Existing law establishes the California Health and Human Services Agency, headed by the Secretary of California Health and Human Services. Existing law further establishes, within the agency, a number of departments and other entities, including the State Department of Health Care Services. Existing law provides for the Medi-Cal program, which is administered by the State Department of Health Care Services, and under which qualified low-income persons receive health care benefits.

This bill would require the State Department of Health Care Services, after obtaining specified information from the Employment Development Department (EDD), to prepare a report that includes information regarding employers in California that employ 100 or more employees and have any employees who receive benefits from the Medi-Cal program, including, among other things, the annual cost to the Medi-Cal program provided to each identified employers employees and their dependents enrolled in the Medi-Cal program, the estimated total annual cost of Medi-Cal services provided to employees, and the dependents of those employees, of each employer, and submit that report to the Legislature no later than July September 1, 2027, and annually thereafter. The bill would provide that individually identifiable information about employees or Medi-Cal enrollees contained in the report is exempt from disclosure under the California Public Records Act, and would authorize the department and EDD to enter into data-sharing agreements, as provided. The bill would also repeal an obsolete reporting requirement.

Under existing law, the information obtained in the administration of the Unemployment Insurance Code is for the exclusive use and information of the Director of Employment Development in the discharge of their duties and is not open to the public. However, existing law permits the use of the information for specified purposes, and allows the director to require reimbursement for direct costs incurred. Existing law provides that a person who knowingly accesses, uses, or discloses this confidential information without authorization is guilty of a misdemeanor.

The bill would require the Director of Employment Development to permit the use of specified information in their possession by the State Department of Health Care Services to prepare and submit the above-described report. By requiring this information to be provided to the department for these purposes, this bill would expand the crime of unauthorized access, use, or disclosure of this information, and would impose a state-mandated local program.

Existing law, subject to certain exceptions, also requires all types of information concerning a person, made or kept by any public officer or agency in connection with the administration of the Medi-Cal program, to be confidential, and makes knowingly releasing or possessing this confidential information punishable as a misdemeanor.

The bill would make individually identifiable information about employees or Medi-Cal enrollees contained in the above-described report subject to these confidentiality requirements. By expanding the scope of an existing crime, this bill would impose a state-mandated local program.

Existing law establishes within the Department of Industrial Relations the Division of Labor Standards Enforcement, headed by the Labor Commissioner, for the purposes of enforcing labor laws. Existing law prohibits an employer from discharging or in any manner discriminating against an employee for specified actions, including, among other things, taking time off to serve on a jury or because of an employees status as a victim of crime or abuse, as specified.

This bill would additionally prohibit an employer from discharging or in any manner discriminating or retaliating against an employee who applies for, or is enrolled in, the Medi-Cal program. The bill would also prohibit an employer from refusing to hire a person because that person is enrolled in the Medi-Cal program.

Existing constitutional provisions require that a statute that limits the right of access to the meetings of public bodies or the writings of public officials and agencies be adopted with findings demonstrating the interest protected by the limitation and the need for protecting that interest.

This bill would make legislative findings to that effect.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law establishes the California Health and Human Services Agency, headed by the Secretary of California Health and Human Services. Existing law further establishes, within the agency, a number of departments and other entities, including the State Department of Health Care Services. Existing law provides for the Medi-Cal program, which is administered by the State Department of Health Care Services, and under which qualified low-income persons receive health care benefits.

This bill would require the California Health and Human Services Agency, State Department of Health Care Services, after obtaining specified information from the Employment Development Department, Department (EDD), to prepare a report that includes information regarding employers in California that employ 50 100 or more employees and have any employees who receive benefits from the Medi-Cal program, including, among other things, the annual cost to the Medi-Cal program provided to each identified employers employees and their dependents enrolled in the Medi-Cal program, and submit that report to the Legislature no later than July 1, 2027, and annually thereafter. The bill would provide that individually identifiable information about employees or Medi-Cal enrollees contained in the report is exempt from disclosure under the California Public Records Act, and would authorize the California Health and Human Services Agency department and the Employment Development Department EDD to enter into data-sharing agreements, as provided. The bill would also repeal an obsolete reporting requirement.

Under existing law, the information obtained in the administration of the Unemployment Insurance Code is for the exclusive use and information of the Director of Employment Development in the discharge of their duties and is not open to the public. However, existing law permits the use of the information for specified purposes, and allows the director to require reimbursement for direct costs incurred. Existing law provides that a person who knowingly accesses, uses, or discloses this confidential information without authorization is guilty of a misdemeanor.

The bill would require the Director of Employment Development to permit the use of specified information in their possession by the California Health and Human Services Agency State Department of Health Care Services to prepare and submit the above-described report. By requiring this information to be provided to the California Health and Human Services Agency department for these purposes, this bill would expand the crime of unauthorized access, use, or disclosure of this information, and would impose a state-mandated local program.

Existing constitutional provisions require that a statute that limits the right of access to the meetings of public bodies or the writings of public officials and agencies be adopted with findings demonstrating the interest protected by the limitation and the need for protecting that interest.

This bill would make legislative findings to that effect.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law, the Emergency Medical Services System and the Prehospital Emergency Medical Care Personnel Act, establishes the Emergency Medical Services Authority. Under existing law, the authority is responsible for the coordination and integration of all state activities concerning emergency medical services.

This bill would make technical, nonsubstantive changes to the provision naming the act.

Date of Hearing: August 5, 2026

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

SBPCA Bill Id:SB 1284

Author:(Smallwood-Cuevas) – As Amended Ver:May 14, 2026

Urgency: No State Mandated Local Program: Yes Reimbursable: No

SUMMARY:

This bill requires the Department of Health Care Services (DHCS) publish a report detailing, for employers of at least 100 employees, how many of the employers’ employees are enrolled in Medi-Cal, and related information. The bill also authorizes data-sharing for the purpose of developing the report and prohibits an employer from discriminating against an employee or applicant based on Medi-Cal enrollment status.

For a detailed enumeration of the provisions of this bill, please refer to the Assembly Health Committee analysis or the Assembly Labor and Employment Committee analysis.

FISCAL EFFECT:

1. The Employment Development Department (EDD) estimates costs of approximately $100,000 in one-time costs and $100,000 in ongoing costs to provide data to DHCS (General Fund (GF)). However, EDD states it is unlikely to be able to provide the data due to federal compliance concerns.
   
2. DHCS estimates, contingent on EDD being able to share the requisite data, one-time costs of approximately $207,000 to $232,000 Total Fund (TF) ($114,000 to $136,000 (GF) and $93,000 to $96,000 Federal Fund (FF)) for fiscal year (FY) 2026-27 for system changes to the California Healthcare Enrollment Eligibility Retention System and one staff position.
   
   DHCS also anticipates costs of $945,000 TF ($474,000 GF and $471,000 FF) for FY 2027-28 and $899,000 TF ($450,000 GF and $449,000 FF) for FY 2028-29 and ongoing, for five additional full-time staff.
   
3. The Labor Commissioner’s Office estimates costs of $200,000 per year (Labor Enforcement and Compliance Fund) to enforce the prohibition on discriminating against an employee or applicant based on Medi-Cal enrollment.

COMMENTS:

1. Purpose. This bill is co-sponsored by California Federation of Labor Unions, AFL-CIO; End Poverty in California; SEIU California; and United Food and Commercial Workers Western States Council. According to the author:

Today, more than 3 million working Californians rely on Medi-Cal because their employers do not provide affordable health insurance. Nearly one in five jobs in California is held by a worker enrolled in Medi-Cal, representing over $20 billion annually in public spending tied to the workforce.

When companies fail to provide affordable coverage or livable wages, Medi-Cal fills the gap. That means taxpayers are subsidizing a significant share of health care costs for California’s low-wage workforce...If taxpayers are covering the cost of health care for a company’s workforce, the public deserves to know. SB 1284 brings transparency and accountability to this issue by requiring the California Health and Human Services Agency to publish the names of employers with workers enrolled in Medi-Cal, along with the estimated annual cost to the program associated with those employees.

1. Background. The state does not require employers to offer health insurance. However, employers are subject to the requirements of the federal Affordable Care Act, under which most employers with an average of 50 or more full-time equivalent employees in a calendar year must offer their full-time employees minimum essential health coverage that is affordable and provides a minimum value, as defined, or potentially make an employer shared responsibility payment to the Internal Revenue Service. This requirement is commonly known as the “employer mandate.”

According to research by the UC Berkeley Labor Center (Labor Center), one in five California workers is enrolled in Medi-Cal. Low-income workers are less likely to have coverage through their job, and certain industries are more likely to employ workers who are also enrolled in Medi-Cal, including agriculture, forestry, fishing, mining, bars, food service, administrative and building services, and retail. The Labor Center estimates the state will spend $36 billion, including state and federal dollars, to provide Medi-Cal coverage to workers in FY 2026-27.

