AB 1366 directs the California Department of Health Care Services (DHCS) to recognize a defined set of pharmacist services as a Medi‑Cal benefit, establish a fee schedule, and set reimbursement rates — generally 85% of the physician fee schedule for pharmacist services, with full parity for services performed by "advanced practice pharmacists." The bill enumerates specific pharmacist activities (immunizations, naloxone, PrEP/PEP, contraception, tobacco cessation, travel meds, and certain medication therapy management tied to specialty drugs) and conditions implementation on obtaining federal approvals and available federal financial participation.
Why it matters: the bill would convert many pharmacist-delivered interventions into billable Medi‑Cal services, open a revenue stream for pharmacists and pharmacies, and require DHCS to pursue a state plan amendment to recognize pharmacists as reimbursable providers at federally qualified health centers (FQHCs). Implementation mechanics — enrollment requirements, utilization controls, and DHCS’s authority to implement via guidance rather than rulemaking — create practical and legal issues that providers and payers will need to resolve before billing can begin.
At a Glance
What It Does
Designates a list of pharmacist services as Medi‑Cal benefits (pending CMS approval), requires DHCS to set a fee schedule, and fixes reimbursement: 85% of the physician fee schedule for pharmacist services and 100% for advanced practice pharmacist services. It also tasks DHCS with seeking a state plan amendment to recognize pharmacists as providers at FQHCs.
Who It Affects
California‑licensed pharmacists, advanced practice pharmacists, retail and clinic pharmacies that bill Medi‑Cal, FQHCs that employ or contract with pharmacists, and Medi‑Cal program administrators and payers who must adapt billing and utilization controls.
Why It Matters
This is a structural change in how Medi‑Cal could pay for non‑physician, pharmacist‑delivered care — expanding access to preventive and urgent interventions while shifting costs and administrative responsibilities into DHCS, Medi‑Cal plans, and pharmacy providers.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
AB 1366 makes a defined set of pharmacist activities payable under Medi‑Cal, but only after DHCS obtains any federal approvals necessary to secure federal financial participation. The bill requires DHCS to create a fee schedule for the listed pharmacist services and sets reimbursement rates by reference to the existing Medi‑Cal physician fee schedule.
For most pharmacist services the bill sets reimbursement at 85% of the physician fee schedule; services performed by advanced practice pharmacists are paid at parity with physicians and expressly include medication therapy management (MTM) tied to specialty drugs.
The bill lists covered pharmacist services by reference to Business and Professions Code provisions: furnishing travel medications, naloxone, self‑administered hormonal contraception, initiating and administering immunizations, tobacco cessation counseling with nicotine replacement therapy, initiating and furnishing PrEP and PEP, and MTM for qualified specialty drugs. Covered services are subject to DHCS protocols and utilization controls, meaning DHCS retains discretion over limits, prior authorization, or other billing requirements.Pharmacists must enroll in Medi‑Cal as ordering, referring, and prescribing providers before submitting claims under this authority; that enrollment condition is a gatekeeper for reimbursement.
DHCS must also seek a state plan amendment to allow pharmacists to be reimbursed as providers at FQHCs. Finally, the bill authorizes DHCS to implement these changes through administrative communications (all‑county letters, plan letters, provider bulletins) without first completing formal rulemaking, while also signaling a regulatory adoption requirement and semiannual reporting language that appears to contain outdated date references in the bill text.
The Five Things You Need to Know
DHCS must establish a fee schedule for pharmacist services and reimburse most pharmacist‑performed services at 85% of the Medi‑Cal physician fee schedule.
Services performed by "advanced practice pharmacists" are reimbursed at 100% of the physician fee schedule, and the bill explicitly includes MTM tied to specialty drugs under that parity.
Covered services are specifically enumerated (travel meds, naloxone, self‑administered contraception, immunizations, tobacco cessation with nicotine replacement, PrEP, PEP, and MTM for qualified specialty drugs) and are subject to DHCS protocols and utilization controls.
A pharmacist must be enrolled as an ordering, referring, and prescribing provider in Medi‑Cal before submitting claims for reimbursement under this authority.
Implementation is conditional on obtaining required federal approvals and federal financial participation; DHCS must also seek a state plan amendment to recognize pharmacists as reimbursable providers at FQHCs and may use all‑county letters or similar guidance to implement prior to formal rulemaking.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Establishes pharmacist services as a Medi‑Cal benefit and fee schedule/rates
Subsection (a) declares pharmacist services a Medi‑Cal benefit, subject to federal approval, and directs DHCS to create a fee schedule. It sets a default reimbursement rate of 85% of the Medi‑Cal physician fee schedule for pharmacist services, while providing reimbursement parity (100%) for services performed by advanced practice pharmacists. For administrators and finance teams, this is the core rate-setting mechanism — the bill ties rates to an existing schedule rather than creating standalone fees.
