Many kinds of accounts and property allow for a beneficiary designation, sometimes called transfer-on-death (TOD) or payable-on-death (POD) designations, that allow the account to pass directly to a beneficiary on your death. Do you know if you have made any beneficiary designations on your accounts? Have you reviewed these lately to be sure they are still consistent with your wishes? Did you know that TOD, or POD designations, take precedence over your Will or living trust? Are you aware of what can go wrong if there are issues with your beneficiary designations?
If you answered “no” to any of these questions, it may be time to review your accounts, particularly your TOD and POD beneficiary designations, to be sure everything is complete, accurate, and up to date. An annual review is crucial to ensuring that your accounts and property go quickly and seamlessly to the right people.
Where to Find TOD, POD, and Beneficiary Designations Beneficiary, TOD, and POD designations in writing that specify who will receive the asset (e.g., accounts, property, death benefits, etc.) after the original owner dies. These designations allow you to pass assets directly to your beneficiaries and avoid probate. This results in faster distribution to your family and loved ones and can reduce costs relative to settling your estate. Some common assets with beneficiary designations include the following: ● retirement accounts—401(k)s, individual retirement accounts, and other retirement plans; ● investment accounts—Brokerage accounts, stocks, bonds, and mutual funds; ● bank accounts—Checking accounts, savings accounts, and certificates of deposit; ● life insurance policies— Including whole, term, and group; and ● real estate—TOD deeds or survivorship designations on title. For most, their homes and financial accounts are the primary source of wealth, making it all the more important that beneficiary designations for these assets reflect your current wishes.
What Can Go Wrong with an Omitted, Incomplete, Inaccurate, or Outdated Beneficiary Designation? According to financial advisors, beneficiary form errors are among the most common—and the costliest—estate planning mistakes that people make. These errors fall into a few main buckets: ● Failure to name a beneficiary. Many people simply forget to complete beneficiary designation forms or put them off indefinitely. This situation is especially common for inherited accounts. ● Outdated information. Major life events such as marriage, divorce, the birth of a child, or the death of a beneficiary generally mean that beneficiary designations need to be updated. ● Inaccurate or missing information. Mistakes in spelling, addresses, or other identifying information, or failure to provide complete information, can cause delays, confusion, or even disputes when processing beneficiary designations. ● Naming a minor as beneficiary. Technically, minors can be named as beneficiaries, but they cannot legally receive or manage money and property above a certain value. If they are named as beneficiaries, a court may need to appoint a guardian to oversee the funds for them until they reach the age of majority (18 years of age in some states and 21 in others). ● Overlooking complex circumstances. A beneficiary may be unable to manage their inheritance because of a disability, special needs, poor money habits, mental health issues, or substance use disorder. ● Not naming contingent beneficiaries. If the primary beneficiary dies before the account holder or cannot be located, and no contingent (backup) beneficiary has been named, it will be treated as if no beneficiary had been named. ● Lost or invalid forms. Unfortunately, financial institutions sometimes misplace beneficiary designation forms or fail to process them correctly. Also, if a financial institution or employer changes the plan’s service provider or administrator, the original beneficiary designation may no longer apply, meaning that a new beneficiary designation form needs to be completed under the new provider.
In addition to the unintended distribution of accounts, property, or death benefits and related disputes, an invalid, missing, or outdated beneficiary designation can result in the assets requiring probate administration, resulting in payout delays and increased costs:
Robert had a brokerage account but never designated a beneficiary. When he died, the account became part of his probate estate, resulting in a lengthy and expensive legal process that delayed the distribution of his money. Moreover, the costs of the probate reduced the final amount that went to his heirs, and even though Robert may have told family that he wanted the brokerage account to pass to a specific beneficiary, through the probate proceeding, the account was divided among several beneficiaries.
Calendar Your Estate Plan Review You should be reviewing your estate plan at least every few years or after any significant life event. But even if you have not formalized your estate plan (what?!?!), you should, at a minimum, review your account beneficiary designations and ask: ● Are these beneficiaries still the people you want to receive your accounts? ● Are the beneficiaries still living? ● Are they capable of managing the inheritance? Should they receive an outright distribution, or are safeguards needed? ● Is there more than one beneficiary named, and if so, how hard is it to divide the account or property, and what is the potential for conflict between/among the beneficiaries? ● Do the beneficiaries know that they are named? Do they know how to proceed after your passing?
