In California

Facilities are required to facilitate access, however, they have the discretion to deny individuals if they feel that they are beyond the capabilities of the facility.

If they feel they cannot handle the medical complexity of a patient, they are required to refer the patient to another facility. Additionally, the county behavioral health plan and managed care plan remain responsible for ensuring that the individual receives timely and appropriate placement in a setting that can meet both their behavioral health and medical needs. First, try to reassure the facility that bleeding disorders are not actually medically complex but if they remain concerned, ask for a referral to a facility that they believe would be more appropriate and request support from the county behavioral health plan and managed care plan in finding an appropriate facility

Sources:

• Medi-Cal Behavioral Health – Policy Division, California Department of Health Care Services via email on July 9, 2025.

• DHCS: “In general, a county behavioral health plan (i.e., a Drug Medi-Cal Organized Delivery System Plan or County Mental Health Plan) provider may not exclude a Medi-Cal member from residential treatment solely because the member has complex medical needs.  Additionally, individuals who meet the criteria for admission and are deemed appropriate for care would not be excluded from receiving external medical treatment for a coexisting condition.  However, if the individual’s medical condition exceeds the facility’s licensed capacity or capabilities, or if a different setting is clinically indicated as more appropriate, the provider may refer the member accordingly.”

Use the following talking points to address the facility. If they still deny based on medical complexity after assurances are given, then request a referral to another facility and request support from the county behavioral health plan and managed care plan in finding an appropriate facility. 

• “I completely understand that bleeding disorders can sound complicated — they’re rare, genetic conditions that most behavioral health providers don’t encounter often. That unfamiliarity can understandably make it seem like these patients need a high level of medical support. In reality, national guidance makes clear that for individuals who are medically stable, their bleeding disorder can be managed safely within your setting without intensive medical intervention.”

• “National guidance from the National Bleeding Disorders Foundation’s Medical and Scientific Advisory Council (known as MASAC) is very clear on this point. MASAC has formally stated that if a person with a bleeding disorder is medically stable and has an established treatment plan from their hematologist, their day-to-day management is straightforward and not complex.”

• “In other words, as long as [the patient] is permitted to continue their prescribed bleeding disorder medication during admission, they are not medically complex, and their diagnosis alone should not be a reason for exclusion from treatment.”

• “MASAC guidance (Document #289, approved October 2024) specifically notes that stable individuals with bleeding disorders typically manage their condition independently in the community. They don’t need hospitalization, remote monitoring, or special medical supervision. The presence of a bleeding disorder alone does not make someone medically unfit or unstable for behavioral-health admission.”

• “If any unrelated medical issue were to arise during treatment, the facility should simply follow its usual standard of care, just as it would for any other patient.”

• “I’m happy to send you the full MASAC recommendation from the national experts and walk through any questions you might have.”

Send the following to the facility:

• MASAC Guidance on Patient Admission: Personalize this email template to share the official MASAC guidance for patient admission.

• MASAC Document #289: Share MASAC Document 289 for recommendations on increasing access to care for people with bleeding disorders.