SB27 (CARE Court Program) directs the California Department of Health Care Services to produce an annual CARE Act report that compiles participant-level administrative data from county behavioral health agencies, courts, and other state and local entities. The department must set data measures and formats, publish guidance, and post the report online.
The statute specifies the types of data to collect — from demographics and housing placements to medication adherence, psychiatric advance directives, criminal-justice contacts, and outcome measures — requires Judicial Council aggregation of court-submitted petition data, sets minimum and maximum follow-up windows for former-participant reporting, and requires deidentification consistent with federal privacy rules.
At a Glance
What It Does
SB27 requires DHCS to develop and publish an annual CARE Act report by compiling standardized, deidentified data from counties, trial courts (via the Judicial Council), and other identified entities. The department sets measures, formats, and reporting cadence in guidance and determines how long former-participant data are retained (12–36 months).
Who It Affects
County behavioral health departments, superior courts and the Judicial Council, DHCS, and state oversight bodies (for example, the California Interagency Council on Homelessness) must collect, aggregate, and analyze CARE-related administrative data. CARE Court participants and their supporters are the subjects of the dataset.
Why It Matters
The law creates a single, statewide data pipeline to evaluate CARE Court implementation and outcomes and to surface demographic disparities. That centralized evidence base will shape program adjustments, funding decisions, and equity interventions — but it also imposes new operational and privacy requirements on counties and courts.
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What This Bill Actually Does
SB27 turns administrative records about CARE Court — petitions, agreements, plans, services provided, and outcomes — into a formal evaluation and oversight product. The Department of Health Care Services (DHCS) must consult a broad set of stakeholders when designing the annual CARE Act report and must publish both the measures and the resulting report on its website.
The statute gives DHCS authority to specify data measures and formats through written guidance and requires counties and other identified state and local agencies to deliver data in the form and frequency DHCS prescribes.
The Judicial Council plays a distinct role for court-derived metrics: trial courts submit petition-level data to the Judicial Council, which aggregates court metrics and forwards them to DHCS on an annual schedule DHCS develops with the Council. Required court metrics include counts of petitions filed, initial appearances, total hearings, CARE plans ordered, CARE agreements approved, petition dismissals, and timing information from filing to disposition.SB27 enumerates extensive data elements to be compiled, including participant demographics (age, race, ethnicity, disability, housing and Medi‑Cal status, immigration and veteran status, gender identity, languages spoken), services ordered and actually provided, housing placement types, treatment starts and terminations, substance use disorder treatment rates, Lanterman‑Petris‑Short Act detentions, criminal‑justice involvement, deaths and causes, outreach formats and outcomes, referral sources and timelines, medication adherence, psychiatric advance directives, graduation plans, and a set of outcome measures tied to housing, hospital and emergency department utilization, law‑enforcement encounters, involuntary treatment and conservatorship, and substance use.The statute requires DHCS to stratify outcome and process measures by the listed demographic variables where statistically relevant, to include a health-equity assessment that identifies disparities, and to present results to oversight bodies such as the California Interagency Council on Homelessness.
The law also mandates that any public release be deidentified consistent with 45 C.F.R. §164.514(a)–(b), and it specifies that counties are not responsible for reporting on participants who are privately insured or who no longer reside in California. SB27 further directs DHCS to set the minimum and maximum follow-up windows for reporting on former participants — at least 12 months and up to 36 months after engagement ends — and requires the inclusion of quantitative, deidentified operational information beginning in 2026.
The Five Things You Need to Know
DHCS must publish an annual, deidentified CARE Act report that compiles administrative data from counties, courts (via the Judicial Council), and other identified entities.
The statute requires counties to report participant- and service-level data to DHCS in the format, measures, and frequency DHCS prescribes through guidance issued under Section 5984(b).
“Former participant” data must be reported for at least 12 months and no more than 36 months after program completion, dismissal, or termination, and counties need not report on people who are privately insured or who have left California.
The Judicial Council collects court metrics (petitions filed, initial appearances, hearings, CARE plans and agreements, dismissals, and days-to-disposition) and aggregates them before submitting to DHCS on an annual schedule.
Public releases must be deidentified to meet HIPAA-like safe-harbor standards (45 C.F.R. §164.514(a)–(b)), while DHCS must stratify outcomes by multiple demographic fields to produce a health equity assessment.
Section-by-Section Breakdown
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DHCS reporting duty, stakeholder consultation, and definitions
This provision requires DHCS to develop the annual CARE Act report in consultation with county behavioral health agencies, disability rights groups, individuals with lived experience, families, counsel, racial justice experts, and other stakeholders, and to post the report online. It also defines key analytic populations: “active participants” (current elective clients or those with CARE plans/agreements) and “former participants” (graduates or those whose proceedings were dismissed or terminated), and clarifies counties need not report on privately insured individuals or those who no longer reside in California. For implementation this creates a gate for who appears in the dataset and signals the department must balance stakeholder input against operational feasibility.
Data specification and county reporting obligations
DHCS has exclusive authority to determine the data measures and specifications and must publish those via formal guidance (referencing Section 5984(b)). Counties and any other identified state and local entities must supply the required data in the format and frequency DHCS prescribes. In practice this centralizes data standards at the state level, but leaves counties responsible for extracting, transforming, and submitting local administrative records on that schedule and in that structure.