As part of your review process, it is important that you have accurate information. Get the current confirmation directly from the financial institutions of what they have on record. Do not just rely on memory or copies of forms you originally filled out.
Even if everything looks good after a review, you may benefit from reviewing your plan with your attorney or financial advisor. They have seen it all and may be able to suggest options or alternatives that are better suited to your needs.
We are pleased to congratulate Jason Eldred on his promotion to senior counsel at Wilke Fleury LLP. Jason’s work in service of clients is outstanding. His thoughtfulness and hard work contribute so much to what makes our firm truly special. Jason’s clients include construction companies, real estate companies, and medical professionals. Jason’s practice focuses on business and healthcare litigation, employment counseling and litigation, and bankruptcy. Senior Counsel at Wilke Fleury have a minimum of six years experience delivering high-quality legal services, collaborating with partners on development and management of cases, and actively mentoring junior lawyers. Congratulations Jason!
Wilke Fleury LLP is pleased to announce that Neal Lutterman is the firm’s Managing Partner beginning January 1, 2026. Neal succeeds Steve Williamson, who held the role of Managing Partner from 2020 through 2025. Steve Williamson led the firm through several years of significant change, and the firm is immeasurably grateful for Steve and his leadership.
Neal joined Wilke Fleury in 2015 and has been a Partner since 2017. Neal is an incredibly valuable member of the firm’s partnership and litigation teams. He has a demonstrated history of leadership on the firm’s Management Committee for 4+ years. Neal’s practice focuses on litigated matters in the healthcare arena. For over 25 years, Neal has defended physicians, healthcare systems, hospitals, medical groups, and allied healthcare providers in professional and general liability matters. Neal regularly represents physicians and other healthcare clients in administrative proceedings relating to professional licensing and disciplinary matters. Neal also works closely with the firm’s corporate healthcare clients representing health plans, Medicare Advantage Plans, Risk Bearing Organizations (RBOs), and other entities in reimbursement and contract disputes.
Neal will work closely with the firm’s Management Committee to advance the firm’s focus on client development, strategic growth, and attorney excellence in the years to come. Neal Lutterman is excited about the firm’s future, committed to the “next generation” of talented Sacramento lawyers, and continues to establish Wilke Fleury as the preeminent law firm in Sacramento.
On October 11, 2025, Governor Gavin Newsom signed Assembly Bill 1415 (“AB 1415”) into law. The bill amends the California Health Care Quality and Affordability Act by establishing reporting and notice requirements for certain “noticing entities” engaged in healthcare-related transactions, including private equity groups, hedge funds, management services organizations (“MSOs”), and newly formed entities created for the purpose of transacting with health care entities.
Effective January 1, 2026, AB 1415 formally codifies the category of “noticing entities” and mandates that all entities falling within this definition provide the Office of Health Care Affordability (“OHCA”) with written notice at least 90 days prior to entering into any transaction constituting a “material change” to the entity’s structure or operations.
Who Must Report?
In addition to the existing reporting obligations applicable to “health care entities,” AB 1415 extends notice requirements to any “noticing entity,” which includes all of the following:
A private equity group or hedge fund.
A newly created business entity formed for the purpose of entering into agreements or transactions with a health care entity.
A MSO.
An entity that owns, operates, or controls a provider, regardless of whether the provider is actively operating, providing health care services, or holds a current, pending, or suspended license.
AB 1415 defines MSO as “an entity that provides management and administrative support services for a provider in support of the delivery of health care services, excluding the direct provision of health services,” which may include “provider rate negotiation, revenue cycle management, or both.” AB 1415 also introduces definitions to “hedge fund” and “private equity group.”
What is Reportable?
A “noticing entity” must provide written notice to OHCA prior to engaging in a transaction with any payer, provider, or fully integrated delivery system that involves either of the following:
The sale, transfer, lease, exchange, option, encumbrance, conveyance, or other disposition of a material amount of the assets of a health care entity or an MSO; or
The transfer of control, responsibility, or governance over a material amount of the assets or operations of a health care entity or an MSO.
