CACAT
Policy Priorities
CACAT 2026 Policy Priorities
California’s addiction treatment system depends on clear rules, fair oversight, and reliable access to care. Yet providers and patients continue to face preventable regulatory and payer-related barriers that disrupt services, delay treatment, and create instability across the system.
CACAT’s 2026 Policy Priorities focus on practical, solution-driven reforms that improve treatment access, modernize licensing and certification processes, and ensure consistent, fair standards for ethical providers statewide. These priorities reflect real-world challenges reported by treatment programs and are designed to strengthen both consumer protections and the long-term stability of California’s recovery infrastructure.
CACAT Key Issues to Resolve in 2026
California’s addiction treatment system is facing preventable regulatory and payer-access barriers that disrupt care, weaken consumer protections, and strain providers working in good faith. In 2026, CACAT will prioritize the following key issues to improve treatment access, strengthen oversight, and ensure consistent, fair licensing and certification standards across the state.
1) Provisional Licensing Creates Barriers to In-Network Access
Problem:
When DHCS issues a new license number, the license is often designated as “provisional,” even when the program meets all requirements. This designation creates a major contracting barrier.
When DHCS issues a new license number, the license is often designated as “provisional,” even when the program meets all requirements. This designation creates a major contracting barrier.
Impact:
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Most private payers will not allow in-network (INN) contracting with a provisional license.
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Providers that were previously INN may be forced out-of-network (ONN), disrupting continuity of care.
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ONN billing environments can reduce payer oversight and may increase exposure to unscrupulous practices in the marketplace.
2026 Solution:
DHCS should ensure that when a new license number is issued, the program is treated as a recognized state license for DHCS, DMHC, and DOI purposes—without INN contracting penalties tied solely to “provisional” wording.
DHCS should ensure that when a new license number is issued, the program is treated as a recognized state license for DHCS, DMHC, and DOI purposes—without INN contracting penalties tied solely to “provisional” wording.
2) County-to-County Moves Should Not Trigger Provisional Status
Problem:
Programs relocating from one county to another may receive a new license number and automatically be placed into provisional status.
Programs relocating from one county to another may receive a new license number and automatically be placed into provisional status.
Impact:
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Programs lose in-network contracts through no fault of their own.
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Patients experience delays or loss of access to care.
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Programs may be unable to regain INN status due to closed networks, even after full compliance.
2026 Solution:
A county-to-county move should be treated as an administrative transition—not a reset—so compliant providers are not forced into provisional licensing or network disruption.
A county-to-county move should be treated as an administrative transition—not a reset—so compliant providers are not forced into provisional licensing or network disruption.
3) CHOW Rules Should Not Reset Licenses When Ownership Is Essentially Unchanged
Problem:
Change of Ownership (CHOW) rules can require a new license number—even when the same owners remain, but ownership percentages shift slightly (example: 49% / 51% changes to 51% / 49%).
Change of Ownership (CHOW) rules can require a new license number—even when the same owners remain, but ownership percentages shift slightly (example: 49% / 51% changes to 51% / 49%).
Impact:
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Programs can lose INN status and be forced ONN.
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Re-entry into INN networks is not guaranteed and may be impossible if networks are closed.
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This harms payer beneficiaries seeking services and destabilizes the treatment system.
2026 Solution:
DHCS should adopt a CHOW process that distinguishes between true ownership change and administrative percentage adjustments, preventing unnecessary license resets and disruption of payer contracting.
DHCS should adopt a CHOW process that distinguishes between true ownership change and administrative percentage adjustments, preventing unnecessary license resets and disruption of payer contracting.
4) DHCS Must Recognize ASAM Level of Care 3.7 (Residential Detox)
Problem:
With ASAM 4, Level of Care 3.7 is clearly defined as residential detox. DHCS not recognizing 3.7 contributes to widespread authorization denials—especially for detox services.
With ASAM 4, Level of Care 3.7 is clearly defined as residential detox. DHCS not recognizing 3.7 contributes to widespread authorization denials—especially for detox services.
Impact:
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Increased denials for medically necessary detox
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Delayed stabilization and higher clinical risk
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Reduced ability to place patients at the appropriate level of care
2026 Solution:
DHCS should formally recognize and align policies with ASAM 3.7 to reduce inappropriate denials and protect access to risk-driven detox services.
DHCS should formally recognize and align policies with ASAM 3.7 to reduce inappropriate denials and protect access to risk-driven detox services.
5) Certification Standards Must Fully Align With Title 9 Personal Rights
Problem:
The February 2025 certification standards improved consistency by incorporating Title 9 Personal Rights into certification requirements. However, one key right did not carry over:
The February 2025 certification standards improved consistency by incorporating Title 9 Personal Rights into certification requirements. However, one key right did not carry over:
The right to attend religious services/activities of choice and receive visits from a spiritual advisor (voluntary participation).
Impact:
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Creates inconsistency between licensing and certification standards
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Confuses providers and auditors
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Risks uneven enforcement and reduced client protections
2026 Solution:
Restore the missing Title 9 Personal Right into certification standards to ensure full alignment, consistency, and protection of client rights.
Restore the missing Title 9 Personal Right into certification standards to ensure full alignment, consistency, and protection of client rights.
6) DHCS Must Improve Application Submission Reliability
Problem:
Emailed applications sent to [email protected] are sometimes reported as “received,” then later missing or not found.
Emailed applications sent to [email protected] are sometimes reported as “received,” then later missing or not found.
Impact:
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Licensing/certification delays
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Increased administrative burden
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Smaller programs are disproportionately impacted due to limited staffing and follow-up capacity
2026 Solution:
Implement a modern submission process such as:
Implement a modern submission process such as:
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auto-generated confirmation receipts
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tracking numbers
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searchable submission logs
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portal-based uploads to prevent lost applications
7) Extension Portal Must Allow One Email to Manage Multiple Legal Entities
Problem:
The DHCS extension portal requires a different email address per legal entity, forcing owners with multiple licensed entities to maintain multiple logins.
The DHCS extension portal requires a different email address per legal entity, forcing owners with multiple licensed entities to maintain multiple logins.
Impact:
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Increased administrative burden
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Higher risk of missed deadlines
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Unnecessary complications for compliant providers operating multiple programs
2026 Solution:
Enable a single user account/email to manage multiple legal entities and licenses—standard functionality in modern compliance portals.
Enable a single user account/email to manage multiple legal entities and licenses—standard functionality in modern compliance portals.
CACAT’s 2026 Advocacy Commitment
CACAT will work collaboratively with DHCS, DMHC, DOI, payers, and legislative partners to modernize licensing systems, protect access to care, and ensure California’s addiction treatment infrastructure supports ethical providers and the communities they serve.