California Provider Coalition
Protect program integrity. Preserve individualized care.
Keep vulnerable Californians safely housed.
The Golden State Assisted Living Coalition brings together providers and policy stakeholders across California to advance practical, auditable standards while protecting continuity of care for people who depend on community-based services.
Coalition pillars
Provider Voice
Bringing provider experience into a coordinated statewide effort.
Individualized Care
Supporting documented, needs-based care standards and continuity.
Policy Engagement
Turning provider and resident concerns into coordinated policy engagement.
The Issue
Written policy allows individualized staffing. Enforcement should reflect it.
Participating providers report that Residential Habilitation billing and audit practices are being applied as a rigid 1:1 standard. California's CMS-approved Assisted Living Waiver states that staffing may be one-to-one or another staff-to-participant ratio, depending on individual need. The coalition is asking responsible state program administrators and contracted plans to align billing guidance and enforcement with that written standard.
Source: California Department of Health Care Services, CMS-approved California Assisted Living Waiver, CA.0431.R04.00, pp. 4 and 49, effective March 1, 2024. Opens in a new tab.
Note: Descriptions of enforcement practices and their effects reflect provider reports and the coalition's policy position; they are not presented as formal findings by DHCS. The coalition does not claim that the approved waiver imposes a blanket 1:1 staffing requirement. The waiver expressly allows another staffing ratio based on individual need.
Blanket approach
A blanket 1:1 staffing interpretation applied regardless of documented individual need.
Individualized approach
Staffing based on documented participant need, prior authorization, service records, and auditable safeguards.
Our Priorities
A four-step path to durable, auditable standards
- 01
Pause
Seek a time-limited pause in any billing or audit enforcement that treats Residential Habilitation as a blanket 1:1 service while written guidance is clarified.
- 02
Convene
Bring together DHCS, providers, health plans, advocates, legislators, and other stakeholders.
- 03
Analyze
Evaluate resident, workforce, facility-capacity, fiscal, and county-level impacts.
- 04
Adopt
Establish individualized, needs-based, auditable standards and continuity-of-care protections.
The goal is accountability while reducing the risk of avoidable displacement, provider withdrawal, and unnecessary institutional placement.
Program Integrity
Strong oversight without destabilizing community-based care
Coalition-supported safeguards include:
Program integrity and individualized care are not competing goals.
- DHCS clinical authorization and periodic reauthorization
- Participant-specific schedules and daily service records
- Care Coordination Agency review of service documentation
- Written, participant-specific justification for the authorized staffing ratio
- Clear rules preventing duplicate billing for shared staff time
- Targeted audits, corrective action, reporting, and due process
These are coalition policy proposals and are not presented as a complete statement of current law or DHCS guidance.
Continuity of Care
The coalition is calling for safe, written transition plans
Health Net notice 26-899
Health Net's Assisted Living Facility Transitions Community Supports service ends January 1, 2027. December 31, 2026 is the final reimbursable service date.
The coalition supports timely, individualized transition planning, meaningful case management, and continuity-of-care protections before services end or a resident's placement changes.
Source: Health Net Provider Communication 26-899, “Plan Member Transitions Before ALF Transitions Services End,” July 15, 2026. A copy of this plan-issued communication is on file with the coalition. This issue is separate from the Residential Habilitation staffing-ratio issue. Document available upon request.
Human Impact
Billing and audit disputes can affect people who depend on stable, community-based care.
Billing and audit practices that do not account for individual need can have consequences beyond the claim itself. Providers and advocates describe the following potential effects.
Loss of familiar caregivers and routines
Reduced access to community-based placements
Staff time and resources diverted from direct care
Greater pressure on families and care teams
Increased risk of avoidable transfers or institutional placement
Reduced independence, dignity, and continuity
A potential chain of impact
Billing or audit disruption
Operational strain
Potential disruption to resident care
The effects vary by provider and individual circumstances.
Related research
Among 750 long-stay nursing-home residents in a 2019 Michigan cohort who transferred from one nursing home to another, 230 residents, or 30.7%, met the study's composite criteria for “transfer trauma.” This cross-sectional observational study did not involve California Assisted Living Waiver participants and did not establish that the transfer caused the measured changes.
Source: Montoya et al., “Transfer Trauma Among Nursing Home Residents: Development of a Composite Measure,” The Gerontologist, 2024. Opens in a new tab.
Government Affairs
Elevating provider and resident concerns
The coalition works to elevate provider and resident concerns with relevant California policymakers, regulators, state agencies, and stakeholders. The goal is a shared, documented understanding of how billing and audit practices affect community-based care.
