California
AB2161
AB2161 - Medi-Cal eligibility: work or community engagement.
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Amended IN Senate August 19, 2026 Amended IN Senate August 13, 2026 Amended IN Assembly May 18, 2026 Amended IN Assembly March 23, 2026 CALIFORNIA LEGISLATURE— 2025–2026 REGULAR SESSION Assembly Bill No. 2161 Introduced by Assembly Member Bonta (Coauthors: Assembly Members Boerner, Stefani, Aguiar-Curry, and Caloza) February 18, 2026 An act to amend Section 14005.69 of the Welfare and Institutions Code, relating to Medi-Cal. LEGISLATIVE COUNSEL'S DIGEST AB 2161, as amended, Bonta. Medi-Cal: redeterminations and Medi-Cal eligibility: work or community engagement. Existing law establishes the Medi-Cal program, which is administered by the State Department of Health Care Services and under which qualified low-income individuals receive health care services. The Medi-Cal program is in part governed by, and funded pursuant to, federal Medicaid program provisions. Existing federal law, enacted on July 4, 2025, sets forth various changes to Medicaid eligibility with regard to community engagement reporting, redeterminations, cost sharing, and retroactive coverage, among other factors, for certain Medicaid populations, including law generally requires, commencing in 2027, Medicaid beneficiaries between 19 and 64 years of age, inclusive, with income up to 138% of the federal poverty level, commonly known as Medicaid expansion adults. Federal law generally requires a Medicaid expansion adult, commencing January 1, 2027, or earlier at state option, adults, to demonstrate community engagement as a condition of Medicaid eligibility. Existing Existing state law sets forth various provisions to conform to that federal requirement. Existing law requires, no sooner than January 1, 2027, as specified, an applicable individual to demonstrate work or community engagement. Existing law sets forth the mechanisms for an applicable individual to comply with that requirement on a monthly basis, including, among others, a minimum of 80 hours of work, community service, or participation in a work program, or a minimum of half-time enrollment in an educational program. Existing law exempts certain categories of individuals from the requirement, including, among others, a parent or family caregiver of a dependent child 13 years of age or younger or a disabled individual, and a medically frail person. Existing law states the intent of the Legislature that the department implement work or community engagement requirements under the above-described federal law to ensure that all eligible Medi-Cal applicants and beneficiaries obtain and maintain coverage in ways that are least administratively burdensome to those individuals. Existing law sets forth provisions to conform to the above-described federal provisions, including work or community engagement requirements, exemptions, and notices of noncompliance if applicable. For purposes of the above-described provisions, the bill would revise the definitions of “applicable individual” and “educational program,” as specified. The bill would also revise the definition of “work program” to allow the inclusion of additional programs that comply with federal regulation or directives. The bill would require an applicable individual’s total monthly income and average monthly income over the preceding 6 months to be calculated using modified adjusted gross income-based financial methods, as specified, for purposes of demonstrating the individual’s work or community engagement. For beneficiaries who cannot be deemed compliant following ex parte review, the bill would authorize a county to request a Medi-Cal managed care plan to provide any information that will verify that a beneficiary is exempt or meets the requirements. The bill would require the county to request that an applicant or beneficiary confirm information before taking any adverse action on the application or renewal when there is a conflict in reliable data sources that adversely impacts the eligibility of an applicant or beneficiary. This bill would make changes to the definitions of “applicable individual,” “work program,” and “educational program,” and to some of the compliance mechanisms regarding monthly income, for purposes of the above-described provisions. When there is a conflict in reliable data sources that adversely impacts the eligibility of an applicant or beneficiary, the bill would require the county to request the applicant or beneficiary to confirm information before taking any adverse action on the application or renewal. Existing law specifies that if a county requires a county, if it is unable to verify that an applicable individual either has met the requirement to demonstrate work or community engagement or was deemed to have demonstrated work or community engagement, the county is required to provide the individual with a notice of noncompliance, as specified, and to continue to provide the individual