Court reporting and Judicial Council aggregation
DHCS must develop the court reporting schedule in consultation with the Judicial Council. Trial courts report petition-level metrics to the Judicial Council, which aggregates and forwards them to DHCS. The section lists the specific court metrics required (e.g., number of petitions filed, initial appearances, hearings, CARE plans and agreements, and dismissals). This design reduces DHCS’s direct burden of collecting raw court filings but creates a dependency on the Judicial Council’s aggregation processes and timelines.
Data elements, process measures, and outcome metrics
The statute enumerates extensive process measures and outcome measures: participant demographics, petitioner relationship, services ordered/provided/not provided, housing placements, treatment starts/terminations, SUD rates and treatment, LPS detentions, criminal‑justice involvement, deaths and causes, outreach modalities and outcomes, referrals, petition dispositions and timing, medication orders and adherence, psychiatric advance directives, graduation plans, and outcome indicators like housing stability, reductions in ED visits and hospitalizations, law‑enforcement encounters, conservatorships, and substance use. DHCS must stratify these measures by demographic variables where statistically relevant and include a health equity assessment to identify disparities and inform reduction efforts.
2026 quantitative reporting and county-level aggregation
Beginning in 2026 DHCS must include quantitative, deidentified operational data, aggregated by county, compiled from county behavioral health departments, courts, and the department. The statute lists the county-aggregated items required (contacts to county behavioral health, CARE petitions filed, petitioner types, dispositions, days-to-disposition, demographic fields, and referrals from conservatorship proceedings). This provision formalizes a county‑level dashboard approach that supports cross-county comparisons and trend analysis.
Privacy and deidentification requirements
Any publicly released information must not permit identification of participants or petitioners. The statute requires deidentification consistent with 45 C.F.R. §164.514(a)–(b). Operationally, DHCS must implement deidentification processes—likely involving suppression, aggregation thresholds, and data masking—and must reconcile the desire for stratified equity analyses with the need to prevent reidentification, particularly in sparsely populated counties or small demographic cells.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Care coordinators and county program planners — They gain standardized, statewide data to evaluate which services drive better housing and health outcomes and to plan capacity and workforce adjustments based on measurable trends.
- State oversight bodies and policymakers — The report supplies evidence for statewide oversight, funding decisions, and targeted equity interventions by showing trends across counties and demographic groups.
- Researchers and evaluators — Deidentified, standardized metrics enable independent evaluation of CARE Court effectiveness, longitudinal tracking of participants (within the 12–36 month window), and stratified equity analyses.
- People experiencing severe behavioral health conditions and their families — If used as intended, the evaluation and equity findings can drive interventions that reduce homelessness, unnecessary hospitalization, and criminal-justice encounters for specific demographic groups.
Who Bears the Cost
- County behavioral health departments — They must extract, clean, and submit comprehensive, often cross‑system data on a schedule and in a format set by DHCS, which will require staffing, IT, and possibly vendor support.
- Trial courts and the Judicial Council — Courts must collect and transmit petition-level metrics and the Judicial Council must aggregate and forward them, adding operational work and potential system upgrades.
- DHCS — The department bears the analytical load: developing measures, issuing guidance, aggregating multi-source data, conducting health equity assessments, and implementing deidentification, all of which require sustained resources.
- IT vendors and data contractors — Agencies may need new or modified information systems, interfaces, or analytics platforms to meet the specification and deidentification standards, creating procurement and contracting work.
Key Issues
The Core Tension
The central tension is between rigorous, stratified evaluation to drive equity-focused policy (which requires detailed, linkable participant-level data) and the twin obligations of protecting individual privacy and limiting administrative burden on counties and courts; stronger privacy protections and lighter reporting requirements both blunt the report’s utility for identifying disparities and program effectiveness.
SB27 creates a powerful statewide evidence base, but it also sets up several implementation and analytic tensions. First, the statute excludes privately insured people and those who have left California from county reporting, which will create systematic gaps in the dataset and may bias outcome measures, especially in counties with high private‑insurance penetration or seasonal/migrant populations.
Second, the requirement to deidentify data to meet 45 C.F.R. §164.514(a)–(b) standards will protect privacy but can erode the signal in small demographic cells and rural counties, limiting the utility of stratified equity analyses unless DHCS adopts careful suppression and disclosure-avoidance methods.
Operationally, the law centralizes data specifications at DHCS while placing the extraction and submission burden on counties and the Judicial Council for courts. That split creates dependencies (for example, on Judicial Council aggregation timelines) and risks uneven data quality across counties.
The statute requires a broad set of variables — from outreach formats to medication adherence and causes of death — many of which live in different local systems (electronic health records, county HMIS, law enforcement, coroners), raising questions about matching across systems, consistent definitions, and reliable linkage without unique statewide identifiers. Funding, staffing, and technical assistance will be essential but are not specified in this text.
Finally, the 12–36 month reporting window for former participants gives DHCS flexibility but also allows divergent local practices: a county that reports only 12 months of follow‑up will produce different longitudinal signals than one reporting 36 months, complicating statewide trend analysis unless DHCS standardizes the chosen interval and retrofitting of prior data.
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