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Closed-Loop Referral (CLR) Implementation Companion

June 2025

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DHCS Closed- Loop Referrals require three actions for MCPs – tracking, supporting, and monitoring.

Tracking – MCPs are required to track a minimum set of data elements on each Member referral

Supporting – MCPs are required to support referrals, notifying Members and Referring Entities, and work with providers to troubleshoot challenges

Monitoring – MCPs are required to regularly monitor data to resolve challenges across Referring Entities, internal operations, and providers

https://www.dhcs.ca.gov/CalAIM/Documents/2-10-2024-CLR-All-Comer-Webinar.pdf

As presented by DHCS during a Feb. 13, 2025, CLR Webinar

DHCS (Medi-Cal) | Overview of CLR Requirements

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DHCS | What to Expect from CLR Requirements

Members

» Receive notice from their MCP when the service is authorized.

» Receive support from MCPs to identify other services or providers if re- referral is needed.

ECM & Community Supports Providers

» Submit 3 new data elements to MCPs via the Return Transmission File each month.

» Ex: Referral Status, Date of Referral Status Update, Reason for Referral Closure

Referring Entities

» Receive notices from MCPs when the service is authorized and referral is closed.

» If not authorized, MCPs include why.

» MCPs include referral closure reason.

https://www.dhcs.ca.gov/CalAIM/Documents/2-10-2024-CLR-All-Comer-Webinar.pdf

As presented by DHCS during a Feb. 13, 2025, CLR Webinar

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Update: On May 15, 2025, DHCS released an updated version of the Closed-Loop Referral Guidance and followed with an FAQ document.

The following slides summarize key components of the CLR Guidance and FAQs
Find the Closed-Loop Referral (CLR) Implementation Guidance May 2025 Update here
Find the DHCS May 30, 2025, CLR Frequently Asked Questions (FAQs) here

DHCS’s May 2025 FAQs focus on Tracking and Supporting
The May 2025 FAQs delay Monitoring by DHCS until July 2026. Therefore, the FAQs do not include a section on Monitoring

MCPs must implement CLR by July 1, 2025, applicable to ECM (all POFs) and Community Supports referrals (all except PoF Sobering Centers)

Intrepid Ascent | CLR Implementation Companion

Focus of this companion

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Will there be an extension?

DHCS expects MCPs to implement CLR by July 1, 2025
DHCS acknowledges that additional time may be needed to refine CLR operational and implementation requirements such as noticing and tracking methodologies, system updates, and workflows after the go-live date
DHCS will begin actively monitoring for compliance beginning July 1, 2026

DHCS will begin conducting compliance reviews of MCPs' CLRs one year after the implementation date of July 1, 2025

The following are questions and responses synthesized by Intrepid Ascent policy team. Italicized text is quoted text from the DHCS FAQs to assist ECM & Community Support providers.

Intrepid Ascent | FAQ Spotlights

Intrepid Insight:

Anticipate that MCPs will be looking for compliance, highly likely regarding timely submissions of a “Return Transmission File” (RTF), from contracted ECM & CS providers to start July 2025

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Do all referrals for ECM and Community Supports Populations of Focus (PoF) fall under the CLR Guidance?

Nearly all. Sobering Centers are excluded.
CLR requirements will apply to the Transitional Rent Community Support upon its launch as a Medi-Cal managed care covered service on July 1, 2025.

Why are Sobering Centers referrals not required under CLR?

CLR requirements will not apply to Sobering Centers because services are often delivered in real-time, the length of stay is under 24 hours, and services are typically authorized on a retroactive basis to facilitate timely access to this Community Support.

Intrepid Ascent | FAQ Spotlights

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Can an MCP require use of certain data sources, portals, third party software or systems, etc.?

Maybe – Intrepid recommends that contracted providers review their MCP contract, however, from the FAQ, the following may provide good insight

DHCS requires MCPs to build systems for collecting updates on CLR status on at least a monthly basis with Service Providers.

MCPs may use alternative data sources to supplement CLR tracking sources outlined in the guidance

MCPs cannot require ECM/Community Supports Providers to submit data for tracking via means other than the Return Transmission File (RTF)

Intrepid Ascent | FAQ Spotlights

Intrepid Insight:

This could be a portal or a third-party technology solution

Intrepid Insight:

ECM & CS providers must submit an RTF, at least monthly

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If the Referring Entity also renders the service, does CLR apply?

