By: Mario S. Turner

A Shift in Regulatory Focus

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.