California Medicaid HCBS Waivers: The 7 Medi-Cal Pathways

There is no single Medicaid California HCBS waiver. California Medi-Cal delivers home- and community-based services (HCBS) through several distinct programs rather than one waiver, each with its own authority, lead agency, and access rules.1 Families seeking community-based long-term care almost always confront more than one of these structures at the same time, so the first job is figuring out which door fits.

This guide walks through the seven pathways that matter most to older adults and their families: the Home and Community-Based Alternatives (HCBA) waiver, the Assisted Living Waiver (ALW), the Multipurpose Senior Services Program (MSSP), the Self-Determination Program / HCBS-DD waivers, Community-Based Adult Services (CBAS), In-Home Supportive Services (IHSS), and the Program of All-Inclusive Care for the Elderly (PACE). These are not the state's only §1915(c) waivers: DHCS also runs a Section 1915(c) HCBS AIDS Medi-Cal Waiver Program, among others.1 The guide also covers the cross-cutting eligibility rules, the spousal-impoverishment protections California extends to HCBS, and the AB 116 asset limits, which are dated and step down sharply on July 1, 2027.

The 60-Second Version

What Are California Medicaid HCBS Waivers?

Home- and Community-Based Services (HCBS) is the federal Medicaid umbrella for long-term services and supports delivered outside of an institution, in your own home, a family member's home, an assisted-living facility, an adult day center, or a Regional Center–coordinated community living arrangement. Federal Medicaid law gives states multiple authorities to deliver HCBS, and California uses every major one to run several distinct programs rather than a single waiver.1

DHCS describes HCBA benefits as available "as long as they are medically necessary, cost-neutral, and he/she meets the nursing facility or acute hospital level of care," which captures the two structural features every §1915(c) waiver shares: an institutional level-of-care test and a cost-neutrality requirement.1 Federal rules also require person-centered planning and community-integration standards in HCBS settings; ask the program operating your waiver how those rules apply to the setting you are considering.

The Seven California Medicaid HCBS Waivers and Pathways at a Glance

Here is how the seven pathways compare on authority, lead agency, age, level of care, access, and geographic reach. Where a state source does not publish a criterion, the table says so rather than filling the gap.1

Income, Assets, and Cost-Share by Program

All non-managed-care HCBS waivers use non-MAGI Medi-Cal financial rules. The AB 116 asset test reinstated on January 1, 2026 sets the limit at $130,000 for one person plus $65,000 for each additional household member (so $195,000 for a couple), up to a maximum of 10 people.7 Those figures are dated. DHCS publishes them as applying "Through June 30, 2027," and says that "Starting July 1, 2027, the asset limit is: $21,000 for one person / $31,000 for two people / Add $1,550 for every extra person in your house (up to 10 people)."5 California also extends the federal spousal-impoverishment protections to home- and community-based services, including its §1915(c) waivers, through DHCS letters ACWDL 17-25 and ACWDL 18-19.4

HCBA: The Home and Community-Based Alternatives Waiver

HCBA is DHCS's §1915(c) waiver for people who would otherwise need care in a nursing facility or an acute hospital. DHCS states that recipients "must have full-scope Medi-Cal eligibility" and may receive waiver services "as long as they are medically necessary, cost-neutral, and he/she meets the nursing facility or acute hospital level of care."1

Authority and Lead Agency

The Home and Community-Based Alternatives (HCBA) Waiver was formerly the Nursing Facility/Acute Hospital (NF/AH) waiver.1 DHCS administers it directly and contracts with regional Care Management Agencies (CMAs) to operate the program. Check the current DHCS HCBA page for capacity, waitlist status, and the age range it serves before you plan around it; DHCS does not publish an age range or a slot count on the waiver page this guide relies on.

How big is the HCBA queue? DHCS's HCBA monthly dashboard for December 2025 reported 10,760 people enrolled and 6,091 on the waitlist, spread across nine waiver agencies (the largest, Libertana Home Health, showed 2,768 enrolled and 1,586 waitlisted).2 That is a point-in-time count from a dashboard DHCS republishes every month, so read it as a snapshot of the backlog rather than a fixed capacity, and pull the current month's dashboard before you plan around it.