with a period of 30 calendar days to make a satisfactory showing consistent with the work and community engagement requirements. Medi-Cal services during a 30-calendar-day period if the individual is enrolled in the Medi-Cal program. This bill would require the county to notify applicable individuals enrolled in the Medi-Cal program of the requirement to demonstrate work or community engagement based on certain delivery formats. For an applicable individual renewing their Medi-Cal enrollment during a 6-month redetermination period and who otherwise meets all other eligibility criteria, the bill would require the county to maintain active eligibility pending verification of work or community engagement until at least the last day of the month of the 30-calendar-day period. Under the bill, an applicable individual would be deemed to have received a the notice of noncompliance 5 days after the date on the notice. Under the bill, self-attestation by an applicable individual that the individual did not receive a timely notice constitutes good cause for not providing the above-described satisfactory showing. The bill would set forth other procedural steps for the county in reissuing the notice of noncompliance and maintaining or reactivating Medi-Cal eligibility. would constitute good cause for not providing a satisfactory showing within the 30-calendar-day period. If no satisfactory showing is made after the 30-calendar-day period, the bill would require the department to consider all other bases of eligibility for medical assistance under the Medi-Cal state plan prior to denying coverage at application or determining that an individual is ineligible. This bill would authorize the department to defer implementation of these changes to existing law if these changes would The bill would authorize the department to defer implementation of any of the above-described changes if the change would result in a fiscal impact that would require an additional appropriation and that additional appropriation has not been made, as specified. By creating new duties for counties relating to Medi-Cal eligibility determinations with regard to work or community engagement, the bill would impose a state-mandated local program. The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement. This bill would provide that, if the Commission on State Mandates determines that the bill contains costs mandated by the state, reimbursement for those costs shall be made pursuant to the statutory provisions noted above. Digest Key Vote: MAJORITY Appropriation: NO Fiscal Committee: YES Local Program: YES Bill Text The people of the State of California do enact as follows: SECTION 1. Section 14005.69 of the Welfare and Institutions Code is amended to read: 14005.69. (a) It is the intent of the Legislature that the department implement work or community engagement requirements set forth in Section 1396a(xx) of Title 42 of the United States Code (Section 71119 of federal H.R. 1 (Public Law 119-21)) to ensure that all eligible Medi-Cal applicants and beneficiaries obtain and maintain coverage in ways that are least administratively burdensome to applicants and beneficiaries. (b) For purposes of this section, the following definitions apply: (1) “Applicable individual” means an individual, other than a specified excluded individual as defined in paragraph (2), who is eligible to enroll, or is enrolled, in the Medi-Cal program and is either any of the following: (A) An individual whose Medi-Cal eligibility is pursuant to Section 1396a(a)(10)(A)(i)(VIII) of Title 42 of the United States Code. (B) An individual who receives state-funded Medi-Cal coverage and who meets the same criteria described in Section 1396a(a)(10)(A)(i)(VIII) of Title 42 of the United States Code. (C) An individual who meets both of the following: (i) Is otherwise eligible to enroll, or is enrolled, under a waiver of the Medi-Cal state plan that provides coverage that is equivalent to minimum essential coverage, as described in Section 5000A(f)(1)(A) of the Internal Revenue Code of 1986 and as determined in accordance with standards prescribed by the United States Secretary of Health and Human Services in regulations. (ii) Has attained 19 years of age and is under 65 years of age, is not pregnant, and is not entitled to, or enrolled for, benefits under federal Medicare Part A (42 U.S.C. Sec. 1395c et seq.), or eligible for, or enrolled for, benefits under federal Medicare Part B (42 U.S.C. Sec. 1395j et seq.). (2) “Specified excluded individual” means any of the following individuals, as determined in accordance with criteria established by federal regulation or directive from the federal Centers for Medicare and Medicaid Services: (A) An individual who is described in Section 1396a(a)(10)(A)(i)(IX) of Title 42 of the United States Code. (B) An Indian or an Urban Indian, as defined in paragraphs (13) and (28) of Section 1603 of Title 25 of the United States Code, respectively. (C) A California