AB 348 directs every California county to establish and administer a full-service partnership (FSP) program delivering integrated behavioral health, substance use disorder treatment, and supportive services tied to housing interventions. The law specifies a menu of high‑intensity models and practices—such as Assertive Community Treatment, Individual Placement and Support, and high‑fidelity wraparound—and requires programs to be trauma‑informed, whole‑person, and partnered with family or natural supports.
The bill creates presumptive eligibility for certain adults with serious mental illness (for example, people experiencing unsheltered homelessness, those leaving long stays in locked institutions or prison, or those with repeated 5150 detentions) and ties payments for FSP services to funds allocated under the Behavioral Health Services Fund. It also gives the State Department of Health Care Services authority to set clinical standards, documentation rules, and criteria for exemptions and evidence practices—while making implementation contingent on available funds and operative on January 1, 2027.
At a Glance
What It Does
Requires counties to offer an integrated FSP program using specified evidence‑based and community‑defined models, provide field‑based initiation of SUD treatment (including medications for addiction treatment), and document service plans in client clinical records. The State Department of Health Care Services sets fidelity, enrollment, and documentation standards and can approve exemptions for smaller counties.
Who It Affects
County behavioral health departments and contracted providers who deliver ACT/FACT, IPS supported employment, high‑fidelity wraparound and related services; community‑based organizations providing supportive services and housing interventions; and adults, older adults, children and youth with serious mental illness who meet the bill’s priority criteria.
Why It Matters
It standardizes a high‑intensity service package across counties, creates a presumptive pathway into intensive supports for several high‑need populations, and aligns service planning documentation with Medi‑Cal—shifting operational, fidelity, and funding questions to county systems and the State Department of Health Care Services.
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What This Bill Actually Does
The statute requires each county to run a full‑service partnership program that bundles clinical treatment, substance use services, and nonclinical supports—explicitly tying those services to housing interventions. The list of required options includes Assertive Community Treatment and Forensic ACT fidelity models, the Individual Placement and Support model for employment, high‑fidelity wraparound for youth, and other models the state designates.
Counties under 200,000 population can seek an exemption; the State Department of Health Care Services will work with county associations to set the criteria and process for those requests.
Enrollment rules prioritize people with serious mental illness and create a set of triggers that confer presumptive eligibility—unsheltered homelessness, extended secured institutional stays, multiple 5150 detentions over five years, or release from prison/jail after six months or more. Presumptive eligibility still requires that the person meet additional criteria established by the statute and obtain a recommending assessment from a licensed behavioral health clinician; counties may decline enrollment if it would conflict with Medi‑Cal contracts, court orders, or exceed program capacity or funding.Operational requirements include a whole‑person, trauma‑informed approach with family or natural support engagement, ongoing engagement services to sustain treatment and housing, and the inclusion of community‑defined evidence practices to ensure culturally anchored interventions.
The bill directs that all services and supports delivered through FSPs be paid from the Behavioral Health Services Fund allocations specified elsewhere in statute, and it allows the State Department of Health Care Services to set documentation standards so clinical records can satisfy both FSP and Medi‑Cal requirements. Finally, the law only takes effect to the extent that Behavioral Health Services Fund dollars are available and becomes operative January 1, 2027.
The Five Things You Need to Know
Counties must include assertive field‑based initiation of substance use disorder treatment that can deliver medications for addiction treatment in FSPs.
A person with serious mental illness is presumptively eligible for FSP if they meet at least one trigger: unsheltered homelessness, a six‑month-plus secured institutional stay, five or more 5150 detentions in five years, or recent six‑month-plus incarceration.
Small counties (population under 200,000) may request an exemption from the model‑fidelity requirements; the State Department of Health Care Services must approve or deny those requests using criteria developed with county associations.
All services and supportive services provided through FSP enrollment must be paid from the Behavioral Health Services Fund allocations specified in statute; counties are not required to use other local funds for FSP obligations.
The statute allows the State Department of Health Care Services to adopt documentation standards so that a client’s FSP service planning record can satisfy Medi‑Cal documentation requirements.
Section-by-Section Breakdown
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Required FSP services menu
Lists the services each county’s FSP must include: mental health, supportive services, substance use disorder treatment, ACT/FACT fidelity models, IPS supported employment, high‑fidelity wraparound, outpatient behavioral health, ongoing engagement, and housing interventions under Section 5830. Practically, counties must configure programs that can provide both clinic‑based and field‑based services and offer evidence‑based options the state specifies.
Model fidelity and SUD field initiation
Specifies that certain evidence‑based models must be used at fidelity (e.g., ACT, IPS, wraparound) and requires assertive, field‑based starts for substance use disorder treatment, including medications for addiction treatment. Counties will need training, fidelity monitoring, and protocols to deliver MAT in non‑clinic settings and to maintain model integrity.
