Update from the DMHC

Published on February 7, 2026 in DMHC UPDATES

FOR PROVIDERS WITH UNASSIGNED CASES AGED 24-47 MONTHS

CRITICAL CHANGE EFFECTIVE: JULY 1, 2026

DMHC FILING DEADLINES CHANGING

ERN/NCRA met this past Friday with leadership from the California Department of Managed Health Care (DMHC) to discuss multiple regulatory and system changes that will affect providers throughout the State of California.

Topics included post-stabilization requirements, prior authorization practices, shortened payment timeframes effective in 2026, additional system changes and new legislation impacting provider reimbursement and appeals.

Due to ERN/NCRA’s volume filing history and 25-year tenure advocating for medically appropriate healthcare through administrative law, ERN was selected, alongside organizations such as the California Medical Association, California Hospital Association, and 2 others, to receive and share this information prior to public release.

At this time, we are announcing that the DMHC is reducing the provider complaint filing timeframe from four years (48 months) from the date of service to 30 months from the date of service, effective July 1, 2026.

IDENTIFY CASES AT RISK

Providers should begin updating internal workflows to account for the reduced timeframe to assign cases to representation and regulatory escalation.

As part of that review, providers are encouraged to:

Identify all unassigned cases between 24-47 months from the date of service.
Evaluate which cases may warrant regulatory filing or escalation.
Take steps now to preserve regulatory appeal rights before the new deadline applies.

For providers who currently assign cases to ERN-TRAF, eligible cases may be submitted to ERN for review and handling.

ERN will also meet individually with each provider via Teams or Zoom to review existing processes, help establish workflows aligned with the new requirements, and discuss how this change may impact our ability to represent you effectively before the California Department of Managed Health Care.

PREPARING FOR THE NEW TIMEFRAME

For providers who do not have dedicated internal or external resources specializing in administrative law, regulatory escalation, and DMHC processes, we encourage you to seek guidance as you prepare for this change.

The shortened filing timelines have the potential to materially impact revenue health if workflows, escalation strategies, and assignment practices are not properly aligned with the new requirements.

Following our meetings with our existing provider members, ERN will be hosting a webinar in partnership with outside counsel from King & Spalding, focused on the upcoming DMHC changes. The session will cover practical process considerations, common risk areas, and how providers can preserve regulatory and appeal options under the new rules.

The webinar will be free, purely educational, and open to all providers, intended to support providers as they assess readiness and plan next steps in advance of implementation by the California Department of Managed Health Care.