Eligibility, Functional and Financial

Functional eligibility requires a nursing-facility or acute-hospital level of care.1 The Care Management Agency assesses which of those levels you meet, and DHCS also requires that the waiver plan be cost-neutral against the institutional care it replaces.1

Financial eligibility uses non-MAGI Medi-Cal rules. Recipients of HCBS waivers must have full-scope Medi-Cal eligibility.1 The income door is the Aged & Disabled Federal Poverty Level methodology; higher income qualifies through the Medically Needy / Share-of-Cost pathway (the Medically Needy maintenance need level is $600/month for one person, and income above it counts toward Share of Cost).7 The AB 116 asset test, reinstated January 1, 2026, is $130,000 for the applicant through June 30, 2027, dropping to $21,000 on July 1, 2027.7,5

For a married applicant with a community spouse, California applies spousal-impoverishment protections to HCBS through DHCS letters ACWDL 17-25 and ACWDL 18-19, which broadened the federal protections to "HCBS spouses with community spouses who may be residing in their own homes (not institutionalized)":4

• Asset limit for the applicant spouse: $130,000 through June 30, 2027.7,5
• Community Spouse Resource Allowance (CSRA): $162,660 for 2026. DHCS publishes a single California CSRA, not a range, and ACWDL 26-02 does not publish a California minimum.4
• Monthly Maintenance Needs Allowance: California's figure is $4,067 per month effective January 1, 2026, up from $3,948 in 2025. When the community spouse's gross income is measured against it, Medicare and other health-insurance premiums are deducted.4

That allowance is not limited to nursing-home cases: DHCS applies it when the spouse needing care is in a skilled nursing facility, is on the HCBS waitlist, or is actively participating in an HCBS program. In HCBS (community) cases there is no $35 personal needs allowance, which is an institutional rule. Together the two standards total $292,660 for the couple ($130,000 plus $162,660), versus $195,000 without them; ask your county worker to confirm how they apply the CSRA in your case.4,7

Transfers made before you apply still need a conversation with the county. DHCS's ACWDL 25-18 says the period of ineligibility it describes is the one "for nursing facility level-of-care" and "does not apply to Medi-Cal members enrolled in community-based Medi-Cal programs." That is a statement about whom the penalty reaches, not a statement that a waiver applicant's transfers go unexamined.1 See the transfer-penalty section below.

Care Management and Services

DHCS contracts with regional Care Management Agencies (CMAs) to run HCBA. The CMA takes the referral, conducts the in-home assessment, develops the Plan of Treatment (POT) (HCBA's person-centered service plan), and provides ongoing care management by an interdisciplinary team. Its service array is the broadest of any California HCBS waiver outside the developmental-disability programs: care management, skilled and private-duty nursing, Waiver Personal Care Services layered on top of IHSS, home-delivered meals, family training, durable medical equipment, home modifications, respite, transitional case management, and assistive technology. The waiver does not cover room and board, food, or services that duplicate State Plan Medi-Cal.

When DHCS releases slots, it fills some of them from Reserve Capacity categories ahead of the general queue. Ask the Care Management Agency which reserve categories are open and whether the person you are helping fits one, rather than assuming the general waitlist is the only route.

How to Apply (HCBA)

Start at the DHCS HCBA page, which lists the current contact information and the regional Care Management Agency for your county. If you do not yet have Medi-Cal, you can apply at the same time through the Medi-Cal Member Helpline at 1-800-541-5555 or online at BenefitsCal.com.8

A typical pathway: applicant or family contacts DHCS or the regional CMA, gets screened, has Medi-Cal eligibility verified (or applies for Medi-Cal at the same time), completes an in-home comprehensive assessment, has a Plan of Treatment developed, and is then approved or placed on the waitlist.

Common pitfall: Applicants without active Medi-Cal cannot enroll in HCBA. A simultaneous Medi-Cal application is often required. The CMA can assist with the Medi-Cal application but is not a Medi-Cal eligibility worker.

ALW: The Assisted Living Waiver

ALW pays for care in licensed assisted-living settings, but not room and board, and not in most of California.

Geographic Scope, 15 Counties

The Assisted Living Waiver operates only in 15 counties:1,9

Alameda · Contra Costa · Fresno · Kern · Los Angeles · Orange · Riverside · Sacramento · San Bernardino · San Diego · San Francisco · San Joaquin · San Mateo · Santa Clara · Sonoma

Older advocacy materials sometimes cite an 18-county roster; the current DHCS list is 15.

Eligibility (ALW)

To qualify, a person must be age 21 or older, have full-scope Medi-Cal with zero share of cost, and require a nursing-facility level of care.1,9 They must also be willing and able to reside in a participating Residential Care Facility for the Elderly (RCFE), Adult Residential Facility (ARF), or subsidized public housing. The same AB 116 asset limits apply here: $130,000 for an individual and $195,000 for a couple through June 30, 2027, then $21,000 and $31,000 from July 1, 2027.7,5 So do the spousal-impoverishment protections DHCS extends to §1915(c) HCBS waivers under ACWDL 17-25 and ACWDL 18-19.4

Enrollment and Waitlist

The ALW is not an entitlement: it operates with a capped number of slots and a waiting list, with priority for people transitioning out of nursing facilities, so waits can be long.9 The waiver runs under a federal authority approved for March 1, 2024 through February 28, 2029.9

The waitlist is now longer than the program. As of December 2025, DHCS reported ALW enrollment of 14,847 against a waitlist of 18,365, so more people were waiting for a slot than were using one. The gap widened through 2025: the waitlist grew from 8,285 in January to 18,365 in December while enrollment fell from 16,134 to 14,847. ALW has been waitlisted since it reached capacity in 2017, and DHCS releases slots to Care Coordination Agencies as they open, with priority for institutionalized individuals.2 These are point-in-time counts from a DHCS report updated monthly, not a standing figure, so check the latest ALW enrollment and waitlist report for where the queue stands today.

