year. These costs are for court personnel and other court costs, and do not include any allocation for services. For comparison, Full-Service Partnerships (FSP) are designed to provide treatment for, and services to, adults with serious mental illness. FSP’s cost taxpayers approximately $16,666 per person per year and in 2021 served more than 60,000 people statewide.

This bill attempts to increase CARE Court referrals in response to the low, almost nonexistent, number of CARE participants. CARE Court’s inability to meet expectations indicates a systemic flaw that won’t be solved by expanding the criteria of who can be forced into treatment via a court order. It is for these reasons that we are opposed to SB 27 (Umberg) and ask for your “Veto”.

If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at kvicari@mhac.org or our Public Policy Coordinator, Danny Thirakul, at dthirakul@mhac.org.

In Community,   

Karen A Vicari, JD
Director of Public Policy

[1] U.S. Department of Health and Human Services. (n.d.-b). Schizophrenia. National Institute of Mental Health. https://www.nimh.nih.gov/health/statistics/schizophrenia

[2] U.S. Department of Health and Human Services. (n.d.). Bipolar disorder. National Institute of Mental Health. https://www.nimh.nih.gov/health/statistics/bipolar-disorder#part_2605

[3] Mai-Duc, C. (2024, November 27). California falling short of enrollment goal as Mental Health Courts Roll Out Statewide. California Healthline.

[4] Depart of Health Care Services . (2024, November). CARE Act Early Implementation Report. Community Assistance, Recovery, and Empowerment Act.  

AB 787 (PAPAN) Provider Directory Disclosure – Support

June 11th, 2025

The Honorable Caroline Menjivar
Senate Health Committee
1021 O Street, Room 3310
Sacramento, CA 95814

RE: MHAC Support for AB 787 (Papan)

Dear Chair Menjivar,   

Mental Health America of California (MHAC) is pleased to support Assembly Bill 787 (Papan), legislation that would require health plans to respond to enrollee inquires seeking a provider within one business day and provide a list of available providers within 2 business days.

MHAC is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. The mission of MHAC is to assist and encourage communities, families and individuals to experience hope, wellness and recovery from mental health and substance use disorder issues. The people and communities we aim to serve include those of all ages; sexual orientation, gender identity or expression; language, racial and ethnic backgrounds, national origin, and immigration status; spirituality and religious affiliations; or socioeconomic status.

Finding a mental health provider within your health plan can be a significant barrier to receiving services. Inaccurate provider directories can lead to prolonged delays in care, frustration, and sometimes leads individuals to give up seeking mental health care altogether. Enrollees attempting to make an appointment using a directory may discover that the provider is no longer contracted with their health plan, has moved, or is no longer accepting new patients. Once a provider is located, enrollees may still have to wait up to 15 days before establishing care.

Timely access plays a vital role in an individual’s health and wellness. This bill will help reduce delays in identifying an available provider by disclosing to enrollees that they should contact the health plan if they need assistance and establishing a standardized response time. It is for these reasons MHAC supports AB 787 (Papan) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org. 

In Community,   

Heidi L. Strunk   
President & CEO 

AB 602 (HANEY) Postsecondary Education Substance Use Harm Reduction Policy – Support

September 5th, 2025

The Honorable Gavin Newsom
California State Governor
1021 O Street, Suite 9000
Sacramento, CA 95814

RE: Request for Signature of Assembly Bill 602 (Haney)

Dear Governor Newsom,   

Mental Health America of California (MHAC) is pleased to support AB 602 (Haney), legislation that would establish a harm reduction approach to supporting students who are experiencing substance use crises by protecting them from punitive academic disciplinary policies.

MHAC is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. The mission of MHAC is to assist and encourage communities, families and individuals to experience hope, wellness and recovery from mental health and substance use disorder issues. The people and communities we aim to serve include those of all ages; sexual orientation, gender identity or expression; language, racial and ethnic backgrounds, national origin, and immigration status; spirituality and religious affiliations; or socioeconomic status. People experiencing a mental health or substance use crisis need to be able to seek help without fear of repercussions.

For youth, colleges and universities can impose various punishments on students found with drugs or involved in overdose incidents. While some CSU and UC campuses have medical amnesty policies, most only protect students in alcohol-related emergencies, not drug overdoses. Additionally, a disciplinary record can make it harder to transfer, graduate, or find a job, as many employers and professional licensing boards ask about academic misconduct.

