26-258 Avoid Penalties: Complete Implicit Bias Training Now

Date: 03/02/26

Facilities must report provider compliance to the attorney general

Now that California’s 2026 reporting period has begun, health care facilities are required to submit proof that all perinatal providers have completed their mandatory implicit bias training. To support accurate reporting and avoid penalties, all physicians and practitioners involved in perinatal care must ensure their training is complete and properly documented. These reporting requirements are built on the training standards established under state law and now require annual submission of compliance to the California attorney general.

What physicians and practitioners must do immediately

1 Complete your implicit bias training.

• If you have not completed the required implicit bias training, or if your refresher course is due, please complete the training immediately.
• Training is mandatory for all physicians and practitioners involved in perinatal care.
• New physicians and practitioners must complete training within six months of employment.
• All physicians and practitioners must complete refresher training every two years.

2 Ensure your training is documented.

• Physicians and practitioners do not submit proof of training directly to the attorney general. Your responsibility is to ensure your facility has your training documentation so it can be included in the mandatory annual report.
• If you are unsure whether your training has been logged properly, check with your education department or facility leadership.

Submitting proof of compliance

The California Attorney General’s Office sends a secure online reporting survey to each facility’s designated point of contact. This survey is the official and required method for reporting whether physicians and practitioners have completed the mandatory implicit bias training. The Department of Justice provides system access and instructions directly to the point of contact. For more information, visit the State of California Department of Justice at California Dignity in Pregnancy and Childbirth Act (AB 2319).

Penalties for non‑compliance

Assembly Bill 2319 does not include a “disqualification” provision for individual physicians and practitioners. However, there are significant penalties for facilities that fail to comply with training or reporting requirements. Penalties may be imposed by the attorney general or the California Department of Public Health (CDPH).

• Civil penalties (attorney general):
  • $5,000 for the first violation.
  • $15,000 for each subsequent violation.
  • The attorney general may also publicly post the names of non‑compliant facilities.
• Administrative penalties (CDPH):
  • CDPH may issue additional administrative penalties.
  • Penalized facilities will be listed publicly each year.

What physicians and practitioners need to know

• Physicians and practitioners do not individually submit proof of training to the attorney general. Facilities collect and submit all required data.
• Your responsibility is to ensure your training is completed and documented so your facility can accurately report compliance.
• Although you are not individually penalized or disqualified, incomplete training can jeopardize your facility’s compliance status, leading to the penalties listed above. Completing your required training promptly helps protect your facility from enforcement actions.

Need help? Contact us

If you have questions regarding the information contained in this update, contact Community Health Plan of Imperial Valley at 833-236-4141.
 

This information applies to Physicians and Practitioners.

This information applies to Medi-Cal in Imperial County.