What ALW Covers, and What It Does NOT

Covered:

• Care coordination by a Care Coordination Agency (CCA).
• Personal care assistance (ADL/IADL support delivered by RCFE/ARF staff).
• Homemaker services.
• Home health aide services.
• Medication management/oversight.
• Skilled nursing oversight.

NOT covered, the resident pays:

• Room and board. This is the headline limitation of ALW. The waiver does not pay rent or food in the assisted-living setting.

ALW pays for care in a Residential Care Facility for the Elderly, Adult Residential Facility, or subsidized public housing, but not room and board, which the resident pays from their own funds.1 Residents typically use their SSI/SSP payment for it and keep a personal-needs allowance.9 In 2026 that room-and-board share runs roughly $1,400 to $1,500 a month, based on the SSI rate.9

This structure means ALW only fits residents at or near SSI/SSP income levels. A senior with substantial Social Security income generally cannot qualify: that income disqualifies them from SSI/SSP, and they cannot meet room and board on their own without depleting assets that would also disqualify them.

For higher-income seniors who want the assisted-living setting, the realistic options are CalAIM's Nursing Facility Transition/Diversion to Assisted Living Community Support (an MCP-delivered parallel pathway that doesn't require a §1915(c) slot, see the CalAIM section below) or private pay.

What Medi-Cal Pays the Facility

Under the ALW, Medi-Cal pays the participating facility for care and services on a tiered daily rate, about $95.69/day at Tier 1 up to about $270.80/day at Tier 5, per the DHCS rate sheet updated December 2025.9 The resident's own room-and-board payment is separate from these care rates.

How to Apply (ALW)

ALW is operated through certified Care Coordination Agencies (CCAs), which conduct the assessment, set the level of care, and build the Individualized Service Plan (ISP); the participating facility then develops a care plan to carry it out. Start at the DHCS ALW page, which has the CCA directory. The pathway is: contact a CCA in your service county, complete the assessment and ISP, enroll if a slot is available (or join the waitlist), and move into a participating facility.

MSSP: The Multipurpose Senior Services Program

MSSP is California's intensive-care-management waiver for seniors at nursing-facility level of care who want to stay in the community. Where HCBA serves hospital- and nursing-facility-level acuity and ALW serves the residential setting, MSSP serves the senior who mainly needs care coordination and warm handoffs to community supports.

MSSP Authority and Lead Agency

MSSP is a §1915(c) waiver delivered through local agencies under contract with the California Department of Aging: DHCS says "[t]here are currently 41 local agencies statewide under contract with the California Department of Aging."1 Those sites are typically community-based nonprofits, Area Agencies on Aging, or county aging departments, each serving a defined geographic catchment.

Eligibility (MSSP)

• Age: the two state agencies publish different numbers, and neither has withdrawn its version. DHCS's MSSP page says clients "must be 65 years of age or older," while the California Department of Aging, which administers the program, publishes "Persons 60 years of age or older" on its own MSSP page.1 If you are between 60 and 65, call the local MSSP site and ask them to screen you rather than ruling yourself out.
• Level of care: clients must "be currently eligible for Medi-Cal, and be certified or certifiable for placement in a nursing facility."1
• Medi-Cal: full-scope Medi-Cal eligibility, with the same income and asset rules as the other non-managed-care waivers, and the spousal-impoverishment protections DHCS extends to §1915(c) HCBS waivers under ACWDL 17-25 and ACWDL 18-19.4
• Residence: currently residing in the community, not a nursing facility. MSSP is built to prevent nursing-facility placement; for a transition out of one, HCBA, ALW, or CalAIM Community Supports are the primary tools.

The Intensive Care Management Model

The defining feature of MSSP is intensive care management. The team typically pairs a care manager (often master's- or bachelor's-level social work) with a public health nurse for clinical assessment and oversight. The team conducts the initial in-home comprehensive assessment, develops the Individualized Plan of Care (IPC) (MSSP's person-centered service plan), authorizes a budgetable mix of waiver services subject to per-participant cost limits, visits the participant in-home periodically, and reassesses at least annually and when the participant's condition changes.

MSSP's authorized services are narrower than HCBA's but well-suited to its mission: care coordination (the central benefit), adult day and social-day referrals, personal care (typically delivered by IHSS providers, since MSSP does not employ providers directly), homemaker services, respite, transportation, home-delivered meals, communication devices and personal emergency response systems, and minor home modifications.

Capacity, Sites, and How to Apply

MSSP is a §1915(c) waiver, so access depends on capacity rather than being open-ended, and each site operates within the capacity it is contracted for. Unlike HCBA and ALW, MSSP has no statewide slot count or waitlist figure published, so ask the site directly.