AB 1792 (Gomez), Chapter 889, Statutes of 2014, was substantially similar to this bill. In 2014, the US Department of Labor (DOL) notified EDD that federal regulations prohibit publishing the information in the AB 1792-required report, stating that federal law requires unemployment compensation (UC)-related information be kept confidential to avoid deterring either unemployed workers or employers from participating in the UC program. As a result, the AB 1792 report was never created. DOL recently sent a similar letter to EDD in relation to this bill. However, the sponsors of this bill note other states have successfully implemented similar laws.

Analysis Prepared by: Allegra Kim / APPR. / (916) 319-2081

Date of Hearing: June 24, 2026

ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT

Liz Ortega, Chair

SBPCA Bill Id:SB 1284

Author:(Smallwood-Cuevas) – As Amended Ver:May 14, 2026

SENATE VOTE: 30-9

SUBJECT: Medi-Cal benefits: employer reports

SUMMARY: Requires the Department of Health Care Services (DHCS) to publish an annual report regarding specified employers with employees enrolled in Medi-Cal; and prohibits an employer from discharging, discriminating or retaliating against an employee, or refusing to hire a job applicant, based on Medi-Cal enrollment. Specifically, this bill:

Requires the DHCS to publish an annual report regarding specified employers with employees enrolled in Medi-Cal:

1. Requires the DHCS, after receiving the information from the Employment Development Department (EDD), to annually publish a report that includes all of the following about employers that have any employees enrolled in Medi-Cal at any point during the reporting year while employed by the employer:
   1. The name and address of each employer;
   2. The parent company of the employer, if applicable;
   3. The Employer Identification Number (EIN) of the employer;
   4. The North American Industry Classification System (NAICS) code assigned to the employer;
   5. The total number of employees of that employer;
   6. The total number of employees of that employer enrolled in the Medi-Cal program by category of aid at any point during that reporting year;
   7. The aggregate number of months all employees of that employer received benefits through the Medi-Cal program while employed;
   8. The total number of dependents of employees of that employer enrolled in the Medi-Cal program;
   9. The estimated total annual cost of Medi-Cal services provided to employees, and dependents of employees, of each employer;
   10. A summary of the 100 employers with the highest number of employees and dependents enrolled in the Medi-Cal program; and,
   11. A summary of the 100 employers with the highest percent of employees and dependents enrolled in the Medi-Cal program.
2. Defines “employer” to mean an employer required to file an annual pay data report with the Civil Rights Department (private employers with 100 or more employees) and that has any employee enrolled in Medi-Cal at any point during the reporting year while employed by the employer.
3. Requires the DHCS to submit the report to the Legislature no later than September 1, 2027, and annually thereafter, as specified.
4. Exempts individually identifiable information about employees or Medi-Cal enrollees contained in the report from disclosure under the California Public Records Act and subjects such information to existing confidentiality requirements that apply for purposes of the Medi-Cal program.
5. Provides that the above provisions shall not be construed to permit authorization or publication of identifying information of employees enrolled in Medi-Cal.
6. Updates authority for the EDD to provide information to the DHCS for purposes of the report described above, and authorizes the DHCS and the EDD to enter into data-sharing agreements as necessary to implement the above provisions, consistent with state and federal privacy laws.
7. Provides that the above provisions shall not be construed to authorize an employer to engage in any conduct against an employee or a job applicant in violation of (9) below, including, but not limited to, discouraging or preventing an employee from applying for or enrolling in Medi-Cal.
8. Makes related findings and declarations, and states the intent of the Legislature in enacting the above provisions to ensure that Medi-Cal continues to operate as the payor of last resort and to support the effective administration, oversight, and evaluation of the program by improving transparency regarding the relationship between employment and Medi-Cal enrollment.

Prohibits an employer from discharging or retaliating against an employee or job applicant based on Medi-Cal enrollment:

1. Prohibits an employer from discharging or in any manner discriminating or retaliating against an employee who applies for, or is enrolled in, Medi-Cal, and prohibits an employer from refusing to hire a person because that person is enrolled in Medi-Cal.

Other provisions:

1. Repeals the sunsetted law requiring the DHCS and the Department of Social Services to share with the EDD the social security numbers of all Medi-Cal and CalFresh recipients.

EXISTING FEDERAL LAW:

1. Establishes the Medicaid program to enable each state to furnish medical assistance on behalf of individuals whose income and resources are insufficient to meet the costs of necessary medical services. 42 USC §1396, et seq.
2. Requires states to provide safeguards restricting the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the program with limited exceptions for school nutrition programs. 42 USC §1396(a).
3. Starting January 1, 2027, as enacted by H.R. 1 (Public Law No. 119-21), requires individuals with incomes below 138% of the federal poverty level who are under age 65, not pregnant, and have no Medicaid-eligible dependents to demonstrate community engagement through at least 80 hours of work, community service, or participation in a work program, or at least half-time participation in an educational program, or have a monthly income not less than 80 times the federal minimum wage in a specified month. Provides for some exceptions to this requirement. 42 USC §1396(a).
4. Requires an applicable large employer, defined as an employer with an average of 50 or more full-time equivalent employees in a calendar year, to offer its full-time employees and their dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan or be subject to an assessable payment if any of their full-time employees enroll in a state-based health insurance exchange. 26 USC §4980(h).

EXISTING STATE LAW:

1. Establishes the Medi-Cal program, administered by the DHCS, under which qualified low-income individuals receive health care services. Welfare and Institutions Code § 14000, et seq.
2. Requires an individual’s information given for purposes of receiving Medi-Cal to be kept confidential and not open to examination other than for purposes directly connected with the administration of the program. Limits the use of Medi-Cal applicant and recipient information to encompass those activities and responsibilities in which DHCS and its agents are required to engage in to ensure effective program operations, which include but are not limited to, establishing eligibility and methods of reimbursement; determining the amount of medical assistance; providing services for recipients; conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the Medi-Cal program; and conducting a legislative investigation or audit related to the administration of the Medi-Cal program, with limited exceptions for the coordination of other benefits, namely school nutrition programs. Welfare & Institutions Code § 14100.2.
3. Exempts confidential Medi-Cal applicant or recipient information from disclosure pursuant to the California Public Records Act. Government Code § 7930.170.
4. Requires private employers with 100 or more employees to submit to the Civil Rights Department an annual pay data report with specified information on employees including total earnings hours worked of each employee, total employees, and the employer’s NAICS code. Government Code § 12999.
5. Establishes the EDD within the Labor and Workforce Development Agency and makes it responsible for, among other duties, the administration of the Unemployment Insurance and Disability Insurance programs. Unemployment Insurance Code § 301.
6. Authorizes the EDD to share wage and employment data, under specified conditions, for specified purposes and enumerates the programs for which data can be shared. Unemployment Insurance Code § 1095.

FISCAL EFFECT: According to the Senate Appropriations Committee:

• Unknown costs for the Employment Development Department (EDD), likely one-time General Fund costs of $100,000 and ongoing General Fund costs of $100,000, for administration.
• Unknown ongoing General Fund costs, potentially hundreds of thousands, for DHCS to provide the reports.

COMMENTS:

Employer-provided healthcare requirements under federal law:

In California, there is no state-level mandate requiring all employers to offer health insurance. However, employers are subject to the requirements of the federal Affordable Care Act, under which most employers with an average of 50 or more full-time equivalent employees in a calendar year must offer their full-time employees minimum essential health coverage that is affordable and provides a minimum value, as defined, or potentially make an employer shared responsibility payment to the IRS. This requirement is commonly known as the “employer mandate.”

When workers are not covered by an employer-sponsored plan, they often enroll in Medi-Cal if their household income falls within the program's limits. Medi-Cal is California's Medicaid program and offers free or low-cost coverage to qualifying low-income individuals and families.

California workers enrolled in Medi-Cal:

According to research by the UC Berkeley Labor Center, one out of five California workers is enrolled in Medi-Cal. Low-income workers are less likely to have coverage through their job, and certain industries are more likely to employ individuals who are also enrolled in Medi-Cal, including agriculture, forestry, fishing, and mining; restaurants, bars, and food service; administrative and building services, and retail.

Employees with Medi-Cal coverage work for employers of all sizes, with 27 percent of Medi-Cal-enrolled workers employed by companies with over 1,000 employees, 17 percent working for employers with 101-999 employees, and 7 percent working for companies with 51-100 employees. However, nearly half of working Medi-Cal enrollees work in businesses with under 50 employees.

