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OCA posts DSG3 draft and proposes new behavioral-health file and primary-care module
Summary
OCA published the DSG3 draft for public comment and proposed a new behavioral-health file, payment-allocation instructions, Medi-Cal managed-care reporting requirements, and a phased behavioral-health-in-primary-care module; staff seeks comments and plans final regulation submittal in spring 2026.
OCA staff presented the draft Data Submission Guide 3 (DSG3) and associated regulatory proposals for public comment. The DSG3 draft, posted Jan. 5, 2026, would guide submission of 2024–25 calendar-year data with registrations in May and full file submissions due Sept. 1, 2026. OCA asked for public comments by Jan. 30.
Notable proposed changes include a new behavioral health file, payment-allocation instructions, the requirement that Medi-Cal managed care plans submit all files directly (phased in over prior years), separate reporting of self-insured member months in the statewide file, and a request for submitters to provide copies of filed medical loss ratio (MLR) reports. The office plans a public comment period and a formal emergency rulemaking process with the Office of Administrative Law.
Margaret Abrant and Debbie Lindes described OCA's three-module approach to measuring behavioral health spending: claims-based spending (primary-diagnosis rule, plus screening/assessment claim lines), non-claims payments allocation (population health, integration payments, capitation formulas), and a separate behavioral-health-in-primary-care module to capture integrated care delivered by primary-care providers. Pharmacy spending for behavioral health will be identified via national drug codes (NDCs).
Staff noted Medi-Cal-specific tweaks, including methods to incorporate county specialty mental-health and substance-use-disorder spending and special rules for Medi‑Cal members under 21 (where diagnosis requirements differ). The office plans iterative HPD analyses to refine the primary-care module and to post crosswalks and datasets in 2026 and 2027.
Next steps: DSG3 comment window (through Jan. 30); OCA to refine regulations, submit to OAL in March with an April effective date, and require registration and data submissions per the DSG3 timetable.