Who Can Participate
The coalition is currently open to California RCFEs
At launch, coalition membership is limited to licensed Residential Care Facilities for the Elderly. Other provider types may be invited to participate later.
Licensed Residential Care Facilities for the Elderly (RCFEs)
California-licensed communities serving older adults in non-medical residential settings.
Single-site and multi-site RCFE operators
Organizations running one facility or many. Participation is based on total licensed beds across the organization.
RCFE owners, administrators, and executives
The people authorized to speak for the organization on policy, billing, and audit matters.
RCFEs participating in the Assisted Living Waiver
Facilities serving Assisted Living Waiver participants, including those affected by billing and audit practices.
Participation
Six-month RCFE participation
Bed counts are the total licensed beds across your entire organization, not per facility. For example, ten six-bed facilities are 60 total beds, not 0–10. Amounts are confirmed directly with Golden Bear Strategies; this website does not process payments.
0–10 total beds
$6,000 total
$6,000 for the six-month term. Paid in full upfront.
Select this tier11–50 total beds
$5,000 per month
$30,000 over the six-month term. Six-month commitment.
Select this tier51–100 total beds
$10,000 per month
$60,000 over the six-month term. Six-month commitment.
Select this tier
More than 100 total beds? Organizations with more than 100 total beds are quoted directly. Submit an inquiry and the coalition will follow up with pricing.
Contacts
Coalition Leadership and Contacts
The Golden State Assisted Living Coalition is led by Golden Bear Strategies, a Sacramento-based government affairs and lobbying firm. Golden Bear Strategies coordinates provider outreach, coalition participation, and government affairs engagement.
Coalition Contacts
Samantha Corbin
President of Golden Bear Strategies
Get Involved
Take part in the coalition
One step gets you started. Choose how you would like to take part and the coalition team will follow up directly.
Lead Contact
Brandon Knapp
Golden Bear Strategies
brandon@goldenbearstrategies.com
Samantha Corbin — President of Golden Bear Strategies
FAQ
Frequently asked questions
It is an independent California provider coalition of licensed Residential Care Facilities for the Elderly (RCFEs) working together to advance practical, individualized care policy.
The Golden State Assisted Living Coalition is led by Golden Bear Strategies, a Sacramento-based government affairs and lobbying firm. Golden Bear Strategies coordinates provider outreach, coalition participation, and government affairs engagement. Brandon Knapp is the lead contact, and Samantha Corbin serves as President of Golden Bear Strategies.
The coalition focuses on individualized care standards under the Assisted Living Waiver, workable program-integrity and audit practices, provider stability, and continuity of care during health-plan transitions.
It is not a blanket staffing requirement. The approved waiver allows one-to-one or another staff-to-participant ratio depending on individual need and authorization. Providers report that billing and audit practices are nevertheless being applied as a rigid 1:1 standard.
Health Net's Assisted Living Facility Transitions Community Supports service ends January 1, 2027, and December 31, 2026 is the final reimbursable service date. This is separate from the Residential Habilitation staffing-ratio issue. The coalition supports written transition planning and continuity-of-care protections.
At launch, coalition membership is limited to California-licensed Residential Care Facilities for the Elderly (RCFEs), including single-site and multi-site operators. Other provider types may be invited to participate later.
Participation is organized by the total number of licensed beds across your entire organization for a six-month term: 0–10 total beds, $6,000 total paid upfront; 11–50 total beds, $5,000 per month ($30,000 over six months); 51–100 total beds, $10,000 per month ($60,000 over six months). Bed counts are the total licensed beds across your entire organization, not per facility. For example, ten six-bed facilities are 60 total beds, not 0–10. Organizations with more than 100 total beds are quoted directly. Submit an inquiry and the coalition will follow up with pricing. Amounts are confirmed directly with Golden Bear Strategies, and the website does not process payments.
Your inquiry is delivered to coalition contacts, who follow up by email or phone to discuss participation, share materials, or schedule a meeting.
No. The Golden State Assisted Living Coalition is an independent provider coalition. It is not sponsored or endorsed by any government official or agency.
Inquiries are stored in a private database with access restricted to authorized administrators and emailed to coalition contacts so they can respond. The site does not use advertising or cross-site tracking cookies. Website inquiry records are automatically deleted after 180 days, and records marked as tests or duplicates after 30 days. Please do not submit resident, patient, medical, or protected health information. See the Privacy Notice for full details.
Sources
Primary Documents and Research
Policy conditions can change. Information is presented for public education and advocacy and does not constitute legal advice.