To find a local MSSP site:

• Web: the California Department of Aging MSSP directory, which has a county lookup.
• Local: through your Area Agency on Aging, which often refers directly.
• Medi-Cal questions: the Medi-Cal Member Helpline at 1-800-541-5555.8

HCBS-DD and the Self-Determination Program (SDP)

California serves people with developmental disabilities through the Department of Developmental Services (DDS), which "oversees the coordination and delivery of services for Californians with developmental disabilities through a statewide network of 21 community-based, non-profit agencies known as regional centers."1 The Self-Determination Program is one of California's §1915(c) HCBS waivers, alongside ALW, HCBA, and MSSP.5 These programs run in parallel to the elder-focused waivers, and access to them starts with the regional center rather than the county Medi-Cal office.

Regional Centers and the Lanterman Act

Regional center services rest on California's Lanterman Developmental Disabilities Services Act, and eligibility is determined by the regional center under criteria DDS sets, not by a Medi-Cal eligibility worker. Because those criteria and the intake process are administered locally, start by contacting the regional center for your area through dds.ca.gov and asking for an intake assessment.

Regional center eligibility and Medi-Cal eligibility are separate determinations, and a person can have one without the other. Ask your service coordinator how your Medi-Cal status affects which of your services are funded, and how the federal HCBS waiver match figures into your plan; that is the question families most often get wrong.

The HCBS-DD Waiver

The HCBS-DD waiver is administered by DDS for regional center consumers who meet the institutional level of care the waiver requires, which the regional center assesses. Its services span supported living and employment, day programs and behavioral services, respite, transportation, vehicle and home modification, communication aids, family training, community integration, and crisis intervention. The plan document is the Individual Program Plan (IPP), developed at least annually by the regional center service coordinator with the consumer and family. Confirm the current service array and level-of-care criteria with your regional center, since DDS updates them.

The Self-Determination Program (SDP)

The Self-Determination Program (SDP) is California's self-directed mode of HCBS for regional center consumers, run by DDS and operated as a §1915(c) waiver.5 It is opt-in: instead of the traditional service-broker model, the consumer (or their representative) receives an individualized budget, equivalent to what the services would have cost, and directs it. A person-centered plan drives the budget, a required Financial Management Services agency handles payroll and taxes, and an optional Independent Facilitator can help with planning and vendor selection. Within the budget, the consumer can hire credentialed vendors, qualified individuals, and in some cases family members. Ask your regional center how each of those pieces works before you opt in.

SDP Orientation

Before transitioning to SDP, a consumer must complete an SDP orientation. The State Council on Developmental Disabilities runs the orientation program, and Regional Center service coordinators check that it is completed at intake and transition gates. Because orientation requirements and providers are updated periodically, confirm the current process with your Regional Center and at the State Council's SDP orientation page before you start.

CBAS: Community-Based Adult Services

DHCS describes Community-Based Adult Services (CBAS) as "a Medi-Cal Managed Care benefit available to eligible Medi-Cal beneficiaries enrolled in Medi-Cal Managed Care," and says it "replaced Adult Day Health Care (ADHC) services."1 It was included in California's Section 1115(a) waiver, Medi-Cal 2020, and now runs under CalAIM, "effective December 29, 2021 through December 31, 2026."1

Eligibility (CBAS)

Because CBAS is a managed-care benefit rather than a §1915(c) waiver slot, eligibility runs through your health plan. A registered nurse at the CBAS center performs a face-to-face assessment using DHCS's CBAS Eligibility Determination Tool (CEDT), and the managed-care plan reviews it and authorizes the benefit.

The qualifying categories cover functional need at a nursing-facility level as well as several cognitive and behavioral-health conditions, and DHCS revises them periodically, so ask your plan or the DHCS CBAS page for the current criteria rather than assuming a diagnosis does or does not qualify. You must be enrolled in a Medi-Cal managed-care plan to receive CBAS at all.1

What CBAS Provides and How It Is Delivered

CBAS is delivered at a licensed CBAS center (the regulatory descendant of ADHC centers), where a participant attends part of the week and receives skilled nursing, therapies, social work, mental health services, personal care, therapeutic activities, meals, and transportation, all under an Individualized Plan of Care. It is a carved-in benefit under Medi-Cal Managed Care: the managed-care plan authorizes CBAS, contracts with centers, and receives the claims, so the participant must be enrolled in a plan.1 Because access is a plan authorization rather than a §1915(c) slot, the practical constraints are your plan's approval and the individual center's capacity; ask the center whether it is currently taking new participants.