The UC Berkeley Labor Center estimates that $36 billion will be spent to provide Medi-Cal to these workers, including state and federal spending, in Fiscal Year 2026-27.^[1]

HR 1 Medicaid eligibility work requirements:

In July 2025, Congress passed HR 1, the federal budget reconciliation bill, which, among other things, included new work documentation requirements for Medicaid eligibility starting January 1, 2027, and increased the frequency of eligibility redeterminations to every six months instead of annually. To be eligible, individuals must prove that they are working, engaging in community service, or receiving work training for at least 80 hours per month—or that they are enrolled in school part time—unless they qualify for an exemption. States must verify compliance through these activities or through an income equivalent to the federal minimum wage for 80 hours a month.

The UC Berkeley Labor Center estimates that 1.87 million Californian adults will lose Medi-Cal coverage due to the work requirements.^[2] Given this increase in the number of uninsured, along with other HR 1 provisions that restrict states’ ability to raise revenue to fund their Medicaid programs, California is having to reevaluate its budget to either supplement the spending or cut services. 

AB 1792 (Gomez, Chapter 889, Statutes of 2014):

In 2014, AB 1792 (Gomez) was signed into law, which required the DHCS to annually inform the EDD of the names and social security numbers of all recipients of the Medi-Cal program; required the DHCS to determine the average per-individual cost of state- and federally-funded benefits provided by the Medi-Cal program and inform the EDD of these costs; defined an employer as an individual or organization that employs 100 or more beneficiaries of the Medi-Cal program; required the Department of Finance (DOF) to, after obtaining specified information from EDD, annually transmit to the Legislature and post on the DOF website a report that, among other things, identified the 500 employers in the state with the most number of employees enrolled in a public assistance program ranked by the number of those employees.

However, in 2014, the US Department of Labor (DOL) notified the EDD that federal regulations prohibit making public the information in the AB 1792-required report. The DOL letter essentially stated that federal law requires unemployment compensation (UC)-related information to be kept confidential to avoid deterring either unemployed workers or employers from participating in the UC program. States must bar the disclosure of "any UC information that reveals the name or any identifying particular about any individual or any past or present employer or employing unit, or which could foreseeably be combined with other publicly available information to reveal any such particulars."

However, federal law permits states to disclose confidential UC information to public officials for use in the performance of their official duties if there is a written, enforceable agreement whereby the public official agrees to limit the use of the information. as specified, and take measures to protect its confidentiality, and reimburses the UC agency for all costs of providing the information. For these purposes, "public official" is defined as "an official, agency, or public entity within the executive branch of Federal, State, or local government who (or which) has responsibility for administering or enforcing a law; or an elected official in the Federal, State, or local government." Of particular importance to this bill, the DOL letter specifically noted that the Legislature as a whole does not meet the definition of public official, but individual legislators do.

As a result of these conflicts, the report pursuant to AB 1792 was never created. As noted by other committees, the author should continue discussions to ensure this bill’s language does not run afoul of federal law and meet the same fate as AB 1792.

AB 1792 also protected employees from discrimination and retaliation in the workplace for applying for or being enrolled in the Medi-Cal program. However, AB 1792 had a sunset date of January 1, 2020, and its provisions are now repealed.

According to the author: “Over the past decade, California has expanded health care coverage and grown into the fourth largest economy in the world, proving that we can build prosperity while protecting working families. Today, more than 3 million working Californians rely on Medi-Cal because their employers do not provide affordable health insurance. Nearly one in five jobs in California is held by a worker enrolled in Medi-Cal, representing over $20 billion annually in public spending tied to the workforce.

When companies fail to provide affordable coverage or livable wages, Medi-Cal fills the gap. That means taxpayers are subsidizing a significant share of health care costs for California’s low-wage workforce. That should not happen in the dark. If taxpayers are covering the cost of health care for a company’s workforce, the public deserves to know. SB 1284 brings transparency and accountability to this issue by requiring the California Health and Human Services Agency to publish the names of employers with workers enrolled in Medi-Cal, along with the estimated annual cost to the program associated with those employees.”

The author adds that the measure promotes equity, per HR 39 (Gipson, 2021), in that “SB 1284 seeks to address inequities by highlighting the extent to which low-wage workers rely on Medi-Cal for access to health care. Workers in industries with low rates of employer-sponsored insurance are disproportionately people of color, women, immigrants, and workers employed in service-sector occupations.

Many of these workers and their families depend on Medi-Cal to access essential health services. By increasing transparency, the bill helps identify systemic factors contributing to health coverage disparities and supports informed policy discussions about employer responsibility, wages, and access to affordable health care. The bill may particularly benefit low-income communities, Black and Latino Californians, immigrant communities, and other populations that experience higher rates of uninsurance and are more likely to rely on Medi-Cal for coverage.”

Committee Comment: As mentioned above, nearly half of working Medi-Cal enrollees work for employers with fewer than 50 employees. Given this statistic, the author may wish to consider including all private employers in the bill’s definition of “employer.”

Arguments in Support

SEIU California, co-sponsor of this measure, writes that “research shows that nearly two in three (63%) nondisabled nonelderly adults enrolled in Medi-Cal work, and over 8 in 10 (83%) reported being in a working family. Workers turn to Medi-Cal because they are working in a low-wage industry or the employer-sponsored health care plan premiums and associated out of pocket costs are not affordable for their family.

Employers that pay low wages and offer no or unaffordable benefits shift the costs of doing business onto taxpayers. The social and economic burden created by the lack of health care coverage for some workers and the coverage of other workers through the Medi-Cal program creates a burden on the state, affected workers, and the families of affected workers who suffer ill health and risk financial ruin. Employers that shift the costs of their business expenses onto taxpayers put responsible employers at a competitive disadvantage too, creating an unfair playing field for business in the state.”

Arguments in Opposition

The Greater Coachella Valley Chamber of Commerce writes in opposition that “Many employers in the Coachella Valley - particularly in the agricultural, hospitality, and service sectors - employ large workforces of hourly and seasonal workers who may qualify for Medi-Cal due to household income thresholds entirely unrelated to the employer's coverage offerings. Publicly identifying those employers by name alongside Medi-Cal cost figures attributed to their workers, without context about existing employer-sponsored benefit offerings, creates a misleading public record that unfairly stigmatizes businesses that are complying fully with current law and providing competitive employment opportunities in the Valley. The report is explicitly designed as the legislative predicate for future employer penalty legislation, and cross-agency data sharing between DHCS and EDD involving confidential wage, tax, and enrollment records raises significant privacy and data security concerns that go beyond the bill's public records exemptions.”

Prior and Related Legislation

SB 1054 (Cabaldon) of 2026 would require, beginning July 1, 2027, specified employers and other entities to include in their report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as specified; requires the information to be submitted monthly; and requires the EDD to share this information with various state entities for specified objectives. Pending in this Committee.

SB 1202 (Weber Pierson) of 2026 would require the DHCS to establish a dashboard to track enrollment data related to the implementation of recently-enacted federal enrollment barriers, including work requirements; and would require DHCS, counties, and Medi-Cal managed care plans to undertake linguistically and culturally appropriate outreach efforts to Medi-Cal recipients to educate them on the changes to federal law and maintaining Medi-Cal eligibility. Pending in the Assembly Health Committee.

AB 2161 (Bonta) of 2026 would codify the federal HR 1’s work requirements; would require the DHCS to implement HR 1’s work requirements in California in the least administratively burdensome way to Medi-Cal applicants and recipients as possible; and would prohibit the DHCS from applying HR 1’s work requirements to state-only Medi-Cal populations. Pending in the Senate Health Committee.

AB 2729 (Bonta) of 2026 would create the Employer Responsibility for Medi-Cal Trust Fund consisting of new taxes and deposits, including employer penalties, to fund direct and indirect costs of administering the Medi-Cal program in a manner necessary to prevent the loss of or restore health care coverage, benefits, or access to care, following the passage of HR 1. Pending in the Assembly Appropriations Committee.

AB 1792 (Gomez), Chapter 889, Statutes of 2014, required the DHCS to annually inform the EDD of the names and social security numbers of all recipients of the Medi-Cal program; required the DHCS to determine the average per-individual cost of state- and federally-funded benefits provided by the Medi-Cal program and inform the EDD of these costs; defined an employer as an individual or organization that employs 100 or more beneficiaries of the Medi-Cal program; required the DOF to, after obtaining specified information from EDD, annually transmit to the Legislature and post on the DOF website a report that, among other things, identified the 500 employers in the state with the most number of employees enrolled in a public assistance program ranked by the number of those employees, as specified; and established a January 1, 2020 sunset date.

AB 880 (Gomez) of 2013 would have required employers with 500 or more employees to pay an employer responsibility penalty if their employees working more than 12 hours per week and more than 45 days in a calendar year are enrolled in Medi-Cal based on the Modified Adjusted Gross Income eligibility standard. Failed on the Assembly Floor.