Additionally, MSOs must provide OHCA notice of any agreement or transaction described above when between the MSO and “any other entity.” This means MSOs must provide notice even when the other party is not a “noticing entity.”
Additional Reporting Requirement for MSOs
AB 1415 adds Section 127501.5 that authorizes OHCS to collect information from MSOs: “The office shall, in a manner prescribed by the office, establish requirements for management services organizations to submit data and other information as necessary to carry out the functions of the office.”
When Must Reporting Occur?
Notice must be submitted to OHCA at least 90 days before the parties enter into any reportable agreement or transaction.
How Does AB 1415 Impact Your Friendly-PC or MSO?
For newly formed friendly-PC structures, or for investors seeking to invest in healthcare entities through such structures, AB 1415 will require pre-closing notice to OHCA whenever the formation, acquisition, or execution of a management services agreement constitutes a material change transaction under the statute.
Existing friendly-PC or MSO arrangements are not subject to retroactive reporting; however, any new material change (e.g., a sale, transfer of equity or governance rights, restructuring, refinancing, or recapitalization) will trigger the 90-day notice requirement. As a result, even routine ownership or organizational adjustments may face added regulatory steps and potential delays.
If you have further questions in anticipation of the January 1, 2026 effective date, please contact the healthcare team at Wilke Fleury.
1. A partridge in a pear tree. Female partridges are among a group of clever birds known to feign injury as a way to lure predators from their nest and protect their young. Think of yourestate plan as the human version of that instinct—a clever way to protect and reduce risk for your own loved ones.
Estate planning step: Schedule meetings with your financial advisor and estate planning attorney to discuss your priorities, values, and needs. Laying this groundwork ensures that every step that follows serves your core objectives. Be prepared to discuss family dynamics and special circumstances; pinpoint your legal objectives (e.g., minimizing estate taxes or avoiding probate); and determine which financial and estate planning strategies best meet your needs.
2. Two turtle doves. Turtle doves often serve as a symbol of devotion. A comprehensive estate plan that includes everyone you value in your life can demonstrate your own level of commitment to those closest to you.
Estate planning step: Before meeting with your advisor and attorney, gather your personal, financial, and family information, including names, birthdates, and contact information for your children, stepchildren, spouse, siblings, and other loved ones. Consider involving your spouse or your closest family members early in the process. Including them early helps ensure that everyone understands your intentions, avoids misunderstandings, and reduces the risk of surprises or conflict later.
3. Three French hens. In the famed Christmas carol, the three French hens are commonly associated with the virtues of faith, hope, and generosity. In seeking to safeguard your own nest egg for the next generation, consider what hopes you may have for their future as well as whom you would trust most to carry out your wishes.
Estate planning step: Take time to identify your beneficiaries and understand their individual needs—financial, emotional, or otherwise. Knowing what you want to support in each person’s life helps shape a plan that is both practical and meaningful. But do not stop there; think carefully about whom you trust to carry out your wishes, since the success of your plan depends on choosing the right people to fulfill your intentions when the time comes.
4. Four calling birds. Some historians assert that the song lyrics originally referenced “colly” birds,[1] an archaic term for blackbirds. Highly territorial, blackbirds stand ready to defend their home under any circumstances. Once you have a clear picture of what you wish to protect, you will also be able to secure all that you hold dear.
Estate planning step: Prepare an inventory of everything you own and owe, including a complete list of your assets (e.g., accounts and property), income information, and existing insurance policies, as well as your debts. Have this information organized and ready to share at your meetings with your advisor and attorney, ensuring you can effectively defend and protect your loved ones through your estate plan.
5. Five golden rings. According to some researchers, the gold rings from the “Twelve Days of Christmas” song do not signify jewelry but the name of yet another bird, the goldfinch.[2] A resilient and adaptable songbird species, the goldfinch reminds you to be prepared to weather any of life’s unpredictable events.
Estate planning step: Preparing for the unexpected means considering many possible scenarios. Your estate plan should be flexible enough to adapt as your life, family, and finances evolve. Before meeting with your advisor or attorney, review any recent life changes, such as births, deaths, marriages, or the acquisition of new assets, and consider how your goals may shift over time. This will enable your plan to be designed to grow and adapt with you.
