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Golden State Assisted Living Coalition

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.

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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

  1. 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.

  2. 02

    Convene

    Bring together DHCS, providers, health plans, advocates, legislators, and other stakeholders.

  3. 03

    Analyze

    Evaluate resident, workforce, facility-capacity, fiscal, and county-level impacts.

  4. 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

  1. Billing or audit disruption

  2. Operational strain

  3. 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.

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 tier

  • 11–50 total beds

    $5,000 per month

    $30,000 over the six-month term. Six-month commitment.

    Select this tier

  • 51–100 total beds

    $10,000 per month

    $60,000 over the six-month term. Six-month commitment.

    Select this tier

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.

Updates

Official Updates

Federal Policy Update

U.S. Department of Justice |

DOJ Announces New Fraud Whistleblower Program

On October 20, 2026, the U.S. Department of Justice announced the Fraud Whistleblower Incentive Program (WHIP), supported by a $25 million commitment from the U.S. Department of the Treasury. The program seeks qualifying information about federal health care offenses and fraud involving government programs and benefits.

Why it matters for providers

For community-based care providers, the announcement highlights the importance of accurate billing, documented services, and clear compliance guidance.

The Golden State Assisted Living Coalition supports accountability and program integrity. Our advocacy calls for clear, individualized, auditable care standards that help providers meet their obligations while protecting residents’ access to community-based care.

This federal announcement is separate from the coalition’s California Assisted Living Waiver staffing and billing advocacy.

Read the DOJ Announcement(opens in a new tab)Watch the Official Announcement(opens in a new tab)Program Details and Eligibility(opens in a new tab)

Official Source: DHCS

DHCS |

Health Net Continuity-of-Care and Corrective Action Update

DHCS confirmed Health Net's continuity-of-care, authorization, and transition obligations and imposed a Corrective Action Plan, while Health Net's termination of its ALFT Community Support remains scheduled for January 1, 2027.

Read the Full UpdateRequest the Official DHCS Letter

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

samantha@goldenbearstrategies.com

Lead Contact

Brandon Knapp

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.

Join the coalition

Open the coalition inquiry form and tell us about your organization.

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Request information

Receive coalition materials, policy updates, and participation details.

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Request a meeting

Speak with coalition contacts about the policy issues and current priorities.

Continue

Lead Contact

Brandon Knapp

Golden Bear Strategies

brandon@goldenbearstrategies.com

Samantha Corbin — President of Golden Bear Strategies

samantha@goldenbearstrategies.com

(916) 316-7891

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. 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

Information last reviewed August 29, 2026.

Policy conditions can change. Information is presented for public education and advocacy and does not constitute legal advice.

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