Full-Scope Expansions and The Medi-Cal Expansion Freeze

Full-Scope Expansions

California has enacted multiple laws to expand full-scope Medi-cal (MC) to eligible members regardless of immigration status which include:

State of California Senate Bill 75 (SB 75) enacted on May 1, 2016, grants full-scope MC for all children under age 19, who do not have satisfactory immigration status (SIS) or who are unable to verify satisfactory immigration status or citizenship.
On January 1, 2020, full-scope MC eligibility was expanded to include the young adult group aged 19-25 through SB 104 Young Adult Expansion.
On May 1, 2022, full-scope MC eligibility was expanded to include the 50 and older population through AB 133 Older Adult Expansion.
On January 1, 2024, full-scope MC eligibility was expanded to include adults ages 26-49 through SB 184 Age 26-49 Adult Expansion.

Individuals cannot opt out of full-scope MC benefits under SB 75 & SB 104, AB 133, and SB 184.

Reminder: If a child is potentially an Unaccompanied Refugee Minor (URM) who has not yet received the certification letter from the Office of Refugee Resettlement (ORR) the child should be evaluated for regular MC. Once granted the URM status the client should be forwarded to Foster Care (FC).

The Medi-Cal Expansion Freeze

Beginning January 1, 2026, the Medi-Cal Expansion Freeze will pause all new enrollments in full-scope coverage for adults age 19 and older who cannot provide proof of a satisfactory immigration status (SIS). Applicants to Medi-Cal in this category who apply on or after January 1, 2026, will be eligible for restricted-scope coverage if they meet all other eligibility criteria.

Medi-Cal members age 19 and older who do not have a SIS and were approved for full-scope coverage through one of the expansions prior to January 1, 2026, are eligible to continue on full-scope coverage unless they experience a loss of eligibility that exceeds three months following the discontinuance. This three-month grace period is referred to as the Expansion Grace Period and is specific to any member over age 19, without SIS, who was approved for full-scope prior to January 1, 2026. The Expansion Grace Period policy allows for a member discontinued for any reason to reestablish eligibility and re-enroll into full-scope coverage if otherwise eligible. Once they exceed the Expansion Grace Period three-month timeframe, the individual will no longer be able to re-enroll into full-scope coverage and will be entitled only to restricted-scope coverage. Once a member transitions to restricted-scope Medi-Cal, they will not be able to re-enroll into full-scope unless they can provide proof of U.S. citizenship or a SIS. The Expansion Grace Period does not restore coverage back to the date of discontinuance, but if a new application is submitted within the three-month Expansion Grace Period and they are found eligible, they can re-enroll into full-scope coverage, beginning with the application month, even with a break in aid. If the individual was discontinued for a failure to provide at an annual Renewal (RE) or a Change in Circumstance (CIC) report and is eligible for a 90-day cure period, full-scope coverage must be restored back to the date of discontinuance if the necessary information is provided and they are found eligible.

Example:Example:The MC RE is due in February 2026 for an individual in the Expansion Freeze population. The auto-renewal process was unsuccessful, and an MC RE packet was sent but not returned. MC is discontinued 2/28/2026 due to non-compliance. In April 2026, the client contacts the county, provides the missing information, and is found eligible for MC. Because the client contacted the county within the three-month grace period and was discontinued for non-compliance, both the 90-day cure period and the three-month grace period policies apply. The worker should rescind the MC coverage back to the date of discontinuance.

ExampleExample:The MC RE is due in 8/2026 for a single individual in the Expansion Freeze population. On 3/3/2026, the client reports an increase in income that exceeds the MAGI MC limit and is discontinued effective 3/31/2026. In June 2026, the client loses their job and submits a new application for MC. All necessary verifications are provided, and the client is found eligible for MAGI MC. Since the individual was not discontinued for non-compliance, the 90-day cure period does not apply. Since the application was submitted within the three-month grace period, and the client was found eligible, they are entitled to maintain the full-scope level of coverage with a begin date of June 1, 2026.

Note: Members enrolled in full-scope Medi-Cal under one of the prior expansions who are entering a Consumer Protection Program (CPP), such as the 365-day postpartum period or Transitional Medi-Cal (TMC), are not subject to the Expansion Freeze for the duration of the CPP. If they experience a loss of eligibility following the end of the CPP, they will be eligible to re-enroll during the Expansion Grace Period, if otherwise eligible.

Age-Out Policy

There is no age-out policy for members who were approved for full-scope prior to January 1, 2026. If an individual ages out of their aid type (turning age 19 or 65) after January 1, 2026, they will continue on full-scope coverage if they retain their coverage and are otherwise eligible.

Retroactive Medi-cal

Retroactive Medi-Cal coverage is available to individuals affected by the Expansion Freeze, if otherwise eligible, for any months prior to January 2026. Individuals who reapply during the three-month grace period may request retroactive coverage for any month in which they experienced a gap in coverage.

Full-Scope Expansions and The Medi-Cal Expansion Freeze