REGISTERED SUPPORT / OPPOSITION:

Support

Service Employees International Union California (Co-Sponsor)
American Federation of State, County and Municipal Employees, AFL-CIO
California Alliance for Retired Americans
California Federation of Labor Unions, AFL-CIO
California Immigrant Policy Center
California Professional Firefighters
Courage California
Health Access California
Teamsters California
United Domestic Workers/American Federation of State, County and Municipal Employees. Local 3930
United Food and Commercial Workers Union - Western States Council

Opposition

Brea Chamber of Commerce
California Attractions and Parks Association
California Chamber of Commerce
California Farm Bureau
California Grocers Association
California League of Food Producers
California Trucking Association
Carlsbad Chamber of Commerce
Colusa County Chamber of Commerce
Corona Chamber of Commerce
Family Business Association of California
Gateway Chambers Alliance
Greater High Desert Chamber of Commerce
Housing Contractors of California
Imperial Valley Regional Chamber of Commerce
Industry Business Council
LA Cañada Flintridge Chamber of Commerce and Community Association
Laguna Niguel Chamber of Commerce
Lodi Chamber of Commerce
Los Angeles Area Chamber of Commerce
Menifee Valley Chamber of Commerce
Mission Viejo Chamber of Commerce
Modesto Chamber of Commerce
Murrieta Wildomar Chamber of Commerce
Newport Beach Chamber of Commerce
Norwalk Chamber of Commerce
Oceanside Chamber of Commerce
Rancho Cordova Area Chamber of Commerce
Santa Ana Chamber of Commerce
Santa Clarita Valley Chamber of Commerce
Santa Maria Valley Chamber of Commerce
Simi Valley Chamber of Commerce
Society of Human Resource Management California
The Greater Coachella Valley Chamber of Commerce
Torrance Area Chamber of Commerce
Yorba Linda Chamber of Commerce

Analysis Prepared by: Erin Hickey / L. & E. / (916) 319-2091

1. Inequities in job-based health coverage for California low-wage workers.” UC Berkeley Labor Center. (2026). https://laborcenter.berkeley.edu/wp-content/uploads/2023/05/Inequities-in-job-based-health-coverage-for-California-low-wage-workers.pdf ↑

2. Projected reduction in Medi-Cal coverage due to federal H.R.1 and 2025-26 State Budget, by county, 2028. UC Berkeley Labor Center. https://laborcenter.berkeley.edu/projected-reduction-in-medi-cal-coverage-due-to-federal-h-r-1-and-2025-26-state-budget-by-county-2028/ ↑

Date of Hearing: June 16, 2026

ASSEMBLY COMMITTEE ON HEALTH

Mia Bonta, Chair

SBPCA Bill Id:SB 1284

Author:(Smallwood-Cuevas) – As Amended Ver:May 14, 2026

SENATE VOTE: 30-9

SUBJECT: Medi-Cal benefits: employer reports.

SUMMARY: This bill requires the Department of Health Care Services (DHCS) to publish a report detailing, for specified large employers, how many employees of the employer are enrolled in Medi-Cal, authorizes data-sharing for this purpose, and prohibits an employer from discouraging an employee or applicant from enrolling in the Medi-Cal program or discriminating, for purposes of employment, based on Medi-Cal enrollment status. Specifically, this bill:

1. Makes the following findings:
   1. Medi-Cal is intended to function as a public safety net and as the payor of last resort, consistent with state and federal law, providing coverage only when other sources of health coverage are unavailable or insufficient;
   2. One in three working Californians rely on Medi-Cal for health coverage, including individuals employed by employers that do not provide affordable employer-sponsored coverage or that pay wages insufficient to meet basic health care needs;
   3. House Resolution (H.R.) 1 (Public Law 119-21) work requirements have brought the intersection of work, employer-sponsored health care coverage, and Medi-Cal back to the forefront. To best administer the Medi-Cal program, policymakers need empirical data, broken down by employer, business type, and industry, to understand if H.R. 1 requirements are leading to changes in the number of persons who are uninsured, covered by employer-sponsored coverage, or enrolled in Medi-Cal; and,
   4. It is the intent of the Legislature in enacting this section to ensure that the Medi-Cal program continues to operate as the payor of last resort and to support the effective administration, oversight, and evaluation of the program by improving transparency regarding the relationship between employment and Medi-Cal enrollment.
2. Defines an “employer” as an employer required to file an annual pay data report with the state Civil Rights Department and that has any employee enrolled in Medi-Cal at any point during the reporting year while employed by the employer.
3. Requires DHCS to annually publish a report that includes all of the following:
   1. The name and address of each employer;
   2. The parent company of the employer, if applicable;
   3. The Employer Identification Number (EIN) of the employer;
   4. The North American Industry Classification System (NAICS) code assigned to the employer;
   5. The total number of employees of that employer;
   6. The total number of employees of that employer enrolled in the Medi-Cal program by category of aid at any point during that reporting year;
   7. The aggregate number of months all employees of that employer received benefits through the Medi-Cal program while employed;
   8. The total number of dependents of employees of that employer enrolled in the Medi-Cal program;
   9. The estimated total annual cost of Medi-Cal services provided to employees, and dependents of employees, of each employer;
   10. A summary of the 100 employers with the highest number of employees and dependents enrolled in the Medi-Cal program; and,
   11. A summary of the 100 employers with the highest percent of employees and dependents enrolled in the Medi-Cal program.
4. Exempts individually identifiable information about employees or Medi-Cal enrollees contained in the report prepared pursuant to 3) above from disclosure under the California Public Records Act and subjects such information to existing confidentiality requirements that apply for purposes of the Medi-Cal program.
5. Allows DHCS and the Employment Development Department (EDD) to enter into data-sharing agreements as necessary to implement the reporting requirement, consistent with state and federal privacy laws.
6. Updates authority for EDD to provide information to DHCS for purposes of the report described in 3) above, as specified.
7. States it shall not be construed to authorize an employer to engage in any conduct against an employee or an applicant for employment in violation of a specified provision of the Labor Code, including, but not limited to, discouraging or preventing an employee from applying for or enrolling in the Medi-Cal program.
8. Prohibits an employer from discharging or in any manner discriminating or retaliating against an employee who applies for, or is enrolled in, Medi-Cal, and prohibits an employer from refusing to hire a person because that person is enrolled in Medi-Cal.
9. Repeals an obsolete code section that allowed DHCS to inform EDD of the names and Social Security Numbers of all recipients of the Medi-Cal program and required DHCS and the Department of Social Services, for purposes of calculating the cost of Medi-Cal and CalFresh provided to employees of employers.

EXISTING FEDERAL LAW:

1. Establishes the Medicaid program to enable each state to furnish medical assistance on behalf of individuals whose income and resources are insufficient to meet the costs of necessary medical services. [Title 42, United States Code (42 U.S.C.) § 1396, et seq.]
2. Requires states to provide safeguards restricting the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the program with limited exceptions for school nutrition programs. [42 U.S.C. § 1396a(a)]
3. Authorizes states, through the Patient Protection and Affordable Care Act (ACA), beginning January 1, 2014, to expand Medicaid (Medi-Cal in California) to individuals who are under 65 years of age, not pregnant, not entitled to, or enrolled for, benefits under Medicare, and whose income does not exceed 133% of the poverty line plus applicable income disregards. [42 U.S.C. § 1396a (a)(10)(A)(i)(VIII), as interpreted by National Federation of Independent Business v. Sebelius (2012), 567 U.S. 519]
4. Requires, beginning January 1, 2027, the Medicaid ACA Expansion population described in 3) above to comply with “community engagement requirements.” Creates mandatory and state-optional exemptions from compliance. Allows states to conduct compliance checks more frequently than as part of eligibility redetermination. Requires states to establish processes and use reliable information available to the state, without requiring, where possible, the applicable individual to submit additional information. Establishes hours and income thresholds that constitute compliance, and procedures for noncompliance. Requires notice and outreach to affected individuals. Allows the federal Health and Human Services (HHS) Secretary to exempt a state from complying with the law for a defined period if the state requests exemption and the state is demonstrating a good faith effort to comply. [42 U.S.C. § 1396a(xx)]
5. Requires an applicable large employer, defined as an employer with an average of 50 or more full-time equivalent employees in a calendar year, to offer its full-time employees and their dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan or be subject to an assessable payment if any of their full-time employees enroll in a state-based health insurance exchange. [26 U.S.C. § 4980H]

EXISTING STATE LAW:

1. Establishes the Medi-Cal program, administered by DHCS, under which qualified low-income individuals receive health care services. [Welfare and Institutions Code (WIC) § 14000, et seq.]
2. Requires an individual’s information given for purposes of receiving Medi-Cal to be kept confidential and not open to examination other than for purposes directly connected with the administration of the program. Limits the use of Medi-Cal applicant and recipient information to encompass those activities and responsibilities in which DHCS and its agents are required to engage in to ensure effective program operations, which include but are not limited to, establishing eligibility and methods of reimbursement; determining the amount of medical assistance; providing services for recipients; conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the Medi-Cal program; and conducting a legislative investigation or audit related to the administration of the Medi-Cal program, with limited exceptions for the coordination of other benefits, namely school nutrition programs. [WIC § 14100.2]
3. Exempts confidential Medi-Cal applicant or recipient information from disclosure pursuant to the California Public Records Act. [Government Code (GOV) § 7930.170]
4. Requires a private employer that has 100 or more employees to submit a pay data report to the Department of Civil Rights containing information about the number of employees, broken down by specified demographic categories, in each type of position and pay range, as specified. [GOV § 12999]
5. Establishes the EDD within the Labor and Workforce Development Agency. EDD is responsible for, among other duties, the administration of the Unemployment Insurance (UI) and Disability Insurance programs. (Unemployment Insurance Code (UIC) § 301)
6. Establishes the UI program as a joint state/federal program, administered by EDD that provides weekly unemployment insurance payments for workers who lose their job through no fault of their own. (UIC §§100-144)
7. Requires, among other things, an employer to file a report of contributions, a quarterly return, and a report of wages paid to the employer’s worker, as well as information on new employees, as specified. (UIC § 1088, § 1088.5)
8. Authorizes EDD to share wage and employment data, under specified conditions, for a variety of purposes, including the evaluation of workforce programs, as specified, which enumerates the programs for which data can be shared. (UIC § 1095)

FISCAL EFFECT: According to the Senate Committee on Appropriations:

1. Unknown costs for the EDD, likely one-time General Fund (GF) costs of $100,000 and ongoing GF costs of $100,000, for administration.
2. Unknown ongoing GF costs, potentially hundreds of thousands, for DHCS to provide the reports.

COMMENTS:

1. PURPOSE OF THIS BILL. According to the author, over the past decade, California has expanded health care coverage and grown into the fourth largest economy in the world, proving that we can build prosperity while protecting working families. Today, the author notes, more than three million working Californians rely on Medi-Cal because their employers do not provide affordable health insurance. Nearly one in five jobs in California is held by a worker enrolled in Medi-Cal, representing over $20 billion annually in public spending tied to the workforce. The author argues that when companies fail to provide affordable coverage or livable wages, Medi-Cal fills the gap. That means taxpayers are subsidizing a significant share of health care costs for California’s low-wage workforce. That should not happen in the dark. The author states that if taxpayers are covering the cost of health care for a company’s workforce, the public deserves to know. The author concludes that this bill brings transparency and accountability to this issue by requiring DHCS to publish the names of employers with workers enrolled in Medi-Cal, along with the estimated annual cost to the program associated with those employees.
2. BACKGROUND.
   1. Employer Sponsored Insurance (ESI). Unlike many other nations, the U.S. relies on voluntary, private health insurance as the primary source of coverage for most residents who are not elderly, poor or disabled. According to KFF, ESI is by far the most common source of private health insurance. There are two primary reasons for this. The first is that providing health insurance through the workplace is efficient, with advantages relating both to risk management and to the costs of administration. The second is that contributions towards premiums by employers and (in most cases) by employees are not subject to income or payroll taxes, providing a substantial federal and state subsidy towards the costs of ESI.

Overall, 60% of people under age 65, or about 165.6 million people nationwide, had employment-sponsored health insurance in 2025. The level of coverage varies significantly with income and other factors, even among working families.

According to research by the U.C. Berkeley Labor Center (Labor Center), workers paid low wages are less likely to have coverage through their job. They may have no offer of coverage, with small firms under 50 employees less likely to offer coverage. They may be ineligible because of part-time work or because they were recently hired and are subject to a waiting period. Finally, coverage may be unaffordable. The average annual worker premium contribution in 2025 was $1,303, which is 8% of income for a person at the federal poverty level. For family coverage, the average annual worker premium contribution is $7,312, making this 23% of average income just for premiums. These plans often have high deductibles when health care is actually needed, meaning people have to pay thousands of dollars for their health care out of pocket, in addition to their premium payments, before getting any help from their insurance plan.

• 1. Low-Wage Workers Enrolled in Medi-Cal. 3.6 million California workers ages 19-64 are enrolled in Medi-Cal, excluding 900,000 self-employed workers. The Labor Center estimates $36 billion will be spent to provide Medi-Cal to these workers, including state and federal spending, in Fiscal Year 2026-27. Certain industries are more likely to employ individuals who are also enrolled in Medi-Cal, including agriculture, forestry, fishing, and mining (35% of workers in this industry are on Medi-Cal); restaurants, bars, and food service (35%); administrative and building services, and retail (26%). Medi-Cal enrollees work across a range of firm sizes, with 27% of Medi-Cal enrolled workers working in companies with over 1,000 employees, 17% working in companies with 101-999 employees, and 7% working in companies with 51-100 employees. Nearly half of working Medi-Cal enrollees work in businesses with under 50 employees.
  2. Work or Community Engagement Requirements under New H.R. 1 Eligibility Rules. H.R. 1 of 2025, officially titled the “One Big Beautiful Bill Act,” includes significant Medicaid-related changes that reduce federal investment in Medicaid, including new eligibility rules for the population of adults without dependent children who gained health care coverage through the ACA Expansion. More stringent eligibility rules result in cost savings from individuals losing Medicaid coverage. H.R. 1 represents the largest-ever cut to the Medicaid program, with savings from Medicaid eligibility-related and financing changes projected to partially offset the loss of federal revenue associated with tax cuts that disproportionately benefit the wealthy and corporations.

Section 71119 of federal H.R. 1 with certain exceptions, requires the ACA expansion population—generally, adults ages 19 through 64 without dependent children— to engage in a minimum of work or community engagement requirements (called “community engagement requirements” in H.R. 1) beginning in 2027. This means an individual needs to document at least 80 hours per month of work, community service, or job training to keep Medi-Cal coverage. The law outlines mandatory and short-term hardship exemptions, which must be verified every 6 months.

Although rhetoric related to work requirements indicates these policies are designed to support employment, evidence from other states and programs consistently shows that significant coverage losses under policies similar to H.R. 1’s occur because individuals face administrative barriers, paperwork burdens, and documentation challenges even when they remain eligible.

Furthermore, data analyzed by KFF and reported by the Labor Center demonstrates that most Medi-Cal members who can work are already working. Data from 2023 show that 63% of non-disabled, non-elderly adults reported working full-time or part-time, 14% were not working due to being a caretaker for a family member, 8% were students, and 7% reported a disability or other illness that was not eligible for a federal disability designation. Missed notices, unstable housing, limited internet access, language barriers, or confusion about reporting requirements can result in termination of coverage even when individuals meet eligibility requirements.

Ultimately, DHCS estimates 1.4 million Medi-Cal members will lose coverage by June 2028 as a result of the federally imposed work requirements. DHCS projects this coverage loss will significantly drive up California’s uninsured rate and raise costs for hospitals and clinics treating uninsured patients.