6. Six geese a-laying. Some pinpoint the six geese in the song as representing creation and new life. Similarly, think of estate planning not as gloomy or morbid but as a forward-looking act of creating new opportunities and protections for those who come after you.
Estate planning step: An estate plan encompasses more than distributing your money and property after you have passed away. Creating a thoughtful plan that passes your wisdom and values on to your beneficiaries can prove just as meaningful. Think about what family histories, stories, or personal philosophies feel crucial to share with the next generation. You may consider including these in a legacy letter that accompanies your estate plan. Taking this step not only strengthens your legacy but also provides new opportunities and perspectives for the next generation to build upon.
7. Seven swans a-swimming. The number seven is often regarded as sacred in many religions and cultures. In Catholicism, it has often been tied to completeness or perfection. While no one is perfect, you can work with advisors and estate planning professionals to ensure that your estate plan is as complete and legally solid as possible.
Estate planning step: Finalizing and signing your estate planning documents is essential to ensure that they are legally valid and enforceable. Because requirements for witnesses, notarization, and execution vary by state, working with a qualified professional helps ensure that your documents meet all legal standards and reflect best practices in your jurisdiction.
8. Eight maids a-milking. The milkmaid in the lyrics has elicited a range of interpretations throughout history, including portrayals of diligence, humility, and dignity in everyday tasks. At first glance, estate planning may seem to be of interest only to those with significant wealth, but in reality, it is a process from which everyone can benefit, regardless of the size of their estate.
Estate planning step: Focus on your goals, not just your net worth. Like the milkmaid who found meaning in her everyday work, view your estate plan as a way to care for the people and values that matter most—both during your lifetime and after your death. A well-crafted plan can also guide and protect you during periods of incapacity (being unable to handle your own affairs), ensuring that your daily life and decisions continue to reflect your wishes.
9. Nine ladies dancing. Whether the nine ladies in the song symbolize angels or virtues such as love, joy, and patience remains uncertain. Either way, they serve as a reminder to take the necessary steps in the estate planning process. It may initially seem intimidating or hard to follow, but with guidance from your advisor and attorney, all components of your plan will ultimately align.
Estate planning step: Partner with a professional to master all the right estate planning moves. If you establish a trust-based estate plan, be sure to fund the trust, i.e., transfer assets into it, so it actually works as intended and avoids probate. Another smart move is to keep your beneficiary designations up-to-date, ensuring that your accounts align with the rest of your plan.
10. Ten lords a-leaping. The leaping lords remind us to lift others up and stay connected during the holidays. Joy grows when it is shared, especially with those who may need extra support or encouragement.
Estate planning step: Taking the lead involves helping those around you. In estate planning, communicate the key elements of your plan to all key partners involved in the process, including your fiduciaries and beneficiaries. Ensure that they are aware of the location of your documents, who is responsible for what, and what you expect from them. By involving your loved ones in the conversation, you provide them with clarity about your wishes and ensure that they are supported when life feels uncertain.
11. Eleven pipers piping. Estate planning can help maintain harmony among your loved ones. You are the composer, and your financial accounts, property, and personal possessions are all instruments that play a role in your plan. A well-structured estate plan that accurately reflects your intentions can facilitate a smooth transfer of assets to your beneficiaries.
Estate planning step: Once you have completed your carefully curated “playlist” of estate planning documents, store your plan securely (both physically and digitally), and maintain a summary or index that helps your loved ones quickly find what they need.
12. Twelve drummers drumming. Getting into a consistent rhythm as the seasons of your life shift means less stress and more time for celebration and enjoyment.
Estate planning step: Set a regular review schedule—annually or after major life events such as marriage, birth, or a move—to keep your plan current with your life and the law.
The Greatest Gift You Can Give
Knowing where something came from, whether a song, a family tradition, or a personal value, deepens its meaning. The same principle applies to your estate plan.
To create a plan that truly reflects who you are and what you care about, your advisor and attorney need to understand your history, relationships, and goals. It may take longer than 12 days to create your plan once we have all the necessary information, but you will have a gift far more valuable and lasting than anything found under the tree.