How to Apply (CBAS)

PACE: Program of All-Inclusive Care for the Elderly

The Program of All-Inclusive Care for the Elderly (PACE) combines Medicare and Medi-Cal into a single integrated benefit delivered by one organization. CMS states that individuals can join PACE if they are "Age 55 or older," "Eligible for nursing home care," and "Able to live safely in the community at the time of enrollment."1

PACE traces back to On Lok Senior Health Services in San Francisco. It is capitated and integrated: one organization receives a per-member, per-month payment from Medicare and Medi-Cal and is responsible for providing or arranging the medically necessary care its team authorizes.

Eligibility (PACE)

To enroll in PACE, an applicant must:

1. Be age 55 or older.1
2. Reside in a PACE service area.
3. Be eligible for nursing home care.1
4. Be able to live safely in the community at the time of enrollment, with PACE supports.1
5. Receive their care through the PACE organization. Ask the program directly how enrolling would affect your current Medicare coverage or Medi-Cal managed-care plan before you sign an enrollment agreement.

Most PACE participants are full-benefit dual eligibles. Some pay privately, and some pay only the Medicare portion with private dollars while being Medi-Cal eligible.

How PACE Works and What It Covers

The defining feature of PACE is its Interdisciplinary Team (IDT), a care team that federal rules require, typically including the primary care physician, nurse, social worker, therapists, dietitian, and care and transportation staff. The team meets regularly to review every participant's care plan, and participants attend a PACE Center on a schedule the team sets, receiving primary and specialty care, therapies, meals, and social engagement there, plus home-based services as needed. The organization is responsible for the Medicare- and Medicaid-covered care its team authorizes, and a participant whose needs later rise to nursing-facility level generally stays enrolled. Ask the organization for its written description of what it covers before you enroll.

The 2026 PACE Application Pause

DHCS Policy Letter 25-02 announces "the pause to the PACE application process and related changes effective November 20, 2025, until November 19, 2027, at minimum or until otherwise notified through a superseding PL." DHCS says the pause is "to ensure appropriate resources to operate the PACE program as well as manage the current rate of growth of the PACE program."1

Read the end date precisely. November 19, 2027 is a minimum, not a scheduled end: the pause runs at least that long and continues until a superseding policy letter says otherwise.

What this means for families: PL 25-02 does not, on its face, say whether an already-operating PACE organization may keep enrolling new participants during the pause, so do not assume either answer.1 Call the organization serving your area and ask whether it is accepting new participants and whether your address is inside its approved service area. A senior in a county with no operating PACE organization should plan around other pathways while the pause holds.

How to Apply (PACE)

Find an organization in your service area through the CalPACE member roster. The organization screens for age (55+), nursing-facility level of care, and service area, confirms financial eligibility, and enrolls you effective the first of the month after the enrollment agreement is complete.

IHSS: California's State Plan HCBS Workhorse

In-Home Supportive Services (IHSS) is California's Medicaid State Plan Personal Care benefit, combined with §1915(j) Self-Directed Personal Assistance Services and the §1915(k) Community First Choice Option. California's Legislative Analyst's Office projects roughly 771,650 IHSS recipients in fiscal year 2025-26, making it by far the largest Medi-Cal HCBS pathway.3 IHSS permits paid spousal caregivers through its IHSS-Plus Option.3

For full IHSS coverage, provider hiring, hours allocation, EVV, FLSA overtime, county wage floors, the IRS Notice 2014-7 tax exclusion, and the 2026 changes, see our dedicated IHSS guide.

For HCBS-waiver readers, the key point is that IHSS is not a §1915(c) waiver, so there is no waiver slot to wait for. To qualify as of January 1, 2026 you must have full-scope Medi-Cal, be age 65 or older, or blind, or disabled, live in your own home (facility residents are ineligible), and have an assessed functional need documented by a county social worker's SOC 293 in-home assessment.3 Authorized hours are capped at 283 hours a month for the severely impaired and 195 hours otherwise, with supplemental Waiver Personal Care Services hours available to recipients also enrolled in certain HCBS waivers.3

IHSS + HCBS Waiver Coordination

IHSS and the §1915(c) waivers are often layered. HCBA's care management and skilled services sit on top of IHSS personal care, and Waiver Personal Care Services hours are available to recipients enrolled in certain HCBS waivers.3 MSSP and CBAS likewise provide coordination or daytime services while IHSS covers in-home personal care the rest of the time. The one exception is ALW: IHSS requires that the recipient live in their own home and makes facility residents ineligible, so a senior moving into an ALW facility transitions out of IHSS.3

Cross-Cutting Eligibility, The Rules That Touch Every Pathway

One Level-of-Care Standard, Many Assessment Tools

There is no single "California HCBS level-of-care form." Each pathway runs its own nursing-facility-level-of-care assessment, the CMA's comprehensive assessment for HCBA, the Care Coordination Agency's standardized tool for ALW, the site care manager's functional assessment for MSSP, the center RN's eligibility tool for CBAS, the Regional Center's diagnostic assessment for the developmental-disability programs, the county social worker's assessment for IHSS, and the PACE organization's assessment with DHCS certification.