1. SUPPORT. According to co-sponsors California Federation of Labor Unions, AFL-CIO; End Poverty in California; SEIU California; and United Food and Commercial Workers Western States Council, H.R. 1 creates the urgency to revisit corporate accountability in health coverage, but the broader interplay of work, poverty, and public benefits long predates this moment. Co-sponsors assert workers turn to Medi-Cal because they are working in a low-wage industry or the employer-sponsored health care plan premiums and associated out of pocket costs are not affordable for their family. Co-sponsors argue that employers that pay low wages and offer no or unaffordable benefits shift the costs of doing business onto taxpayers, and this bill is a critical step forward to promote a deeper understanding of the dynamics of health care coverage and employment, and the related economic impacts on Californians, businesses, and the state budget.
2. OPPOSITION. Southwest California Legislative Council (SWCLC), an alliance of Riverside County Chambers of Commerce, opposes this bill. They assert that cross-agency sharing of confidential employee wage and enrollment records raises significant privacy and data security risks, and the annual reporting obligations imposed on multiple state departments generate administrative costs without demonstrated offsetting benefits. SWCLC argues this bill creates reputational harm and new administrative burdens for businesses. The California Chamber of Commerce asserts in opposition that this bill will create a government-operated public shaming registry built on incomplete, decontextualized data that says nothing definitive about how an employer treats its workforce.
3. RELATED LEGISLATION.
   1. SB 1202 (Weber Pierson) would require DHCS to establish a dashboard to track enrollment data related to the implementation of recently enacted federal enrollment barriers, including work requirements. Would require DHCS, counties, and Medi-Cal managed care plans to undertake linguistically and culturally appropriate outreach efforts to Medi-Cal recipients to educate them on the changes to federal law and maintaining Medi-Cal eligibility. SB 1202 is pending in the Assembly Appropriations Committee.
   2. AB 2161 (Bonta) would codify H.R. 1’s work requirements; would require DHCS to implement H.R. 1’s work requirements in California in the least administratively burdensome way to Medi-Cal applicants and recipients as possible; and would limit the application of H.R. 1’s work requirements to Medi-Cal populations required to comply under federal law. AB 2161 is pending in the Senate Health Committee.
   3. AB 2729 (Bonta) would create the Employer Responsibility for Medi-Cal Trust Fund consisting of new taxes and deposits, including employer penalties, to fund direct and indirect costs of administering the Medi-Cal program in a manner necessary to prevent the loss of or restore health care coverage, benefits, or access to care, following the passage of H.R. 1. AB 2729 is pending in the Assembly Appropriations Committee.
4. PREVIOUS LEGISLATION.
   1. AB 1792 (Gomez), Chapter 889, Statutes of 2014, requires the Department of Finance to publish an annual report listing the 500 employers in the state with the most number of employees enrolled in a public assistance program, including Medi-Cal, ranked by the number of those employees after receiving the relevant information from EDD, DHCS, and the Department of Social Services. Provisions of AB 1792 similar to this bill were sunsetted in 2020.
   2. AB 880 (Gomez) of 2013, would have required employers with 500 or more employees to pay an employer responsibility penalty if their employees working more than 12 hours per week and more than 45 days in a calendar year are enrolled in Medi-Cal. AB 880 failed on the Assembly Floor.
5. DOUBLE REFERRAL. This bill is double-referred; upon passage of this committee, it will be referred to the Assembly Labor and Employment Committee.
6. POLICY COMMENT. In 2014, the Department of Finance encountered challenges implementing AB 1792 (Gomez), described above, because of concerns about using data collected for unemployment insurance-related uses for purposes of the public report required by that bill. However, at least three other states have mandated similar reports (Nevada, Washington, and New Jersey), and these states all rely on quarterly wage data reported by their labor and workforce departments. Leveraging existing data sources, as this bill does, is the most efficient way to implement this bill. As this bill moves forward, the author may wish to mitigate risk of implementation barriers by ensuring state departments have appropriate authority to use data to create the desired report.

REGISTERED SUPPORT / OPPOSITION:

Support

California Federation of Labor Unions, AFL-CIO (co-sponsor)
End Poverty in California (EPIC) (co-sponsor)
Service Employees International Union (SEIU), California State Council (co-sponsor)

United Food and Commercial Workers (UFCW), Western States Council (co-sponsor)
American Federation of State, County and Municipal Employees, AFL-CIO
California Alliance for Retired Americans
California LGBTQ Health and Human Services Network
California Physicians Alliance
California Professional Firefighters
CFT – a Union of Educators & Classified Professionals, AFT, AFL-CIO
Community Health Partnership
Courage California
Health Access California
Teamsters California
United Domestic Workers/AFSCME Local 3930
Western Center on Law & Poverty, Inc.

Opposition

California Chamber of Commerce

Southwest California Legislative Council

Analysis Prepared by: Lisa Murawski / HEALTH / (916) 319-2097

 THIRD READING  

Bill No: SB 1284

Author: Smallwood-Cuevas (D), et al.

Amended: 5/14/26

Vote: 21

SENATE HEALTH COMMITTEE: 8-1, 4/15/26

AYES: Weber Pierson, Caballero, Durazo, Gonzalez, Padilla, Pérez, Rubio, Smallwood-Cuevas

NOES: Grove

NO VOTE RECORDED: Valladares, Menjivar

SENATE LABOR, PUB. EMP. & RET. COMMITTEE: 4-1, 4/22/26

AYES: Smallwood-Cuevas, Cortese, Durazo, Laird

NOES: Strickland

SENATE APPROPRIATIONS COMMITTEE: 5-2, 5/14/26

AYES: Cervantes, Cabaldon, Grayson, Richardson, Wahab

NOES: Seyarto, Dahle

SUBJECT: Medi-Cal benefits: employer reports

SOURCE: California State Council of Service Employees International Union

DIGEST:

This bill requires the Department of Health Care Services to prepare an annual report of all private employers with 100 or more employees that calculates the estimated cost to the Medi-Cal program for each identified employee and employee’s dependents receiving Medi-Cal.

ANALYSIS:

Existing federal law:

1. Establishes the Medicaid program to enable each state to furnish medical assistance on behalf of individuals whose income and resources are insufficient to meet the costs of necessary medical services. [Title 42 United States Code (USC) §1396, et seq.]
2. Requires states to provide safeguards restricting the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the program with limited exceptions for school nutrition programs. [42 USC §1396a]
3. Starting January 1, 2027, as enacted by H.R. 1 (Public Law No. 119-21), requires individuals with incomes below 138% of the federal poverty level who are under age 65, not pregnant, and have no Medicaid-eligible dependents to demonstrate community engagement through at least 80 hours of work, community service, or participation in a work program, or at least half-time participation in an educational program, or have a monthly income not less than 80 times the federal minimum wage in a specified month. Provides for some exceptions to this requirement. This is referred to as the “work and community engagement” requirements. [42 USC §1396a]
4. Requires an applicable large employer, defined as an employer with an average of 50 or more full-time equivalent employees in a calendar year, to offer its full-time employees and their dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan or be subject to an assessable payment if any of their full-time employees enroll in a state-based health insurance exchange. [26 USC §4980H]

Existing state law:

1. Establishes the Medi-Cal program, administered by the Department of Health Care Services (DHCS), under which qualified low-income individuals receive health care services. [Welfare and Institutions Code (WIC) §14000, et seq.]
2. Requires an individual’s information given for purposes of receiving Medi-Cal to be kept confidential and not open to examination other than for purposes directly connected with the administration of the program. Limits the use of Medi-Cal applicant and recipient information to encompass those activities and responsibilities in which DHCS and its agents are required to engage in to ensure effective program operations, which include but are not limited to, establishing eligibility and methods of reimbursement; determining the amount of medical assistance; providing services for recipients; conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the Medi-Cal program; and conducting a legislative investigation or audit related to the administration of the Medi-Cal program, with limited exceptions for the coordination of other benefits, namely school nutrition programs. [WIC §14100.2]
3. Exempts confidential Medi-Cal applicant or recipient information from disclosure pursuant to the California Public Records Act [Government Code (GOV) §7930.170]
4. Requires private employers with 100 or more employees to submit and annual pay data report with specified information on employees including total earnings hours worked of each employee, total employees, and the employer’s North American Industry Classification System code. [GOV §12999]

This bill:

1. Requires the Employment Development Department (EDD) to share information based on personal income tax wage withholding and the disability insurance program that identifies all employers in California required to file an annual pay data report under existing law, and that have employees who receive benefits from the Medi-Cal program while employed in the last calendar year, with DHCS, to the extent not prohibited by federal law.
2. Requires DHCS, after obtaining the above information, to prepare a report to the Legislature by September 1, 2027, and annually thereafter, that includes:
3. The employer’s name and address; parent company, if applicable; Employer Identification Number; North American Industry Classification System code; total number of employees; total number of employees enrolled in Medi-Cal by aid category at any point during the reporting year; the aggregate number of months all employees of that employer received Medi-Cal benefits while employed; the total number of employee dependents enrolled in Medi-Cal; and the total annual cost of Medi-Cal services provided to employees, and dependents of employees, of each employer;
4. A summary of the 100 employers with the highest number of employees and dependents enrolled in Medi-Cal and of the 100 employers with the highest percentage of employees and dependents enrolled in Medi-Cal; and,
5. Requires any public reporting to adhere to DHCS’s existing guidelines on data deidentification, exempts individually identifiable information about employees or Medi-Cal enrollees contained in the report from disclosure under the California Public Records Act, and makes legislative findings about the importance of the privacy of Medi-Cal enrollees.
6. Prohibits authorization or publication of identifying information of employees enrolled in the Medi-Cal program.
7. Authorizes DHCS and EDD to enter into data-sharing agreements necessary to implement this bill, consistent with state and federal privacy laws.
8. Repeals the sunsetted law requiring DHCS and DSS to share with EDD the social security numbers of all Medi-Cal and CalFresh recipients.
9. Prohibits an employer from discriminating, retaliating, or discharging an employee who applies for or is enrolled in Medi-Cal, or refusing to hire a person on the basis of their enrollment in Medi-Cal.
10. States legislative findings that Medi-Cal is intended to function as a public safety net and payor of last resort providing coverage when other sources or health coverage are unavailable or insufficient; that one in three Californians rely on Medi-Cal for coverage, including individuals employed by employers that do not provide affordable health coverage or pay sufficient wages to meet basic health care needs; that policymakers need empirical data to understand if H.R. 1 requirements are leading to changes in the number of persons who are uninsured, covered by employer-sponsored coverage, or enrolled in Medi-Cal; and that this bill is intended to ensure that the Medi-Cal program continues to operate as the payor of last resort and to support the effective administration, oversight, and evaluation of the program by improving transparency regarding the relationship between employment and Medi-Cal enrollment.

