Pipeline to Treatment for Foster Youth 

Transforming service delivery models for our most vulnerable young people.

Special Needs Network is setting a new standard for supporting children with disabilities in foster care. Our pilot referral system for children from the LA County Foster Care Pediatric Hub promotes access to ABA therapy and other services.  

In partnership with experienced navigators and advocates, we are identifying foster care youth ages 0-12 who will benefit from high-quality behavior health treatment. Additionally, SNN is empowering foster parents with knowledge and skills through our Parent Advocacy Mentorship program (PAM).  

This program will serve as a model throughout the California to ensure all foster youth have access to vital developmental services. 


  • Medicaid is public health insurance for low-income families and individuals with disabilities. The federal government splits the cost with states and in exchange federal rules must be followed. 
  • Medi-Cal is California’s name for Medicaid. 
  • Eligible members meet the income and disability qualifications and are in good standing. Children with slightly higher incomes are included in Medi-Cal (CHIP). Foster Youth and former foster youth are automatically qualified and enrolled in Medi-cal, regardless of income or resources.
  • Medi-Cal must provide Preventative Services – to prevent future health problems – and also all medically necessary services for individuals under 21 through an expansive benefit called EPSDT (Early, Periodic Screening, Diagnostic, and Treatment).  Behavioral Health Treatment (BHT) is required under both these categories of service.
  • “BHT services include applied behavioral analysis (ABA) and a variety of other behavioral interventions that have been identified as evidence-based approaches that prevent or minimize the adverse effects of behaviors that interfere with learning and social interaction.” (APL 23-010) 
  • The Department of Healthcare Services (DHCS) is the Single State Agency administering Medi-Cal and ultimately responsible for ensuring all eligible Medi-Cal members receive services.
  • Medi-Cal members can be enrolled in two types of Medi-Cal health plans: Managed Care Plans (MCP/MCO) or Fee For Service (FFS) plans. FY are predominantly enrolled in FFS.
  • Medi-Cal must ensure BHT is accessible whether a member is enrolled in an MCO or FFS.
  • Under EPSDT (under age 21), medical necessity is established when BHT or ABA is recommended as medically necessary by a licensed physician, surgeon, or psychologist. 
  • “For the EPSDT population, state and federal law define a service as “Medically Necessary” if the service is necessary to correct or ameliorate defects and physical and/or mental illnesses and other conditions.” i.e., “sustain,” “support,” “maintain,” “prevent … from worsening,” “make more tolerable.” (APL 23-010) 
  • There can be no other limitations put on medical necessity such as diagnostic requirements or limitations on settings, such as school.
  • Unlike all other Medi-Cal services, in 2014, DHCS decided to provide the BHT/ABA benefit through the Department of Developmental Services (DDS) and the regional centers.

The Problem:

  • A decade after the California State Plan was amended to include BHT services, there is still no clear mechanism for Medi-Cal FFS members to access medically necessary BHT services covered under the EPSDT benefit. As a result, FFS members, including the majority of children in foster care, are not being able to access life altering BHT services.
  • In 2014 when implementing SPA 14-026, DHCS entered into a binding Interagency Agreement Memorandum of Understanding (IA MOU) with DDS to provide BHT services to FFS members. SNN’s analysis of the IA MOU identified a clear disconnect between the expectations set forth and their implementation due to the ambiguous use of the term “eligible” in the IA MOU. 
  • Currently, DDS is only providing BHT to a subset of FFS members who are eligible for regional center (RC) services, a separate eligibility process that has nothing to do with Medi-Cal eligibility and limits access to BHT for hundreds of thousands of members. 
  • As of July 2023, there were 5.75 million children ages 0-20 enrolled in California Medi-Cal Program, with 9.2% of total members enrolled in fee-for-service. We estimate more than 500,000 Medi-Cal FFS members being without access to BHT services. 
  • Moreover, even RC eligible FFS members are having trouble accessing BHT and are not receiving them per Medi-Cal timely access standards and sometimes not at all.


  • Provide appropriate access to behavioral health treatment (BHT) services to all Medi-Cal beneficiaries under the age of 21 when it has been determined medically necessary and as recommended by a licensed physician and surgeon or a licensed psychologist.
  • Ensure all EPSDT standards are met for FFS members accessing BHT services
    • statewideness: services must be available statewide 
    • comparability: services must be the same for all members (MCP/FFS)
    • medical necessity standards: services have been recommended as medically necessary by a licensed clinician
    • timely access standards: services are provided within 10 days of a request  
    • network adequacy: reasonable access to sufficient providers to meet the need within the required time frames
    • mental health parity standards: behavioral and mental services can’t have more restrictions or limitations than medical or surgical service



  • SNN received the Pipeline to Treatment for Foster Youth grant from DDS to provide BHT services, including ABA and other complementary services, to youth in the Foster Care System; and establish a referral system model for FY (the majority of whom are FFS members) statewide to access behavioral health services.  
  • In partnership with the Martin Luther King Pediatric Hub, neighboring our new Center of Autism and Developmental Disabilities (C.A.D.D.)  located at the Jacqueline Avant Children and Family Center, SNN is providing life-saving behavioral health services to dozens of foster youths who otherwise would be unable to access BHT.
  • SNN is also empowering foster parents and caregivers to become effective advocates and mentors within their communities.
  • DHCS has taken ownership of solving the BHT access issue and has committed to creating a mechanism to ensure FFS members, including FY, have appropriate and timely access to BHT. To this end, DHCS has established a partnership with SNN.
    • SNN is serving as the lead community-based organization galvanizing the concerns and challenges experienced by those involved in the foster care system seeking to access BHT services for children in their care such as foster parents, attorneys, Pediatric Hub staff, service providers, legislators, and advocates.

DHCS Commitments:

Short Term 

  • DHCS has committed to fixing the regional center delivery system through which FFS members to receive BHT. 
  • DHCS has established a team dedicated in the benefits division to identify and implement policy guidance necessary to achieve this objective.
    • SNN and DHCS’ Benefits Division are meeting monthly for accountability and progress monitoring. 
    • DHCS has arranged regular communications between its and DDS’ executive leadership to ensure a collaborative solution.
  • DHCS is seeking SNN’s proposed refinements/clarifications to DHCS’ existing IA MOU with DDS, as well as technical guidance on new policy guidelines.  
  • DHCS will develop and implement new accountability and oversight standards to ensure Medi-Cal FFS members are receiving adequate BHT services through RCs.
  • DHCS will develop new policy guidance to ensure access to appeals and the fair hearing process, as well as implementation, accountability, and monitoring procedures. 

Medium Term

  • DHCS will explore delivery mechanisms outside of DDS to identify the right long-term solution for BHT delivery to its FFS members, including BHT becoming a full Medi-Cal FFS benefit.

Additional Challenges – location of services:

  • Due to the unique needs of foster youths, caregivers sometimes require in-school services rather than in-home services, a required EPSDT option.
  • After months of overcoming bureaucratic barriers and challenges working with LAUSD, SNN has entered into an MOU with LAUSD to provide in-school services which we hope will commence in the Spring of 2024. 


Please direct any questions or concerns to: 
Ingrid Rivera-Guzman, Director of Policy and Advocacy
via email: irivera@snnla.org