Medi-Cal Eligibility Doors

To enroll in a §1915(c) waiver, the applicant must have full-scope Medi-Cal. Several doors lead there:

• Aged & Disabled Federal Poverty Level (A&D-FPL). The main income door for most HCBS waiver enrollees.
• Medically Needy / Share of Cost. For income above the A&D-FPL door: the applicant qualifies but pays a monthly Share of Cost. The Medically Needy maintenance need level is $600/month for one person, and income above it counts toward Share of Cost.7
• 250% Working Disabled Program. For working disabled adults; allows higher income with a small premium.
• MAGI-based eligibility. Generally for under-65 non-disabled adults.
• SSI-linked Medi-Cal. SSI recipients remain under SSI's $2,000 individual and $3,000 couple resource limits, which AB 116 did not change.7

Spousal Impoverishment, California's HCBS Extension

Federal §1924 spousal-impoverishment protections are mandatory for institutional Medi-Cal, and California extends them to home- and community-based services, including its §1915(c) HCBS waivers, through DHCS all-county letters. ACWDL 18-19 states that "federal law, through the ACA, broadened the application of those SI protections to HCBS spouses with community spouses who may be residing in their own homes (not institutionalized)" and that "ACWDL 17-25 added the SI provisions as an eligibility step for HCBS applicants and recipients."1

The authority is those DHCS letters, not W&I Code §14005.41. Section 14005.41 is the National School Lunch Program children's-enrollment section and has nothing to do with spousal impoverishment; if an advisor or an older guide points you there, they have the wrong statute.4

California's own 2026 figures (DHCS ACWDL 26-02):4

DHCS publishes a single CSRA and a single maintenance allowance for California. ACWDL 26-02 does not publish a California CSRA minimum or a California MMMNA floor, so do not plan around the federal $2,705 minimum as though it were what a California community spouse receives; California's figure is $4,067.4 When the community spouse's gross income is measured against that allowance, Medicare and other health-insurance premiums are deducted.4

These protections apply when the spouse needing care is in a skilled nursing facility, is on the HCBS waitlist, or is actively participating in an HCBS program, not only in institutional cases.4

Asset Reinstatement (AB 116, eff. 1/1/2026)

California had eliminated all non-MAGI Medi-Cal asset tests as of January 1, 2024. AB 116 (Chapter 21, Statutes of 2025) reinstated them effective January 1, 2026:7

• $130,000 for an individual, through June 30, 2027.7,5
• $195,000 for a couple, through June 30, 2027.7,5
• Plus $65,000 for each additional household member, up to a maximum of 10 people.7

The Pickle, Disabled Adult Child, and Disabled Widow/er programs stay exempt from the asset test, because their limits were removed under separate federal authority, and SSI-linked members remain under SSI's $2,000 and $3,000 limits.7

These limits expire, and the replacement is far lower. DHCS's Medi-Cal Changes page states that the $130,000 plus $65,000 structure holds "Through June 30, 2027," and that "Starting July 1, 2027, the asset limit is: $21,000 for one person / $31,000 for two people / Add $1,550 for every extra person in your house (up to 10 people)."5 Never plan a multi-year HCBS strategy on the $130,000 figure without that date attached: a household holding $120,000 today is inside the limit and roughly $99,000 over it on July 1, 2027.

These limits apply to HCBA, ALW, MSSP, HCBS-DD/SDP, and IHSS applicants. The interaction with spousal impoverishment is favorable while it lasts: the community spouse can hold $162,660 on top of the applicant spouse's $130,000, for a couple-level countable-resource total of $292,660 through June 30, 2027.4,7,5

The Transfer Look-Back and What It Actually Reaches

Read this one precisely, because a common shortcut version of it is wrong.

DHCS's ACWDL 25-18 says the look-back review happens "When applying for Medi-Cal or entering an LTC facility," that "[i]n California, the look-back period is 30 months," that the penalty period "is referred to as the period of ineligibility (POI) for nursing facility level-of-care," and that "[t]he POI does not apply to Medi-Cal members enrolled in community-based Medi-Cal programs."1

That last sentence tells you whom the nursing-facility-level-of-care penalty reaches. It is not a statement that an HCBS-waiver applicant's transfers are never examined, and it should not be read as one: the review is triggered by the Medi-Cal application that every §1915(c) waiver requires first. So ask your county eligibility worker what a specific transfer means for the specific program you are applying to, before you make it, and if an advisor says flatly that transfers "don't count" for HCBS, ask them to show you where DHCS says so.

