AB 1670 amends California Medicaid (Medi‑Cal) coverage by expressly excluding a set of optional benefits from program coverage while preserving narrow exceptions and phased restorations. The exclusions include adult dental (with a detailed, limited restoration schedule), audiology and speech therapy, chiropractic, optometric/optician services, podiatry, and incontinence creams and washes, subject to federal approval and budgetary conditions.
The bill matters because it reshapes which routine and specialty services Medi‑Cal will cover, sets concrete—but conditional—timelines for restoring some services, and authorizes the Department of Health Care Services to implement changes via all‑county letters or provider bulletins rather than formal rulemaking. That combination of conditional restorations, utilization controls, and administrative implementation changes moves key coverage decisions into budget and federal‑approval processes, with direct consequences for providers, managed care plans, and beneficiaries.
At a Glance
What It Does
The bill lists specific optional Medi‑Cal benefits to be excluded from coverage, then specifies narrow restorations: limited adult dental services (detailed list), and conditional restorations of optometric/optician services, audiology/speech, podiatry, and incontinence supplies on stated effective dates or contingent on funding and federal approvals. It also authorizes administrative implementation without formal rulemaking.
Who It Affects
Directly affects Medi‑Cal beneficiaries (especially adults 21+), dentistry and optical providers, audiology/podiatry providers, managed care plans, and county administrators who run Medi‑Cal benefit operations. The Department of Health Care Services (DHCS) will carry implementation responsibility and federal budget teams will be involved for approvals.
Why It Matters
The measure shifts benefit availability through explicit exclusions coupled with conditional restorations, creating planning and cash‑flow implications for providers and the state budget. It tightens the role of federal approvals and state budget choices in determining access to routine oral, vision, and ancillary services for Medi‑Cal enrollees.
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What This Bill Actually Does
AB 1670 begins by declaring that, notwithstanding existing Medi‑Cal statutes, the state will exclude a short list of optional benefits from Medi‑Cal coverage. The exclusion list is explicit: adult dental (with complex carve‑outs and a later limited restoration), audiology and speech therapy, chiropractic care, optometric/optician services (including fabricating optical laboratories), podiatry, and incontinence creams and washes.
Those exclusions are the starting point; the bill then layers exceptions and phased restorations on top of them.
The bill creates a detailed exception for certain dental work. It preserves coverage when dental surgeons perform procedures that are properly treated as physician services, and it authorizes emergency dental procedures.
It also sets out a dated restoration pathway for a defined package of adult dental services—examinations, radiographs, prophylaxis/fluoride, certain restorations and crowns, anterior root canal therapy, and complete dentures—subject to utilization controls, federal approvals, and the statutory treatment of those services as a medical benefit under Section 14132.89.AB 1670 limits the impact of exclusions in two ways that materially affect beneficiaries: first, the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) population is untouched by the exclusions; and second, beneficiaries receiving long‑term care in specified licensed nursing facilities continue to receive excluded services. The bill also ties implementation and any restoration to federal law and the availability of federal financial participation, and it explicitly allows DHCS to implement the changes through all‑county letters or provider bulletins instead of going through the California Administrative Procedure Act rulemaking process.Finally, the bill includes contingent restorations for optical services and a trio of previously excluded benefits.
Optometric and optician services are scheduled for restoration no sooner than January 1, 2020, but only if the Legislature funds those services in the budget and federal approvals are in place; audiology/speech, podiatry, and incontinence creams and washes are likewise set to be covered no sooner than January 1, 2020, subject to federal approval. Those conditional restorations mean coverage turns on two gatekeepers: state budget action and federal Medicaid authority.
The Five Things You Need to Know
The bill expressly excludes six optional Medi‑Cal benefit categories: adult dental, audiology and speech therapy, chiropractic, optometric/optician services (including fabricating optical labs), podiatric services, and incontinence creams and washes.
It delineates a narrowly defined package of adult dental services (exams, radiographs, prophylaxis/fluoride, certain restorations and crowns, anterior root canal therapy, and complete dentures) that may be restored as medical benefits subject to utilization controls and federal approvals.
EPSDT beneficiaries and residents of licensed skilled or intermediate care nursing facilities are exempt from the exclusions — their services are preserved.
DHCS may implement the exclusions and restorations via all‑county letters, provider bulletins, or similar instructions without undertaking formal rulemaking under California’s Administrative Procedure Act.
All restorations are explicitly contingent on federal law and federal financial participation; optometric/optician and several other restorations also require the Legislature to include funding in the state budget.
Section-by-Section Breakdown
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General exclusion authority
This subsection establishes the bill’s starting point: notwithstanding existing Medi‑Cal chapters, the department may exclude specified optional benefits to implement changes in funding levels. Practically, this gives statutory cover for removing benefits without having to amend every related provision; it’s the legal hook that allows the rest of the exclusions and conditional restorations to operate.