This holiday season, as you reflect on the year and spend time with loved ones, you can take real steps toward securing your family’s future—one meeting, one conversation, and one thoughtful gift at a time. Please call us to schedule a time to create or review your existing estate plan.
The Department of Managed Health Care (DMHC) held its quarterly roundtable on September 3, 2025. Mental health and behavioral health were central topics, with significant focus on 988 crisis services and employee assistance programs (EAPs). While much of the discussion was directed at full-service health and behavioral health plans, DMHC emphasized that the lessons extend to all licensees. Dental plans, vision plans, and other specialized entities should pay close attention to these developments because the Department’s regulatory expectations now apply across the market.
Crisis Services and the 988 Hotline
A major theme was the handling of crisis response under the 988 hotline. DMHC explained that crisis services must be covered without prior authorization until an individual is stabilized. Once stabilization occurs, the provider must either obtain authorization or transfer the member to an in-network facility. This approach is designed to ensure that people in crisis receive timely help without administrative barriers. DMHC also clarified that counties are not permitted to bill commercial plans directly for mobile crisis services, except in cases of crisis stabilization. Earlier this year, the Department issued All Plan Letter 25-006 with billing codes, and it is now working with county Behavioral Health Directors to conduct training in all 58 counties. These efforts aim to ensure consistent billing and payment practices.
Broader Application to All Plans
Although these requirements are often associated with behavioral health, DMHC was clear that the same expectations apply to all licensees. Plans must have internal protocols that prevent improper billing, avoid disruptions in care, and provide smooth coordination for enrollees who need crisis services. The central message is that plans are expected to adopt practices that protect members in moments of crisis.
Clarifying the Role of EAPs
The Department also devoted attention to EAPs. These programs often serve as a first entry point for members in distress, yet they can create confusion about where coverage ends and where behavioral health benefits begin. DMHC has stated that plans must help enrollees transition from EAP sessions into ongoing behavioral health treatment when necessary. Member-facing materials must clearly explain coverage boundaries and referral pathways. Employers that provide EAPs should also confirm that employees understand what is included in these programs and what steps to take when additional care is needed.
Network Adequacy and Health Equity
In addition to these immediate issues, DMHC is advancing broader initiatives around network adequacy and health equity. New standards for provider ratios, geographic access, and block transfers have already been released and will soon be incorporated into regulation. At the same time, DMHC is developing health equity regulations that are scheduled to take effect on January 1, 2027. These regulations will require all plans to report disparities in access and outcomes and to demonstrate corrective action. Behavioral health is likely to remain a central focus, but the rules will extend across all benefit categories. For enrollees, these changes should improve wait times and expand provider options. For plans, they create new responsibilities to evaluate networks and implement equity reporting systems.
The Path Forward
The overall takeaway from the September roundtable is that DMHC intends to hold every plan to consistent and measurable standards. Whether a plan is medical, dental, vision, or another type of specialized licensee, the Department expects compliance, transparency, and accountability. Plans that begin aligning their protocols and communications now will not only stay ahead of regulatory deadlines but will also improve the enrollee experience. DMHC is treating behavioral health compliance as a model for how it will regulate the entire health plan market.
The Department’s message was clear: health plans should not wait for enforcement action before making changes. Those that review their crisis protocols, clarify the boundaries of EAP coverage, and begin preparing for health equity reporting will be better positioned to demonstrate compliance and build trust with their enrollees.
Wilke Fleury is extremely proud to have seven attorneys recognized in The Best Lawyers in America and eight attorneys recognized in the Best Lawyers: Ones to Watch in America! Best Lawyers has been regarded by lawyers and the public for more than 40 years as the most credible measure of legal integrity and distinction in the United States. Congratulations to this talented group!
California is a litigious landscape; it is one of the most heavily regulated and litigious states in the country. Businesses both small and large face a complex web of employment laws, consumer protection statutes, environmental regulations, and contractual obligations – most of which come with heavy-handed penalties for non-compliance. In this environment, the best defense is a robust offense. Businesses that invest internally in thoughtful structuring, clear internal protocols, and regular legal check-ins position themselves well to avoid litigation altogether or, at the very least, to withstand it. Facing litigation can be a reality in today’s world of catchy headlines of big-time judgments, so it is important to follow some time-tested rules to best arm your business if the day comes where it needs to defend itself.