Service principles and community‑defined evidence practices
Mandates a whole‑person, trauma‑informed, age‑appropriate approach that actively involves families or natural supports and reduces barriers to access. The law also requires FSPs to employ community‑defined evidence practices—locally rooted interventions identified by communities—creating latitude for culturally specific services alongside state‑defined evidence‑based models.
Eligibility, presumptive enrollment, and clinical recommendation
Defines who counties must enroll: adults, older adults, children, and youth per Section 5892 priority criteria, and sets out presumptive eligibility triggers for people with serious mental illness. Enrollment of a presumptively eligible person still requires meeting criteria in subdivision (e) and a recommending assessment by a licensed behavioral health clinician, documented in the clinical record. Counties may decline enrollment when it conflicts with Medi‑Cal contracts, court orders, or capacity/funding limits.
Standard of care and step‑down rules
Requires counties to establish levels of care keyed to acuity and objective step‑down criteria for moving individuals into less intensive services. The State Department of Health Care Services, in consultation with stakeholders, will define those levels and step‑down triggers—meaning counties must build triage, monitoring, and step‑down workflows into program design.
Payment source
Directs that all behavioral health and supportive services for FSP clients be paid from allocations under Section 5892 (Behavioral Health Services Fund), subject to Section 5891. The provision ties program finances to a specified funding stream and limits counties from obligating other funds to meet FSP requirements.
Clinical records and documentation standards
Requires the client’s clinical record to describe all services identified during the service planning process and authorizes the State Department of Health Care Services to adopt documentation standards that align FSP planning records with Medi‑Cal requirements—permitting a single record to satisfy both programmatic and Medi‑Cal documentation when standards align.
Definitions, funding contingency, and operative date
Defines key terms such as community‑defined evidence practices and supportive services, clarifies that the section is implemented only if Behavioral Health Services Fund dollars are provided, and sets the statute’s operative date as January 1, 2027. Practically, counties cannot be compelled to use other funding sources for FSPs under this provision.
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Who Benefits
- Adults with serious mental illness who are unsheltered or exiting prolonged institutional care — the bill creates a presumptive pathway and required outreach‑oriented services that increase access to intensive supports.
- Individuals with co‑occurring substance use disorders — FSPs must offer assertive, field‑based initiation of SUD treatment and make medications for addiction treatment available in the community.
- Community‑based organizations and culturally specific providers — the mandate to use community‑defined evidence practices recognizes and funds interventions rooted in community practice and may channel program dollars to those organizations.
- Clients seeking employment — the required use of the Individual Placement and Support supported‑employment model embeds evidence‑based employment assistance into FSPs.
Who Bears the Cost
- County behavioral health departments — must stand up and staff FSPs, monitor fidelity, manage enrollment flows, and absorb administrative burdens, especially if Behavioral Health Services Fund allocations are delayed or insufficient.
- Contracted providers — face new fidelity and documentation expectations (ACT/FACT, IPS, wraparound), which will require training, supervision, and potential changes to billing and recordkeeping.
- State Department of Health Care Services — assumes significant program design, exemption review, standards‑setting, and oversight responsibilities, requiring administrative resources for technical assistance and rulemaking.
- Small counties that apply for exemptions — must prepare exemption requests and supporting documentation and may face program gaps if exemptions are denied or funding is inadequate.
Key Issues
The Core Tension
The central dilemma is between expanding an intensive, culturally responsive continuum of care for high‑need individuals and imposing substantial, potentially unfunded operational and fidelity requirements on counties; the law aims to standardize access while leaving funding, oversight, and many implementation details to state and county systems, which can produce unequal results depending on local capacity.
The bill centralizes a high‑intensity service package but leaves three practical questions unresolved. First, the statute conditions implementation on Behavioral Health Services Fund dollars without specifying minimum or transition funding for startup costs; counties will need to align hiring, training, and contracting timelines to uncertain appropriations.
Second, the tension between fidelity to nationally validated models (ACT, IPS, high‑fidelity wraparound) and the statute’s endorsement of community‑defined evidence practices creates a hybrid expectation: counties must satisfy model requirements while accommodating culturally specific approaches—raising questions about how the State will measure outcomes and fidelity across different modalities.
Third, the presumptive eligibility rules expand access to people with clear markers of high need, but the statute allows counties to decline enrollment when doing so would conflict with Medi‑Cal obligations, court orders, or capacity and funding limits. That carve‑out risks uneven access: counties with constrained capacity or complicated Medi‑Cal contracts could effectively deny the pathway the law intends to create.
Finally, operational elements—field‑based MAT, documentation alignment with Medi‑Cal, and step‑down criteria—will require coordinated policy guidance, new workflows, and likely additional workforce investment; absent clear timelines and resources from the State, the practical rollout may be staggered and uneven across jurisdictions.
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