Indian, as described in Section 1679(a) of Title 25 of the United States Code. (D) An individual who has otherwise been determined eligible as an Indian for the federal Indian Health Service under regulations promulgated by the United States Secretary of Health and Human Services. (E) The parent, guardian, caretaker relative, or family caregiver of a dependent child 13 years of age or younger or a disabled individual. (F) The parent, guardian, caretaker relative, or family caregiver of an individual with a chronic or other health condition, disability, or functional limitation. (G) A veteran with a disability rated as total under Section 1155 of Title 38 of the United States Code. (H) An individual who is medically frail or otherwise has special medical needs, as defined by the United States Secretary of Health and Human Services, including any of the following individuals: (i) An individual who is blind or disabled, as defined in Section 1382c of Title 42 of the United States Code. (ii) An individual with a substance use disorder. (iii) An individual with a disabling mental disorder. (iv) An individual with a physical, intellectual, or developmental disability that significantly impairs their ability to perform one or more activities of daily living. (v) An individual with a serious or complex medical condition. (I) An individual in compliance with the work requirements under the federal Temporary Assistance for Needy Families (TANF). (J) A member of a household that receives Supplemental Nutrition Assistance Program (SNAP) benefits under the federal Food and Nutrition Act of 2008 (Public Law 110-246) and is not exempt from a work requirement under that act. (K) An individual participating in a drug addiction or alcoholic treatment and rehabilitation program, as defined in Section 2012(h) of Title 7 of the United States Code. (L) An inmate or former inmate of a public institution released at any point during the three-month period ending on the first day of that month. (M) An individual who is pregnant or entitled to postpartum medical assistance under paragraph (5) or (16) of Section 1396(e) of Title 42 of the United States Code. (N) Foster youth or former foster youth under 26 years of age. (3) “Educational program” includes all of the following: (A) An institution of higher education, as defined in Section 1001 of Title 20 of the United States Code. (B) A program of career and technical education, as defined in Section 2302 of Title 20 of the United States Code. (C) A high school, as defined in Section 7801 of Title 20 of the United States Code. (D) A state-approved program of study leading to a certificate of high school equivalence for an applicable individual who has not received a high school diploma. (4) “Work program” has the meaning as set forth in Section 2015(o)(1) of Title 7 of the United States Code, which includes, among other programs, certain employment and training programs described in paragraph (4) of subdivision (d) of that section, subject to the exclusions described in paragraph (1) of subdivision (o) of that section. “Work program” may include additional programs that comply with federal regulation or directives. (c) The department shall confirm that systems are programmed to maintain coverage with minimal information requests to an applicant or beneficiary by doing both of the following: (1) Verifying compliance through interfaces with data sources that include, but are not limited to, wage data, Medi-Cal eligibility aid codes, Medi-Cal claims and encounter data, and data from the State Department of Social Services. (2) Allowing individuals the option to add, through consent-based verification platforms and any other means, information to their application or renewal for purposes of verifying compliance. (d) No sooner than January 1, 2027, pursuant to the requirements set forth in Section 1396a(xx) of Title 42 of the United States Code, as a condition of Medi-Cal eligibility, and following the department’s confirmation that systems are programmed to maintain coverage with minimal data requests to an applicable individual, an applicable individual shall demonstrate work or community engagement. (1) An applicable individual who applies for the Medi-Cal program shall demonstrate work or community engagement for one month immediately preceding the month during which the individual applies for the Medi-Cal program. (2) An applicable individual enrolled and receiving Medi-Cal services shall demonstrate work or community engagement for any one month during the period between the individual’s most recent determination or redetermination, as applicable, of eligibility and their next regularly scheduled redetermination of eligibility as described in Section 14005.37. (e) Subject to this subdivision and subdivision (f), an applicable individual demonstrates work or community engagement for a month if they meet one or more of the following conditio
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