First Rule of Litigation: Documentation – It will not be surprising to learn the best way to protect your business against what feels like inevitable litigation, is documentation. Whether it is your time clock entries, communications with vendors or clients, clear, written documentation that complies with California law creates a record that can make or break a defense. If you do have something like an employment handbook, do not rest on the laurels of that accomplishment. Have it reviewed regularly to be sure it reflects compliance with current legal standards. Doing so means you close common loopholes that billboard and bus stop plaintiff attorneys are familiar with exploiting.
Second Rule of Litigation: Have Legal Counsel Before You Need It – Successful businesses, or businesses that last, do not wait for a someone to file a lawsuit before looking for legal counsel. Once service of a complaint takes place, the clock on your time to respond starts; each day spent trying to find competent counsel ticks away precious days that should be spent analyzing and strategizing the best defense. Stalwart businesses foster an ongoing relationship with attorneys who understand their individualized business model, pressures facing their specific industry, and comfort level with risk tolerance. Consulting with counsel on an ongoing basis ensures day-to-day decision making runs as smoothly as possible and allows for candid conversations about liability exposure. Additionally, business owners with counsel already on board save themselves the apprehension if a lawsuit ever arises.
Third Rule of Litigation: Insurance Coverage – Make sure you have the insurance coverage you think you do before an employee, client, or party to a contract files suit. Too often, businesses under-insure or do not have coverage for conduct they think they do. Reviewing your commercial general liability policy, employment practices liability insurance, cyber insurance, and directors and officers coverage with your attorney or your insurance broker helps ensure your coverage is aligned with the actual risk profile of your business. For example, many contractors find out after the fact their policy does not cover claims of poor workmanship; once litigation is filed, it is too late to rectify that problem. Having proper insurance coverage to start with makes it easier to tender a defense quickly and get an insurance company to participate in the litigation on your behalf, when required to do so.
Taking proactive steps to protect your business from litigation in California is not just smart – it is essential. By maintaining documentation, engaging legal counsel before disputes arrive, and ensuring your insurance coverage aligns with your risk profile, you can significantly reduce exposure and respond more effectively if a claim is made. A little preparation today can save your business time, money, and stress down the road.
Wilke Fleury is extremely proud that several of its incredible attorneys have been selected as 2025 Northern California Super Lawyers or Rising Stars! Super Lawyers rates attorneys in each state using a patented selection process and publishes a yearly magazine issue that produces award-winning features on selected attorneys. Congratulations to this talented group:
Wilke Fleury exists to solve clients’ business needs. Committed to intellectual excellence and critical thinking, Wilke Fleury lawyers apply meaningful analysis to even the most complicated business needs. From entity formation, M&A, restructuring, agri-business, healthcare, real estate, labor & employment, litigation defense, and wealth management, Wilke Fleury is focused on solutions, strategy, responsiveness and fierce advocacy. Wilke Fleury is the firm for all businesses seeking thoughtful, skilled attorneys to advocate and guide.
On March 26, 2025, Mario Turner attended the California Association of Health Plans’ “Shaping the Future of Behavioral Health” event in Burbank, CA. The gathering brought together leaders from state agencies, provider organizations, and health plans to discuss challenges, innovations, and evolving expectations in California’s behavioral health care system.
Below are highlights from the event, along with key considerations for behavioral health and EAP organizations moving forward:
Continued Regulatory Emphasis on Access and Parity
Mary Watanabe, Director of the Department of Managed Health Care (DMHC), opened the day by reaffirming the Department’s focus on enforcing timely access standards and mental health parity laws. The DMHC continues to conduct oversight through network reviews, complaint monitoring, and formal investigations.
Key Consideration: Regular internal reviews of access metrics, network adequacy, and parity documentation can help organizations stay aligned with DMHC expectations and avoid future compliance issues and enforcement actions.
Evolving Access Models: From Appointment Availability to Outcomes
Representatives from Two Chairs emphasized that solving access challenges in behavioral health is not just about the number of appointments available. Instead, their model focuses on outcome measurement, provider-client fit, and long-term engagement as the foundation for effective care.