Yes. In the case that the Referral is placed for a Community Support and the Referring Entity is also the Service Provider, maintaining notification requirements for Referral Loop Closure provides an important data quality check for both MCPs and Providers

In the case of service request denials, under CLR does the MCP have to notify the Referring Entity in addition to the denial notification that MCPs are required to send under APL 21-011?

If the MCP denies the service authorization, then the authorization notice of the denial to the Referring Entity is sufficient. Therefore, in the case of CLR closure due to a denied authorization, a separate CLR closure notice is not required

Intrepid Ascent | FAQ Spotlights

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How is the MCP expected to proceed with noticing if the Referring Entity is a) the Member?; or b) The Member's guardian or caretaker?; or c) The Member's family, friend, or neighbor?

In the case that a Member, their guardian/caretaker, or a family member, friend, or neighbor places a referral and request for ECM/Community Supports authorization, MCPs will still provide notice of the authorization decision to the Member. No other noticing requirements apply.

Do Member noticing requirements apply when the authorization for ECM is denied due to the Member already enrolled in ECM?

Yes, all referrals to ECM and Community Supports are an authorization request and trigger APL 21-011 noticing requirements.

Intrepid Ascent | FAQ Spotlights

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How are MCPs going to track referrals that go directly to ECM providers who presumptively enroll Members?

MCPs may not have visibility into the origin of such referrals
The FAQ response says, “Please refer to Appendix B Section 1.A.3*. of the CLR Implementation Guidance for guidance on coding of referrals/authorization requests coming from ECM Providers to MCPs under presumptive authorization arrangements.

Intrepid Ascent | FAQ Spotlights

* Appendix B Section 1.A.3 (page 24 of the CLR Guidance May Update): “MCPs must track data elements on all referrals to ECM and Community Supports, including those generated using data by the MCP or generated by Members or families themselves”

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In the May FAQ under “CLR Noticing” and also in the DHCS Updated CLR Guidance May 2025, Exclusions:

Referral Loop Closure noticing requirements of Referring Entities do not apply in instances where the referral request is placed by the Member, their guardian/caretaker, or their family or friends
The CLR noticing requirements … do not apply to MCP-generated referrals (i.e., when ‘Referral Type’ is “Identified by the MCP”). However, as a best practice, DHCS encourages MCPs to inform Members they are eligible and have been referred for a service to increase the likelihood of Member engagement.

Intrepid Ascent | FAQ Spotlights

Intrepid Insights:

These DHCS exceptions fall under Supporting Member Referrals, not the CLR’s Tracking and Monitoring domains

Therefore, ECM/CS providers should expect to include Self Referrals and MCP-generated referrals in their RTFs

See next slide for excerpts from the DHCS CLR Guidance Document May 2025 update

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Data products used and MCP protocols to electronically collect and store data elements for CLR (page 25 of the 41 page CLR Guidance)

Generated by MCPs: Data generated or otherwise known by the MCP for Member referrals to ECM and Community Supports. This may include, for example, the authorization date for ECM or Community Supports referrals or data that the MCP shares with contracted Community Supports Providers via the Community Supports Authorization Status File.
Collected by MCPs via the ECM and Community Supports Provider RTF: Data reported by ECM and Community Supports Network Providers to the MCP via the RTF. These data offer updates on a referral’s status as the Network Provider outreaches the Member and attempts to initiate services.
Collected by MCPs in accordance with ECM Referral Standards: Effective January 1, 2025, data that MCPs are expected to collect from Referring Entities for Members being referred to an MCP for ECM. Similar information may also be collected by MCPs for Community Supports referrals.

Intrepid Ascent | FAQ Spotlights

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Intrepid Ascent | FAQ Spotlights

Intrepid Insights:

When reading guidance, whether from the state (aka DHCS, Medi-Cal), or the MCP(s), categorize such as:

This falls upon the MCP
This falls upon me as a Referring Provider
This falls upon me as a Referred-to Provider
This is something the Member will see directly (e.g. authorization denial)
Consider whether you already do this
Assess how implementing a new step should help your workflow and how you serve your clients
Identify barriers you might encounter in implementing and reach out to your MCP representative to collaboratively solve

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Take Aways for ECM & CS Providers on CLR

You have been doing referrals for a long time, keep doing them

Over the course of July 2025 and June 2026, expect that you should see be able to see whether a client for whom you made a referral received the service

Expect over the same course of time that the clients you serve will receive notifications that they did not previously receive – expect some individuals to embrace, others will not

Work with your partners to improve workflows, which should remove current-state duplicative administrative processes

Understand Medi-Cal’s goals, realize how important closing the referral loop is to a transformed ecosystem, and to quality of services provided

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