Comments

According to the author of this bill:

Over the past decade, California has expanded health care coverage and grown into the fourth largest economy in the world, proving that we can build prosperity while protecting working families. Today, more than three million working Californians rely on Medi-Cal because their employers do not provide affordable health insurance. Nearly one in five jobs in California is held by a worker enrolled in Medi-Cal, representing over $20 billion annually in public spending tied to the workforce. When companies fail to provide affordable coverage or livable wages, Medi-Cal fills the gap. That means taxpayers are subsidizing a significant share of health care costs for California’s low-wage workforce. That should not happen in the dark. If taxpayers are covering the cost of health care for a company’s workforce, the public deserves to know. This bill brings transparency and accountability to this issue by requiring CHHS to publish the names of employers with workers enrolled in Medi-Cal, along with the estimated annual cost to the program associated with those employees.

Background

Medi-Cal recipients and work. According to a January 2025 report by the California Health Care Foundation, almost one in five of all California workers were enrolled in Medi-Cal in 2023. In some industries, such as agriculture and the restaurant industry, that percentage is considerably higher, 35% and 36% respectively. Other industries with higher-than-average numbers of workers on Medi-Cal include administrative and building services; other services; retail; transportation and warehousing; arts, entertainment, recreation, and accommodation; and construction. Of all nondisabled, nonelderly adults (age 19-64) in Medi-Cal, 62% reported working full-time or part-time in 2021 (the latest data available) and 82% reported being in a working family where at least one person is working full- or part-time. These workers turn to Medi-Cal because low-wage workers are less likely to be offered job-based coverage than higher-income workers or may not be able to afford the coverage they are offered at work. The report also states that many are seasonal or hourly workers with fluctuating income or may be between jobs. In addition, for those that do not work, 14% reported being a caretaker, 6% said they were going to school, and 9% reported an illness or disability, though likely not meeting the strict requirements for federal disability benefits.

H.R. 1 and work requirements. H.R. 1, the federal budget reconciliation bill passed in July 2025, makes a number of changes primarily to lower taxes, increase funding for immigration control and national defense, and restrict access to and funding for SNAP and Medicaid. More relevant to this bill is the new “community engagement requirement” (or “work requirement”) that requires nondisabled adults between the ages of 19 and 65 who gained coverage through the Affordable Care Act (“ACA expansion adults”) to demonstrate 80 hours of work, education, or volunteer activities a month to be eligible for Medicaid coverage, unless they qualify for a limited exemption. Because the work requirement is calculated based on federal minimum wage, many may be exempt if they earn at least $580 in monthly income. States are required to verify that an individual meets the community engagement requirements twice a year, starting January 1, 2027. This provision was included to reduce state Medicaid rolls. The UC Berkeley Labor Center estimates that 1.87 million adults will lose coverage due to the work requirements. According to an estimate from DHCS given in a presentation Implementation Plan for New Eligibility and Enrollment Changes Under H.R. 1 on February 5, 2026, by June 2028, 1.4 million recipients will have lost Medi-Cal coverage due to this requirement. Both of these estimates assume that a large number of people to whom the requirements apply will be exempted and that outreach efforts will be largely successful in reaching people who do work and enabling them to comply. However, it is anticipated that some people who are working will lose coverage under this requirement due to the administrative burden of reporting work.

Employer-shared responsibility penalties. According to the Internal Revenue Service (IRS), the ACA requires most employers with an average of 50 or more full-time equivalent employees in a calendar year to offer their full-time employees minimum essential health coverage that is affordable and provides a minimum value, as defined, to their employees or to potentially make an employer shared responsibility payment to the IRS. These provisions are also known as the “employer mandate.” Employers are subject to this provision: 1) if they do not offer minimum essential coverage to at least 95% of their employees and have at least one full-time employee who receives premium tax credits through the state’s health insurance exchange (e.g. Covered California), or 2) if they do offer coverage to at least 95% of their employees, but a full-time employee gets premium tax credits because that employee was not offered coverage or the coverage was insufficient. In the first case, the 2024 amount of the penalty was $2,970 per employee, with the first 30 employees excluded from the calculation. In the second case, the 2024 amount of the penalty was $4,460 for each full-time employee receiving premium tax credits.

Notably, there is only shared responsibility for employers if one of the employer’s full-time employees enrolls in Covered California and gets premium tax credits. If the employee is part-time, including part-time at multiple jobs, or their pay and household size make them ineligible for premium tax credits whether because they earn too much or too little, the employer pays nothing. This bill requires counting the number of employees and dependents that an employer has who receive Medi-Cal and calculating the cost to the state but does not impose a penalty.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: Yes

According to the Senate Appropriations Committee this bill would have the following fiscal impacts:

• EDD estimates one-time General Fund costs of $100,000 and ongoing General Fund costs of $100,000 for administration.
• Unknown ongoing General Fund costs, potentially hundreds of thousands, for DHCS to provide the reports.

SUPPORT: (Verified 5/14/2026)

California State Council of Service Employees International Union (source)

American Federation of State, County, and Municipal Employees

California Federation of Labor Unions

California Federation of Teachers

California LGBTQ Health and Human Services Network

California Physicians Alliance

California Professional Firefighters

Community Health Partnership

Courage California

End Poverty in California

Health Access California

Teamster California

UFCW Western States Council

United Domestic Workers/AFSCME Local 3930

OPPOSITION: (Verified 5/14/2026)

California Chamber of Commerce

Tri-County Chamber Alliance

ARGUMENTS IN SUPPORT: The source of this bill, the California State Council of Service Employees International Union, write that employers that pay low wages and offer no or unaffordable benefits shift the costs of doing business onto taxpayers and also put responsible employers at a competitive disadvantage. They explain that as H.R. 1 work requirements have brought the intersection of work, employer-sponsored health care, and Medi-Cal back to the forefront, policymakers should have empirical data to understand if H.R. 1 requirements are leading to changes in the number of uninsured, number of persons covered by employer-sponsored coverage, and enrolled in Medi-Cal by business type and industry. The California Federation of Labor Unions, AFL-CIO point to data on the country’s largest low-wage employers showing median worker pay declining and high reliance on Medicaid while CEOs of the companies earned an average of 900 times more than the median worker. They also point out that Massachusetts published a similar report beginning in 2006 that was used to analyze program utilization, financing of publicly subsidized programs, identify trends, and track the effect of policies on the use of public programs.

ARGUMENTS IN OPPOSITION: The Tri-County Chamber Alliance write that publicly identifying employers by name alongside Medi-Cal program costs creates a reputational targeting mechanism designed to build political pressure for future employer tax and penalty legislation. Employers who offer health coverage may still have workers who qualify for Medi-Cal for other reasons, and attributing full program costs to those employers without context produces misleading and potentially damaging public disclosures. Cross-agency data sharing involving employee enrollment records, wage data, and benefit usage also raises significant privacy and data security risks beyond what the bill’s public records exemptions adequately address. They state that this report is an explicit precursor to employer penalty legislation, and the data it produces is intended to justify future mandates on employers whose workers use public health programs. The California Chamber of Commerce oppose on similar grounds and point to a number of factors that could lead to Medi-Cal enrollment but have nothing to do with employer malfeasance such as employee preference for the comprehensive benefits of Medi-Cal, the part-time or seasonal nature of the work, new hires in a waiting period for employer benefits, and industries paying low wages whose employees chose Medi-Cal regardless of the employer’s offerings.

Prepared by: Jen Flory / HEALTH / (916) 651-4111

5/18/26 15:25:42

**** END ****

SENATE COMMITTEE ON

Senator Sabrina Cervantes, Chair

2025 - 2026 Regular Session

SB 1284 (Smallwood-Cuevas) - Medi-Cal benefits: employer reports

Bill Summary:

SB 1284 would require the Department of Health Care Services (DHCS) to prepare a report that includes information, as specified, regarding private employers that have 100 or more employees and have any employees enrolled in the Medi-Cal program, as specified.