List of excluded optional benefits
This clause names the specific services excluded from Medi‑Cal: adult dental (with a later carve‑back), audiology/speech, chiropractic, optometry/optician services (including fabricating optical labs), podiatry, and incontinence creams/washes. For administrators and plans, this clause functions as the affirmative list of what is out of scope unless later restored by the bill’s other provisions or by separate legislative action.
Dental exceptions, limited adult dental restoration, and medical‑benefit treatment
This paragraph creates three distinct rules: it preserves coverage for medical or surgical dental services that are functionally physician services; it preserves emergency dental procedures; and it specifies a limited adult dental benefits package (with an effective date tied to federal approvals) for persons 21 and older. The paragraph further directs that those enumerated dental services be treated as covered medical benefits under Section 14132.89, which affects billing classifications and eligibility for federal matching funds.
Populations excluded from the exclusions (EPSDT and nursing facility residents)
Subdivision (c) carves out protections for two groups. First, EPSDT (children) keep full access to the excluded categories; second, beneficiaries in specified licensed skilled or intermediate care nursing facilities also retain excluded services. This preserves federal EPSDT entitlements and protects institutional long‑term care populations from coverage reductions.
Federal law and implementation constraints
These clauses bind the bill’s operation to federal law and the availability of federal financial participation, and authorize DHCS to use all‑county letters or provider bulletins for implementation without standard administrative rulemaking. The practical effect is a policy whose activation and federal cost‑sharing depend on CMS approvals while giving California an administrative shortcut to change coverage rules once approvals and funding exist.
Contingent restoration of optometric and optician services
Subdivision (g) sets a restoration earliest effective date of January 1, 2020 (or the following January 1 if the Legislature acts later), but conditions that restoration on both federal approvals and the Legislature appropriating funding in the state budget. The clause therefore converts coverage into a budgetary decision as much as a policy one, and signals DHCS to plan for re‑adding optical benefits only when funding is explicitly available.
Contingent restoration of audiology, podiatry, and incontinence supplies
Subdivision (h) directs that audiology/speech, podiatry, and incontinence creams/washes become covered benefits no sooner than January 1, 2020, subject to federal requirements. Like the optical restoration, this section makes coverage contingent rather than immediate and places reliance on federal approvals for Medicaid matching funds.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Adults eligible for the specified limited dental package (21+), if federal approvals are obtained — they gain coverage for a defined set of restorative and denture services that were otherwise excluded.
- EPSDT‑eligible children — the bill preserves their full dental, vision, and related services under federal Medicaid law.
- Long‑term care residents in licensed skilled or intermediate care facilities — they retain coverage for the excluded services while institutionalized, reducing disruption to facility care models.
Who Bears the Cost
- California’s General Fund and Medi‑Cal budget — restorations are contingent on state budgeting choices and will require appropriation if federal matching funds are to be accessed.
- Department of Health Care Services — DHCS must manage federal approval requests, construct utilization controls, and issue all‑county letters/provider bulletins to implement coverage changes without formal rulemaking.
- Managed care plans and providers — plans will need to update contracts, prior‑authorization and utilization‑management systems, and providers will face billing classification shifts (especially dental services treated as medical benefits) and possible delayed reimbursements while federal approvals and budget decisions play out.
Key Issues
The Core Tension
The central tension is between controlling state Medicaid costs by excluding optional benefits and preserving access to routine oral, vision, and ancillary care that prevent higher downstream costs and unmet clinical needs; the bill resolves this tension by making restorations conditional on federal approval and budget funding, which buys fiscal control at the cost of access certainty and implementation transparency.
The bill mixes exclusions with conditional restorations and multiple activation gates (federal approvals, federal financial participation, and legislative budget action). That structure creates practical uncertainty: beneficiaries, providers, and plans cannot predict when coverage will change because activation depends on separate processes (CMS approvals, budget bills) outside DHCS’s unilateral control.
Implementation via all‑county letters speeds administrative action once conditions are met but reduces the transparency and public notice typical of formal rulemaking.
The adult dental restoration is tightly specified and subject to utilization controls and medical‑benefit classification. That raises operational questions: how will DHCS define “medically necessary” for the listed dental procedures, which utilization controls will apply, and how will claims be processed under medical benefit billing codes rather than traditional dental codes?
There is also a systemic risk that excluding routine services will shift care into emergency departments or increase long‑term costs if untreated conditions worsen. Finally, the bill’s dated effective‑date language and layered contingencies create a risk of inconsistent coverage across counties or managed care contracts while approvals and appropriations are resolved.
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