Key Consideration: Exploring ways to measure and improve therapeutic outcomes, such as client progress tracking, satisfaction surveys, or provider matching algorithms, may enhance client experience and retention.
Proposition 1 and California’s Behavioral Health Infrastructure Expansion
Passed in 2024, Proposition 1 sets the stage for sweeping changes to California’s behavioral health system, including investments in residential care, housing supports, and the behavioral health workforce.
Key Consideration: Organizations may benefit from keeping an eye on local Proposition 1 funding opportunities and exploring how new infrastructure could support expanded or integrated service offerings.
Integrating Social Determinants of Health Into Behavioral Health Models
Speakers from ZeOmega and Clearlink Partners discussed how integrating social determinants of health (SDOH), such as housing, transportation, food security, and education, can lead to more sustainable behavioral health outcomes. Their session emphasized the need to treat root causes, not just symptoms.
Key Consideration: Embedding SDOH screening and community resource referrals into behavioral health workflows may support more holistic, person-centered care and promote long-term recovery.
Strengthening Opioid Use Disorder (OUD) Response Strategies
Representatives from Millennium Health and Partnership Health Plan of California addressed the growing urgency of the opioid crisis, with panelists highlighting persistent gaps in access to medication-assisted treatment (MAT) and care continuity. Speakers emphasized the importance of provider education, reduced stigma, and seamless transitions between levels of care for individuals with opioid use disorder.
Key Consideration: Behavioral health organizations should evaluate access to MAT services within their networks, provide training around OUD best practices, and enhance outreach strategies to support early intervention and treatment adherence.
Aligning Behavioral Health with Housing Through Medi-Cal Initiatives
Recent Medi-Cal efforts such as BH-Connect and the Housing and Homelessness Incentive Program (HHIP) are providing new pathways to link housing supports with behavioral health services. These programs include rent assistance, care coordination, and flexible funding mechanisms for high-need populations.
Key Consideration: Understanding the structure and funding of these initiatives can help organizations identify partnership opportunities with counties, Medi-Cal managed care plans (MCP), and local housing entities.
Looking Ahead
The CAHP conference reaffirmed that behavioral health in California is moving toward a more integrated, equitable, and outcomes-focused future. For EAPs and behavioral health plans, now is a good time to evaluate how clinical programs, partnerships, and operations align with these evolving expectations.
This past weekend, the United States Department of Treasury announced that, with respect to the Corporate Transparency Act, it will no longer enforce penalties or fines against United States citizens or domestic reporting companies. Further clarification of the Corporate Transparency Act’s enforcement is expected before its new deadline for failure to file – March 21, 2025.
Background
Originally effective on January 1, 2024, the Corporate Transparency Act required all state registered entities to disclose information about the natural persons controlling the entity – their “beneficial owners.” Challenges to the law’s constitutionality sprung up over the course of the year, resulting in various enforcement injunctions – two of which were applicable nationwide. Between the several injunctions and appeals, the ultimate enforcement date was due to be delayed until at least March 21, 2025.
Current Status
In an unexpected announcement on March 2, 2025, the Treasury stated that its reporting obligations will no longer be enforced against United States citizens and domestic companies. In other words, reporting will be limited to foreign companies and foreign beneficial owners. The Treasury has yet to provide guidance clarifying the implications of this rule on multilayered entities and companies that have already submitted voluntary reports.
Wilke Fleury continues to monitor the changes to the Corporate Transparency Act.
Mario Turner joins Wilke Fleury, providing creative solutions to complex problems in healthcare and corporate law. Mario’s practice focuses on Knox-Keene Act licensed health care service plans and insurance regulatory matters. Additionally, Mario represents healthcare providers, including physicians, dentists, veterinarians, optometrists, pharmacists, FQHCs, MSOs, IPAs, and Employee Assistance Programs. Mario assists healthcare organizations with regulatory and compliance matters including licensing, contracting, policies, acquisitions, and litigation. Mario also counsels clients on issues pertaining to Medicaid, Medicare, HIPAA, and antitrust laws in health care. Outside practicing law, Mario is a passionate Sacramento Kings fan and enjoys spending time with family, friends, and his four dogs.
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