Enumerates covered pharmacist services and subjects them to protocols
Subsection (b) lists the specific services that qualify for reimbursement by linking to Business and Professions Code authorizations (travel meds, naloxone, contraception, immunizations, tobacco cessation, PrEP/PEP, and MTM for specialty drugs). It also makes those services subject to department protocols and utilization controls, which gives DHCS broad discretion to define limits, documentation requirements, and prior authorization rules that will determine how often and under what conditions pharmacists can bill.
Enrollment prerequisite for billing
Subsection (c) requires pharmacists to be enrolled as ordering, referring, and prescribing providers in the Medi‑Cal program before rendering services billed under this section. That enrollment requirement creates a practical administrative barrier: pharmacies and pharmacists must complete provider enrollment and meet credentialing standards before generating claims.
Federal approval gating and FQHC recognition
Subsection (d) conditions implementation on obtaining federal approvals and available federal financial participation; the state cannot implement the benefit unless and until the Centers for Medicare & Medicaid Services (CMS) provides the necessary waivers or approvals. Subsection (e) separately requires DHCS to seek a state plan amendment recognizing pharmacists as reimbursable providers at federally qualified health centers, a distinct administrative process that affects how FQHCs bill for pharmacist services and how federal match applies.
Administrative implementation authority and regulatory timeline
The bill authorizes DHCS to implement, interpret, or make specific the provisions via all‑county letters, plan letters, provider bulletins, or similar instructions without formal rulemaking, although it also includes language directing adoption of regulations by a past July 1 date and semiannual reporting requirements. For implementers this creates two practical effects: DHCS can act quickly through guidance, but the text contains inconsistent/outdated date references that will need clarification before enforcement.
This bill is one of many.
Codify tracks hundreds of bills on Healthcare across all five countries.
Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Medi‑Cal beneficiaries who need low‑barrier preventive and urgent care (vaccinations, naloxone, PrEP/PEP, contraception): Expanded coverage lets beneficiaries access these services at pharmacies without a physician visit, improving access especially in underserved areas.
- Community and retail pharmacists and pharmacies: The bill creates a direct billing pathway and new revenue streams for pharmacists who provide the enumerated services, stabilizing business models that incorporate clinical care.
- Advanced practice pharmacists: By tying their services to the full physician fee schedule, the bill financially rewards additional training/certification and encourages advanced practice roles.
- Federally Qualified Health Centers (FQHCs) and their patients: If DHCS secures a state plan amendment, pharmacists working in or for FQHCs become recognized billable providers, potentially increasing clinic capacity and integrated care options.
Who Bears the Cost
- California DHCS and the state budget: If services are implemented without federal match, the state would bear increased Medi‑Cal expenditures; even with federal participation, DHCS must absorb administrative costs for enrollment, billing systems, and monitoring.
- Medi‑Cal managed care plans and payers: Plans will have to update contracts, provider networks, and utilization management approaches; depending on whether services are carved into managed care, plans could face higher utilization and payment obligations.
- Pharmacies and pharmacists (administrative burden): Providers must enroll as ordering/referring/prescribing providers, adapt to DHCS billing rules, comply with utilization controls, and potentially invest in documentation and IT changes before realizing reimbursement.
- Physician and outpatient clinics: Expanded pharmacist billing could shift revenue for services traditionally billed by physicians, creating competitive and coordination pressures (and potential contractual disputes with local providers).
Key Issues
The Core Tension
The bill's central dilemma is straightforward: expand access to timely, pharmacist‑delivered care by making such services billable under Medi‑Cal, while containing costs and maintaining program integrity. Rapid administrative implementation favors access and provider uptake but risks budget exposure, unclear provider qualifications, billing complexity, and insufficient public oversight; slower, more transparent rulemaking protects fiscal and legal certainty but delays patient access and revenue for pharmacists.
The bill is written as a conditional, administratively driven expansion of coverage, but the conditions and implementation paths raise practical and legal questions. First, implementation is explicitly dependent on CMS approvals and available federal financial participation; until DHCS secures those approvals and clarifies whether payments will receive federal match, no billing pathway exists.
Second, the bill ties rates to the physician fee schedule but splits reimbursement between 85% and full parity for "advanced practice pharmacists" without defining how a pharmacist achieves that classification or how MTM services are allocated between the two rates. That gap will require regulatory or policy guidance.
Third, the bill authorizes DHCS to implement via all‑county letters and provider bulletins rather than through the normal regulatory process, accelerating rollout but reducing public notice and formal comment — a choice that could prompt legal challenges or stakeholder pushback if substantive billing rules are set via guidance. Finally, the text contains inconsistent past dates for required regulations and reporting obligations (references to 2017 and 2021), which creates drafting uncertainty and will need cleanup to avoid confusion about deadlines and compliance expectations.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.