On January 1, 2027, about 1.9 million Medi-Cal enrollees with unsatisfactory immigration status (UIS) will leave managed care and move to fee-for-service (FFS). The shift is driven largely by federal guidance. It also rolls back protections California spent more than a decade building. This brief examines what could change for enrollees and how the state can protect access and continuity of care.
At a Glance
- Scale: 1.9 million enrollees, including 251,000 children under age 21, will move to FFS. They will will have to seek care from approximately 373,000 FFS providers primarily concentrated in urban centers (Figure 1).
- Continuity at Risk: 58.7% of UIS enrollees in active treatment see providers who are not enrolled in FFS.
- Fewer Protections: FFS lacks network adequacy standards and the quality oversight that governs managed care.
- Rising Uninsurance: The uninsured rate for this population is projected to climb from 25% in 2024 to over 50% by 2030.
Figure 1. Medi-Cal FFS Providers by California County
What Could Change
Enrollees will need to find providers who accept Medi-Cal directly. Those providers are concentrated in urban areas, and low payment rates make some unwilling to take new patients. Enhanced Care Management and Community Supports will no longer be available. The highest-need enrollees may lose their care managers. The state expects emergency and inpatient care to rise 16%, adding pressure on safety-net providers like community health centers.
Opportunities to Protect Enrollees
DHCS has released transition guides and a provider search tool, and it plans multilingual outreach to enrollees. Gaps remain. Before and after the transition, the state could:
- Develop detailed transition plans for enrollees with complex needs, such as dialysis or organ transplant.
- Finalize an FFS care management pathway and billing codes before January 1, 2027.
- Honor existing prior authorizations for a defined period after the transition.
- Fund interpretation for FFS providers and publish a dashboard tracking how enrollees access care.
The full issue brief is available for download below.
