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.

Exception: CCHIP is limited to U.S. citizens and LPR children. Refer to Children's Health Care Initiative.

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

DRA and SIS verification requirements are federal regulations that still apply. If any SB 75, SB 104, AB 133, or SB 184 impacted individual is unable to provide DRA or SIS verification, he or she will remain eligible for full-scope MC under these state-funded programs. The DHCS will track clients who have failed to provide DRA/SIS documents with the citizenship indicator on the Medi-Cal Eligibility Data System (MEDS).

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 would 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.

The exceptions to the Expansion Freeze policy for certain immigration categories are detailed in Non-citizens Eligible for Full-Scope MC Benefits.

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 eligiblity 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 for any months prior to January 2026.

Managed Care/Fee-For-Service

Individuals receiving full-scope MC are subject to Managed Care requirements and will receive the Health Care Options Choice Packet; new enrollees can select the Managed Care plan by calling or returning the packet. If no plan is selected, DHCS will assign one.

After July 1, 2026, Individuals receiving Medi-Cal with no dental coverage will be able to retain their chosen Managed Care Plan (MCP).

Any individual receiving restricted-scope coverage is not eligible for Managed Care enrollment.

Note: Fee-for-Service (FFS) refers to the way providers are paid by the state. Clients with FFS MC are responsible for asking the provider if they will accept payment from MC before services are received. Not all providers accept FFS MC.

Full-Scope Expansions and The Medi-Cal Expansion Freeze