The inconsistent implementation of these policies creates confusion and fear, leaving students afraid to call 911 in life-or-death situations. No student should have to choose between saving a life and risking their future. Without a clear, statewide policy, students fear severe consequences for seeking medical help, leading to dangerous delays in life-or-death situations. This bill will protect students involved in overdose emergencies by ensuring they are fully shielded from academic penalties.

This bill guarantees that neither the student experiencing an overdose nor bystanders who summon help will face any academic consequences. Students will no longer be punished for surviving an overdose, and the fear of severe academic penalties will no longer prevent them from seeking life-saving assistance. It is for these reasons that MHAC supports AB 602 (Haney) and asks for your signature. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health policies, please do not hesitate to contact me at kvicari@mhac.org or our Public Policy Coordinator, Danny Thirakul, at dthirakul@mhac.org.

In Community,   

Karen Vicari
Director of Public Policy

AB 512 (HARABEDIAN) Shortened timeline for prior authorization – Support

September 17th, 2025

The Honorable Gavin Newsom  
California State Governor  
1021 O Street, Suite 9000  
Sacramento, CA 95814

RE: Request for Signature of AB 512 (Harabedian)

Dear Governor Newsom, 

Mental Health America of California (MHAC) is pleased to support Assembly Bill 512 (Harabedian), legislation that would shorten prior authorizations for health care services to no more than 48 hours for standard requests or 24 hours for urgent requests.

MHAC is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. The mission of MHAC is to assist and encourage communities, families and individuals to experience hope, wellness and recovery from mental health and substance use disorder issues through voluntary services that are delivered in their local community with compassion and respect for everyone’s dignity and autonomy. Prior authorization procedures can create significant barriers to access voluntary mental health and substance use services.

The prior authorization process requires providers to obtain approval from health plans before delivering certain supports or services, including mental health care. However, this process can take anywhere from one to five days. This delay can create unnecessary barriers to accessing voluntary services, services that are intended to support individuals before they reach a point of crisis. This bill ensures that care is delivered promptly by reducing delays for both standard and urgent requests.

It is for these reasons MHAC supports AB  512 (Harabedian) and asks for your signature. If you have any questions, or if MHAC can provide any assistance on this bill or any other behavioral health legislation, please do not hesitate to contact me at kvicari@mhac.org or our Public Policy Coordinator, Danny Thirakul, at dthirakul@mhac.org.

In Community,

Karen Vicari
Director of Public Policy
Mental Health America of California

AB 510 (ADDIS) Health care coverage peer-to-peer review – Support

April 14th, 2025

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

RE: Support for Assembly Bill 510 (Addis)

Dear Chair Bonta,

Mental Health America of California (MHAC) is pleased to support AB 510 (Addis), legislation that ensures appeals or grievances related to denied healthcare services are reviewed within 2 business days by a licensed physician or a qualified healthcare professional with expertise in the relevant area. Additionally, if these timelines are not met, the request would be automatically approved.

MHAC is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. The mission of MHAC is to assist and encourage communities, families and individuals to experience hope, wellness and recovery from mental health and substance use disorder issues through voluntary services that are delivered in their local community with compassion and respect for everyone’s dignity and autonomy.

Individuals can experience a range of mental health or substance use challenges, and when they seek appropriate support or services through their health insurance, coverage denials can create serious gaps in care. While health plans offer grievance processes for enrollees to challenge these denials, the grievances are sometimes reviewed by general physicians or health administrators who may lack the specialized expertise needed to assess mental health or substance use conditions. This lack of competency can lead to continued denials, delaying or denying access to necessary care. In 2016, the Department of Managed Health Care reported that enrollees who requested an Independent Medical Review (IMR) after a health plan grievance was unresolved received the requested health care services in nearly 69 percent of cases.[1]

By ensuring competent review of coverage denials in the grievance process, this bill will help reduce gaps in care and reduce the need for IMRs. It is for these reasons MHAC supports AB 510 (Addis) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please feel free to contact me at hstrunk@mhac.org or reach out to our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.

In Community,   

Heidi L. Strunk   
President & CEO 

[1] The California Department of Managed Health Care. (2016). 2016 ANNUAL REPORT.