California's look-back period is 30 months, shorter than the federal 36 months (or 60 months for disposals on or after February 8, 2006), and the maximum period of ineligibility is 30 months from the date of the transfer. Beginning July 1, 2026 the months reviewed increase by one each month until the full 30-month review applies to LTC applications and members entering LTC on or after July 1, 2028.4 Counties do not follow up when transfers fall under the Average Private Pay Rate or the person was within the asset limits on the transfer date, and January 2024 through December 2025 is not reviewed at all, because the asset test did not apply then.4,7

The penalty math, for a nursing-facility application: the divisor is the statewide Average Private Pay Rate, published annually with updated figures typically available at the end of January. At the 2026 APPR of $14,440 a month, a $200,000 transfer produces roughly 14 months of ineligibility ($200,000 ÷ $14,440).4 DHCS had not published the 2026 dollar figure in ACWDL 25-18 itself, so confirm the current APPR with your county before relying on that arithmetic.

Undocumented Adult Coverage and HCBS, A 2026 Wrinkle

As of January 1, 2026, some adults can no longer sign up for full-scope Medi-Cal because of their immigration status; DHCS heads this an "Enrollment Freeze." Adults who already have full-scope Medi-Cal keep it regardless of immigration status, so long as they renew on time and still meet Medi-Cal rules. The freeze does not reach everyone: children ages 0 to 18, pregnant people, and people under age 26 who were in foster care on their 18th birthday remain eligible for full-scope Medi-Cal regardless of immigration status.5

HCBS waiver implications: DHCS requires full-scope Medi-Cal for HCBS-waiver enrollment, so someone already holding full-scope coverage keeps the door open by renewing on time, while an adult newly caught by the freeze faces a barrier to it.1,5 This is an evolving area; confirm the current rules with DHCS and a benefits counselor before relying on them.

Person-Centered Service Planning

Federal rules require every HCBS enrollee to have a person-centered service plan developed through a participant-directed process. Because California delivers HCBS through several distinct programs, each pathway has its own plan document: the HCBA Plan of Treatment, the ALW Individualized Service Plan, the MSSP Individualized Plan of Care, the developmental-disability Individual Program Plan, the CBAS Plan of Care, the IHSS service plan, and the PACE care plan. Whatever it is called, ask that your plan be directed by you, written in plain language, and reviewed at least annually.

Waitlist Mechanics, Entitlement vs. Non-Entitlement

Whether you wait comes down to whether the pathway hands out §1915(c) waiver slots or authorizes a benefit. The §1915(c) waivers (HCBA, ALW, MSSP) run on capped slots; DHCS publishes waitlist counts for HCBA and ALW but none for MSSP; CBAS and IHSS need no waiver slot; and PACE access depends on the organizations operating in your area.1,2

For a senior with immediate need facing a long ALW or HCBA wait, the realistic options are:

• CBAS, through your managed-care plan, with no §1915(c) slot to wait for.
• IHSS, which needs a county assessment but no waiver slot.
• CalAIM Community Supports, Nursing Facility Transition/Diversion to Assisted Living, MCP-delivered with no §1915(c) slot.
• HCBA Reserve Capacity, if the Care Management Agency confirms the person fits an open reserve category.
• PACE, where an operating organization confirms it is enrolling.

Often the most realistic plan combines several of them.

CalAIM Levers, Community Supports and Beyond

California Advancing and Innovating Medi-Cal (CalAIM) is a §1115(a) demonstration plus a §1915(b) managed-care waiver, both effective through December 31, 2026, that runs alongside the §1915(c) waivers and houses adjacent HCBS-like services that don't require a waiver slot:6

• Community Supports: 14 pre-approved services (formerly In Lieu of Services) that managed-care plans may elect to offer in place of State Plan services, which means availability varies by plan and county.6 They include:
  • Nursing Facility Transition/Diversion to Assisted Living Facilities, an MCP-delivered parallel pathway to ALW that is useful as a bridge for waitlist applicants.
  • Housing Transition Navigation Services and Housing Tenancy and Sustaining Services.
  • Community Transition Services and medically supportive food.
• Short-term rental assistance, which DHCS has also called Transitional Rent, provides up to six months of rent or temporary housing. It is not a fifteenth Community Support: its authority and schedule come from the BH-CONNECT demonstration (effective January 1, 2025 through December 31, 2029). Under CMS's special terms, it becomes a mandatory managed-care service no sooner than January 1, 2026, and then only for individuals who meet the access criteria for Medi-Cal specialty mental health services, Drug Medi-Cal, or DMC-ODS; it stays optional for other populations until no sooner than January 1, 2027, when it becomes mandatory for all eligible populations.6
• Enhanced Care Management (ECM), a statewide Medi-Cal benefit for eligible members with complex needs, organized around defined Populations of Focus and delivered by a single Lead Care Manager.6

CalAIM 1115 renewal status: DHCS submitted its renewal application to CMS on May 11, 2026, seeking a five-year renewal that would run the demonstration through December 31, 2031.6

CCT Wind-Down, What Replaces Money Follows the Person

California Community Transitions (CCT) was the state's Money Follows the Person demonstration, and for years it was the workhorse for nursing-home-to-community transitions, providing transitional case management, environmental modifications, household setup assistance, and service coordination. It has been winding down. Confirm its current status and whether it is enrolling with DHCS before you count on it, because the timeline has shifted more than once.

