Are You Notifying the Right Agency? Medi-Cal Managed Care vs. Fee-for-Service Liens Explained

James Wong — Founder & Pharmacist, LienScripts | February 7, 2025 | 7 min read

Most Medi-Cal patients in California are enrolled in managed care plans — not fee-for-service. The TPLRD/DHCS lien process applies only to fee-for-service. If your client is in a managed care plan, you're dealing with the plan, not DHCS. Many attorneys get this wrong.

Are You Notifying the Right Agency? Medi-Cal Managed Care vs. Fee-for-Service Liens Explained

If your client is on Medi-Cal, you know you have notification and lien obligations. But here is a question many California PI attorneys cannot answer correctly: who do you actually notify?

The answer depends on whether your client is enrolled in Medi-Cal fee-for-service or a Medi-Cal managed care plan. These are fundamentally different Medi-Cal programs with different lien processes and different responsible parties. Notifying DHCS when your client is in a managed care plan — or vice versa — means you are dealing with the wrong agency entirely.

[!KEY] Over 80% of California Medi-Cal enrollees are in managed care plans — meaning the DHCS TPLRD notification process does not apply to most Medi-Cal clients, and you must contact the managed care plan directly instead.

Two Types of Medi-Cal: A Critical Distinction

Fee-for-Service Medi-Cal is the traditional model: the state (through DHCS) pays medical providers directly for each covered service. Most elderly, blind, and disabled Medi-Cal recipients, along with some other populations, receive fee-for-service Medi-Cal. The TPLRD Personal Injury Program — with its 30-day notification rule, Notice of Lien, and Final Lien Claim process — applies to this program.

Medi-Cal Managed Care covers the majority of Medi-Cal enrollees in California today. Under managed care, the state pays a managed care organization (MCO) — a health plan such as LA Care, Health Net, Molina Healthcare, Blue Shield Promise, or Kaiser — a monthly capitated rate to provide all covered services to the enrollee. The plan handles billing and payment, not DHCS directly.

As of recent years, well over 80% of California Medi-Cal enrollees are in managed care plans. This means the majority of your Medi-Cal clients are in managed care, not fee-for-service.

Why This Matters for Lien Recovery

When the client is in fee-for-service Medi-Cal: DHCS paid for the treatment directly and asserts recovery rights through TPLRD. Notify DHCS and follow the TPLRD process.

When the client is in a Medi-Cal managed care plan: the MCO paid the providers (or the providers were capitated under the plan). The MCO — not DHCS — has the recovery interest. You need to contact the managed care plan directly, not DHCS.

Managed care plans have their own:

• Subrogation/recovery departments
• Notification procedures (which may differ from TPLRD's 30-day requirement)
• Lien amounts (based on what the plan paid, which may differ from what DHCS would have paid)
• Reduction and negotiation processes

DHCS cannot help you with a managed care lien. If your client is in managed care and you contact DHCS, DHCS will either tell you they have no record of payments or refer you to the plan. You need to identify the right plan from the beginning.

[!KEY] When an attorney contacts DHCS about a managed care client's lien and DHCS reports no record of payments, the attorney may incorrectly conclude no lien exists — the correct interpretation is that DHCS is not the right party, and the managed care plan's subrogation department must be located and contacted separately.

How to Determine Which Type Your Client Has

1. Ask the client. Most Medi-Cal members know the name of their health plan (LA Care, Health Net, Molina, etc.). If they receive a Medi-Cal ID card from a specific health plan, they are in managed care.

2. Review the client's Medi-Cal Benefits ID Card. The card will show the plan name if the client is in managed care. A plain state Medi-Cal card typically indicates fee-for-service.

3. Check with the client's treating providers. Medical providers can tell you which plan paid for a patient's treatment.

4. Contact Medi-Cal directly. DHCS can confirm whether a beneficiary is in fee-for-service or managed care for the relevant period.

Contacting the Managed Care Plan

Once you have identified the managed care plan, contact its subrogation or third-party liability department directly. Plans typically have a designated team for personal injury recovery. The notification procedures, required documentation, and lien reduction processes vary by plan, so request the plan's specific procedures when you make initial contact.

Some managed care plans have notification windows shorter than TPLRD's 30-day requirement. Confirm the plan's specific deadline immediately after identifying the plan — do not assume the TPLRD rules apply.

[!NOTE] Managed care plans have their own subrogation departments, notification procedures, and lien reduction processes — contacting DHCS when your client is in a managed care plan means you are dealing with the wrong agency entirely.

When Both May Apply

It is possible — though uncommon — for a client to have had both fee-for-service Medi-Cal and managed care coverage during different periods of treatment. In that case, you may owe notifications to both DHCS and the managed care plan, and both may have recovery interests for their respective payment periods.

Carefully review the treatment timeline against the client's Medi-Cal enrollment history to identify any coverage type changes during the relevant period.

[!KEY] Clients who transition between Medi-Cal coverage types during a case — fee-for-service to managed care or vice versa, which commonly occurs during annual redeterminations — may generate recovery claims from both DHCS and the managed care plan for different periods of treatment, requiring separate notification and resolution with each.

Related Resources

• California's TPLRD Program: Full Overview
• The Medi-Cal Lien Checklist for Attorneys
• DHCS TPLRD Program