Integrated Plans, Community Planning, Transparency Reports, and Timelines
In our previous post, we examined how California’s Behavioral Health Services Act (BHSA), enacted under Proposition 1, restructures and redefines the priorities of the former Mental Health Services Act (MHSA). Since then, the California Department of Health Care Services (DHCS) has released Version 1.2.0 of its BHSA County Policy Manual, providing counties with their first detailed guidance on strategic planning, stakeholder engagement, and accountability requirements under the new framework.
This post is the second in our BHSA transition series. In this post, we focus on key implementation updates, particularly the expanded scope and structure of community planning and reporting under BHSA. We provide a deeper dive into:
- The Integrated Plan (IP), including the Annual Update (AU);
- The Behavioral Health Outcomes, Accountability, and Transparency Report (BHOATR); and
- The Community Planning Process (CPP)
As always, EVALCORP remains committed to helping our county partners navigate this transition thoughtfully and strategically, ensuring alignment with state expectations while addressing local behavioral health needs. There are several key BHSA deadlines over the next four years, and we are here to support you at each step of the process.
1) The Integrated Plan: A New Framework for Strategic Behavioral Health Planning
The BHSA replaces the former MHSA Three-Year Program and Expenditure Plan with a more expansive, three-year Integrated Plan (IP). Unlike prior MHSA plans, which focused solely on MHSA-funded activities, the IP requires counties to develop a strategic plan that incorporates all behavioral health funding sources, including:
- BHSA funds
- Medi-Cal
- 1991 and 2011 Realignment funds
- Federal grants (e.g., Mental Health Block Grant, Providing Access and Transforming Health (PATH) Initiative)
- Opioid settlement funds
- Local and other state/federal funding streams
This integrated approach aims to ensure more coordinated, outcome-focused behavioral health service delivery across funding silos.
Required Reporting Elements of the Integrated Plan
The IP will include clearly defined sections that align with both county-level priorities and statewide behavioral health goals. According to DHCS, required reporting and strategic planning components include:
- County Demographics and Behavioral Health Needs: Description of the local population and prevalence data on mental illness and substance use disorders.
- Plan Goals and Objectives: County-specific goals designed to address behavioral health needs, aligned with statewide objectives.
- Community Planning Process (CPP): Summary of how stakeholder input was gathered and incorporated.
- Behavioral Health Care Continuum Capacity: Assessment of existing behavioral health services and strategies to address identified service gaps across levels of care.
- Services by Total Funding Source: Comprehensive financial mapping of how all funding sources will be allocated across service areas.
- Behavioral Health Services Fund Programs: Description of planned programs supported by BHSA funds.
- Workforce Strategy: Plan to recruit, train, and retain a strong behavioral health workforce.
- Budget and Prudent Reserve: A detailed financial plan, including reserve strategies to ensure continuity of care during periods of revenue fluctuation.
- Comment Period and Public Hearing: A 30-day public comment period is mandatory before submission, followed by a hearing conducted by the local behavioral health board.
You can find a draft of the DHCS-provided IP template here. Updated April 2025.
Annual Update (AU) to the Integrated Plan
The Annual Updates (AU) to the IP enable counties to adapt to local changes throughout the plan period. Unlike MHSA, a CPP is not required for the IP AU, though it is encouraged. The IP AU is also forward-looking, serving as a planning document for the upcoming fiscal year, while retrospective reporting is now handled through the BHOATR.
New Statewide Alignment & Performance Measures
Another key difference from the MHSA three-year plan is that the IP must align with statewide behavioral health goals set by DHCS. Counties are required to use local and statewide data to track trends and collect and report on specific performance measures related to these goals. They must submit annual and intermittent updates with measurable performance outcomes through the BHOATR.
DHCS identifies 14 statewide behavioral health goals aimed at improving well-being and reducing adverse outcomes. The County Performance Workbook outlines the primary and supplemental measures for all 14 of these goals. It compiles publicly available data, organized by county, to support performance assessment at the local level. This resource is designed to assist counties in evaluating their progress on key behavioral health indicators and utilizing those insights to inform BHSA planning for the IP.
2) New Annual Reporting: Behavioral Health Outcomes, Accountability, and Transparency Report (BHOATR)
The BHOATR introduces a new level of transparency and accountability. This annual report will require counties to track:
- Spending across all behavioral health funding sources
- Service utilization by population
- Outcome data, disaggregated by demographic and equity categories
- Progress toward statewide behavioral health goals
- Workforce trends and strategies
The draft BHOATR for FY 2026–2027 is due January 30, 2028, followed by a final version in January 2029. The report template and technical assistance resources are forthcoming from DHCS.
3) Expanded Community Planning Process (CPP)
Counties must engage with local stakeholders to develop each element of their IP. One of the most significant shifts under BHSA is the enhanced Community Planning Process (CPP), which now calls for more inclusive, equitable, and data-informed engagement practices.
What’s New?
- Broader Stakeholder Requirements: Counties must now engage Medi-Cal Managed Care Plans (MCPs), public health, law enforcement, education, and area agencies on aging. Counties must seek the participation of individuals representing diverse viewpoints, including LGBTQ+, youth from historically marginalized communities, racial/ethnic minorities, persons with disabilities, and organizations specializing in working with underserved communities.
- More Accessible Engagement Methods: Listening sessions, online surveys, town halls, virtual meetings, and social media outreach are now expected to be utilized.
- Equity and Accessibility: Counties must offer translation, transportation assistance, and participation stipends.
- Required Alignment: Stakeholder input must align with Community Health Improvement Plans (CHIPs) and Managed Care Community Health Assessments (CHAs).
- Dedicated Funding: Up to 5% of annual BHSA funds may be used to support stakeholder engagement, planning staff, virtual tools, and training.
- Integration of Statewide Goals: Statewide behavioral health goals and associated population-level behavioral health measures must be incorporated into the BHSA planning process and should inform resource allocation.
- Feedback Reports: With a 30-day public comment period now mandatory for the IP before final submission, counties must provide an annual public report summarizing how stakeholder input was incorporated into the plan, progress toward reducing behavioral health disparities, and changes made based on public feedback.
Stakeholder engagement requirements for the IP take effect on January 1, 2025.
Still to Come: Clarifications and Technical Guidance
While the draft of the DHCS County Policy Manual provides much-needed structure, counties still await:
- Final templates for the Integrated Plan and BHOATR
- Clarification on performance measures and how statewide goals will be operationalized
- Additional DHCS training and technical assistance resources (an initial training session was completed on June 4, 2025)
EVALCORP’s Role in Supporting Counties
Our BHSA Compliance and Integration Workgroup is actively tracking these developments and providing hands-on support to counties across California. From community engagement strategy development to data system design and outcome reporting, EVALCORP is ready to support you through every stage of the transition.
Stay tuned for additional resources and templates as DHCS releases further guidance.