25-1365m New HIV Test Result Disclosure Rules for Medi-Cal Providers

Date: 12/22/25

Streamlined guidance to support compliance, care coordination and quality improvement

Effective January 1, 2026, Senate Bill (SB) 0278 updates California law on how HIV test results may be disclosed for Medi-Cal beneficiaries.

Key changes

Expanded permitted disclosure for care and quality programs

Providers may share HIV test results that identify Medi-Cal beneficiaries with:

• The patient’s assigned Medi-Cal Managed Care Plan (MCP).
• External quality review organizations contracted by the California Department of Health Care Services (DHCS).

These disclosures support quality improvement initiatives, including value-based payment and healthy behavior incentive programs designed to improve HIV care. No written patient authorization is required for these disclosures.

Non-identifying results for quality improvement

MCPs may share HIV test results that do not identify Medi-Cal patients with the DHCS staff for quality improvement purposes—without written authorization.

Restrictions still apply

• Disclosure of identifying HIV test results to other health care service plans (not the assigned Medi-Cal MCP) requires written patient authorization from the patient or their representative.
• Further disclosure to federal agencies or authorities in other states is only permitted if required by federal law.

What you need to do now

• Review your disclosure practices to ensure compliance with SB 0278 and support coordinated HIV care.
• For additional details on SB 0278 please visit SB-278 Health data: HIV test results.

Need help? Contact us

Relevant sections of the provider operations manuals and Behavioral Health Provider Operations Manual have been revised to reflect the information contained in this update as applicable. Provider operations manuals are available electronically in the Provider Library on the provider portal.

If you have questions regarding the information contained in this update, contact CalViva Health at 888-893-1569. Behavioral Health providers can call 844-966-0298.

 

This information applies to Physicians, Participating Physician Groups (PPGs), Hospitals, Ancillary Providers, Community Supports (CS) Providers, Enhanced Care Management (ECM) Providers, and Behavioral Health Providers.

This information applies to Medi-Cal in Fresno, Kings and Madera counties.