County financial penalties for late IHSS reassessments

The California Department of Social Services (CDSS) has issued guidance regarding county penalties for late In Home Supportive Services (IHSS) reassessments.

IHSS has four subprograms which provide services to different populations:

  • IHSS-Residual (IHSS-R). Recipients do not meet PCS or IPO requirements and are usually people with Satisfactory Immigration Status, which denies them federal reimbursement.
  • Personal Care Services Program (PCSP). Recipients qualified for Medi–Cal on the basis of age, blindness or disability.
  • IHSS Plus Option (IPO). Recipients who have qualified for Medi–Cal and are also part of one of the following groups: parent provider for a minor child, spouse providers, advance pay cases or meal allowance cases.
  • Community First Choice Option (CFCO). Recipients qualified for Medi-Cal and would otherwise need a nursing home level of care.

For CFCO cases, counties must complete a reassessment every 12 months.

Beginning January 1, 2025, counties are liable for penalties for late reassessments in CFCO cases

Beginning July 1, 2026 counties will be liable for an additional penalty if the State of California loses federal Medicaid funds because of late reassessments in CFCO cases.

When a recipient moves to a new county, the county must initiate an inter-county transfer (ICT)  along with sending pertinent case documents to the new county. Counties must ensure that specific documentation is maintained and transferred during the ICT process. All records in  Case Management Information and Payrolling System (CMIPS) and documentation attached to those cases will be included in the ICT process. During the transfer period, the receiving county can complete the transfer within 30 calendar days and can be responsible for completing a face-to-face assessment with the recipient. Counties should ensure that when they are notified of a recipient’s move, they initiate the ICT timely and allow the new county at least 30 calendar days to process the case.

If the receiving county completes the ICT within 30 Calendar Days neither the transferring nor the receiving county will incur a CFCO penalty.  If the receiving county fails to complete the ICT in 30 Calendar Days, the receiving county will be responsible for the CFCO penalty. If the receiving county has less than 30 calendar days to complete the ICT, the transferring county may be held liable for the CFCO penalty, if incurred.  (ACL 25-84, November 20, 2025.)