Where those functions live now: CalAIM and HCBA carry most of them. Ask your managed-care plan which Community Supports it has elected to offer, since plans choose from the 14 pre-approved services rather than offering all of them:6

• CalAIM Community Supports, Nursing Facility Transition/Diversion to Assisted Living, MCP-delivered with no §1915(c) slot required.
• CalAIM Community Supports, Housing Transition Navigation and Housing Tenancy/Sustaining Services.
• HCBA Transitional Case Management, a waiver-paid service for nursing-facility-to-community transitions.

2026 Changes, A Consolidated Cheat Sheet

Several 2026 policy changes touch California's HCBS pathways at once, chief among them the PACE application pause, the AB 116 asset reinstatement and its 2027 step-down, and the CalAIM renewal timeline.1,7,6

Common Pitfalls, What Families Get Wrong

1. Thinking HCBA is the umbrella waiver for "all HCBS." HCBA is one §1915(c) waiver among several. The structure also includes ALW, MSSP, HCBS-DD/SDP, CBAS, IHSS, and PACE.1 Applying for HCBA when ALW or MSSP would fit better can cost months of access.

2. Underestimating the ALW waitlist. ALW is capped, waitlisted, and operates in only 15 counties, and as of December 2025 more people were waiting (18,365) than enrolled (14,847).9,2 Plan bridge solutions, such as CalAIM Nursing Facility Transition/Diversion or private pay, in parallel.

3. Hearing "the penalty doesn't apply to community programs" as "transfers don't matter." DHCS says the nursing-facility-level-of-care period of ineligibility does not apply to members enrolled in community-based Medi-Cal programs, and that is all it says. The look-back review is triggered by the Medi-Cal application every waiver requires.1 Ask your county eligibility worker about a specific transfer and a specific program before you make it.

4. Underusing spousal impoverishment. These protections, extended to HCBS by DHCS ACWDL 17-25 and 18-19, are often missed by community spouses applying for HCBA, ALW, or MSSP. The result: spouses depleted toward the $195,000 couple limit when the community spouse's $162,660 CSRA plus the applicant's $130,000 would let the household hold $292,660 through June 30, 2027.4,7

5. Assuming you know what the PACE pause does to enrollment. PL 25-02 pauses the PACE application process from 11/20/2025 until 11/19/2027 at minimum. It does not say on its face whether an operating organization may keep enrolling participants, so call the organization and ask rather than assuming a yes or a no.1

6. Confusing regional center eligibility with Medi-Cal eligibility. They are separate determinations made by different agencies. Ask your service coordinator how your Medi-Cal status affects which of your services are funded.

7. Assuming ALW covers room and board. It doesn't. ALW pays for care; the resident pays room and board out of their own income, roughly $1,400 to $1,500 a month based on the SSI rate.9 Higher-income seniors usually cannot make the math work without a CalAIM or private-pay option.

FAQ

The Bottom Line

1. There is no single "California HCBS waiver." Several distinct pathways operate under different authorities with different lead agencies, eligibility rules, and waitlists.1 Picking the right door matters more than picking the right form.

2. Spousal impoverishment reaches HCBS, and the asset limits have an expiration date. DHCS extends the §1924 protections to HCBS through ACWDL 17-25 and 18-19, so the community spouse's $162,660 CSRA sits on top of the applicant's $130,000, a household total of $292,660. That structure holds only through June 30, 2027; on July 1, 2027 the asset limits drop to $21,000 for one person and $31,000 for two.4,7,5

3. Waitlists are real, and parallel applications are standard practice. ALW, HCBA, and MSSP run on capped §1915(c) slots, and ALW and HCBA carry published waitlists, so apply to several at once while using the pathways that need no slot (IHSS, CBAS) and CalAIM Community Supports as bridges.1,2

4. 2026 brought significant change. AB 116 reinstated the non-MAGI asset test on January 1, 2026; DHCS paused the PACE application process until at least November 19, 2027; and short-term rental assistance becomes mandatory for managed-care plans no sooner than January 1, 2026, and then only for members meeting the specialty mental health or Drug Medi-Cal access criteria.7,6

5. The CalAIM §1115 renewal, submitted to CMS on May 11, 2026 and seeking a five-year term through December 31, 2031, will reshape the demonstration's HCBS provisions; watch DHCS for the finalized terms.6

6. Ask about transfers rather than assuming. The nursing-facility-level-of-care penalty does not reach members enrolled in community-based Medi-Cal programs, but that is not a promise that a gift is invisible to a waiver application. Your county eligibility worker is the person who can answer for your situation.1

Reference Numbers and Resources

For Medi-Cal eligibility questions, or to apply at the same time you pursue a waiver, call the Medi-Cal Member Helpline at 1-800-541-5555 or apply online at BenefitsCal.com.8 Each program has its own authoritative state page.

Learn More

The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.