*********** ANALYSIS ADDENDUM – SUSPENSE FILE ***********

The following information is revised to reflect amendments

adopted by the committee on May 14, 2026

Fiscal Impact:

• Unknown costs for the Employment Development Department (EDD), likely one-time General Fund costs of $100,000 and ongoing General Fund costs of $100,000, for administration.
• Unknown ongoing General Fund costs, potentially hundreds of thousands, for DHCS to provide the reports.

Author Amendments:

Clarify the definition of “employer” to mean an employer required to file an annual pay data report under existing law, clarify data required in the DHCS reports, and delay the due date for the first report from July 1, 2027 to September 1, 2027.

-- END --

SENATE COMMITTEE ON

Senator Sabrina Cervantes, Chair

2025 - 2026 Regular Session

SB 1284 (Smallwood-Cuevas) - Medi-Cal benefits: employer reports

Bill Summary:

SB 1284 would require the Department of Health Care Services (DHCS) to prepare a report that includes information, as specified, regarding private employers that have 100 or more employees and have any employees enrolled in the Medi-Cal program, as specified.

Fiscal Impact:

• The Employment Development Department (EDD) estimates one-time General Fund costs of $100,000 and ongoing General Fund costs of $100,000 for administration.
• Unknown ongoing General Fund costs, potentially hundreds of thousands, for DHCS to provide the reports.

Background:

Employer-Shared Responsibility. The federal Affordable Care Act (ACA) requires most employers with an average of 50 or more full-time equivalent employees in a calendar year to offer their full-time employees minimum essential health coverage that is affordable and provides a minimum value, as defined, to their employees or to potentially make an employer-shared responsibility payment to the Internal Revenue Service (IRS).

H.R. 1 (Public Law No. 119-21) Medicaid Work Requirements. The Medi-Cal program, administered by DHCS, provides health care services to qualified low-income individuals. The Medi-Cal program is primarily governed by the federal Medicaid program. H.R. 1 made a number of significant changes that restrict eligibility and funding for the federal Medicaid program. The new “community engagement requirements” (or “work requirements”) require nondisabled adults between the ages of 19 and 65 who gained coverage through the ACA (“ACA expansion adults”) to demonstrate 80 hours of work, education, or volunteer activities in order to be eligible for Medicaid coverage, unless they qualify for a limited exemption.

Proposed Law:

• Define for purposes of the bill’s provisions, “employer” to mean a private employer that has 100 or more employees and has any employees enrolled in the Medi-Cal program at any point during the reporting year while employed by the employer.
• Require DHCS after obtaining information from the EDD, as specified, to prepare a report that includes all of the following:
  • The name and address of each employer.
  • The parent company of the employer, if applicable.
  • The Employer Identification Number (EIN) of the employer.
  • The North American Industry Classification System (NAICS) code assigned to the employer.
  • The total number of employees of that employer.
  • The number of employees of that employer enrolled in the Medi-Cal program by category of aid at any point during that reporting year.
  • The number of months the employee received benefits through the Medi-Cal program while employed.
  • The number of dependents of employees of that employer enrolled in the Medi-Cal program.
  • The estimated annual cost to the Medi-Cal program provided to each identified employer’s employees and their dependents enrolled in the Medi-Cal program.
  • A summary of the 100 employers with the highest number of employees and dependents enrolled in the Medi-Cal program.
  • A summary of the 100 employers with the highest percent of employees and dependents enrolled in the Medi-Cal program.
• Require DHCS to submit the report to the Legislature no later than July 1, 2027, and annually thereafter; and require that any public reporting must adhere to the department’s existing guidelines on data deidentification.
• Provide that individually identifiable information about employees or Medi-Cal enrollees contained in the report is exempt from disclosure under the California Public Records Act.
• Authorize DHCS and EDD to enter into data-sharing agreements as necessary for implementation, consistent with state and federal privacy laws.
• Prohibit an employer from discharging or in any manner discriminating or retaliating against an employee who applies for, or is enrolled in, the Medi-Cal program; and prohibit an employer from refusing to hire a person because that person is enrolled in the Medi-Cal program.

Related Legislation:

SB 987 (Weber Pierson) would create the California Health Access Fund and require that moneys in the fund be used to ensure that California residents losing health care coverage due to the impacts of H.R. 1 can continue to receive health care services. The bill is currently on the suspense file in this committee.

SB 1202 (Weber Pierson) would require DHCS to establish a dashboard to track Medi-Cal enrollment data related to the implementation of H.R. 1. The bill is currently on the suspense file in this committee.

SB 1252 (Durazo) would require DHCS to take all necessary actions to prevent abrupt loss of health care coverage for individuals, as described, due to federal policy changes, state enrollment freezes, the imposition of premiums, work requirements, or administrative barriers. The bill is currently in the Senate Health Committee.

AB 2161 (Bonta) would include provisions related to H.R. 1’s work requirements and eligibility redetermination requirements. The bill is currently in the Assembly Appropriations Committee.

AB 2729 (Bonta) would create the Employer Responsibility for Medi-Cal Trust Fund to fund the costs of administering the Medi-Cal program in a manner necessary to prevent loss of or to restore health care coverage, benefits, or access to care following the passage of H.R. 1 and subsequent state budget actions. The bill is currently in the Assembly Appropriations Committee.

-- END --

SENATE COMMITTEE ON LABOR, PUBLIC EMPLOYMENT AND RETIREMENT

Senator Lola Smallwood-Cuevas, Chair

2025 - 2026 Regular

Bill No: SB 1284 Hearing Date: April 22, 2026

SUBJECT: Medi-Cal benefits: employer reports

KEY ISSUE

This bill requires California Health and Human Services (CHHS), after obtaining specified information from Employment Development Department (EDD), to prepare and submit a report, as specified, that identifies employers in California that employ 50 or more employees and that have any employees who receive benefits from the Medi-Cal program, as specified, while employed in the past calendar year.

ANALYSIS

Existing federal law:

1. Establishes the Medicaid program to enable each state to furnish medical assistance on behalf of individuals whose income and resources are insufficient to meet the costs of necessary medical services. (42 USC §1396, et seq.)
2. Requires states to provide safeguards restricting the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the program with limited exceptions for school nutrition programs. (42 USC §1396(a))
3. Starting January 1, 2027, as enacted by H.R. 1 (Public Law No. 119-21), requires individuals with incomes below 138% of the federal poverty level who are under age 65, not pregnant, and have no Medicaid-eligible dependents to demonstrate community engagement through at least 80 hours of work, community service, or participation in a work program, or at least half-time participation in an educational program, or have a monthly income not less than 80 times the federal minimum wage in a specified month. Provides for some exceptions to this requirement. This is referred to as the “work and community engagement” requirements. (42 USC §1396(a))
4. Requires an applicable large employer, defined as an employer with an average of 50 or more full-time equivalent employees in a calendar year, to offer its full-time employees and their dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan or be subject to an assessable payment if any of their full-time employees enroll in a state-based health insurance exchange. (26 USC §4980(h))

Existing state law:

1. Establishes the California Health and Human Services Agency (CHHS), which consists of the following departments and offices: Aging, Child Support Services, Community Services and Development, Developmental Services, Health Care Access and Information, Health Care Services (DHCS), Managed Health Care, Public Health, Rehabilitation, Social Services (DSS), State Hospitals, the Center for Data Insights and Innovation, the Emergency Medical Services Authority, the Office of Technology and Solutions Integration, the Office of Law Enforcement Support, the Office of the Surgeon General, the Office of Youth and Community Restoration, and the State Council on Developmental Disabilities. (Government Code §12803 and §12806)
2. Establishes the Medi-Cal program, administered by DHCS, under which qualified low-income individuals receive health care services. (Welfare and Institutions Code §14000, et seq.)
3. Requires an individual’s information given for purposes of receiving Medi-Cal to be kept confidential and not open to examination other than for purposes directly connected with the administration of the program. Limits the use of Medi-Cal applicant and recipient information to encompass those activities and responsibilities in which DHCS and its agents are required to engage in to ensure effective program operations, which include but are not limited to, establishing eligibility and methods of reimbursement; determining the amount of medical assistance; providing services for recipients; conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the Medi-Cal program; and conducting a legislative investigation or audit related to the administration of the Medi-Cal program, with limited exceptions for the coordination of other benefits, namely school nutrition programs. (Welfare and Institutions Code §14100.2)
4. Establishes the EDD within the Labor and Workforce Development Agency (LWDA). EDD is responsible for, among other duties, the administration of the Unemployment Insurance (UI) and Disability Insurance (DI) programs. (Unemployment Insurance Code §301)
5. Authorizes EDD to share wage and employment data, under specified conditions, for specified purposes and enumerates the programs for which data can be shared. (Unemployment Insurance Code §1095)

This bill:

1. Requires the EDD Director to permit the use of any information in their possession to the extent necessary, as specified, to enable the California Health and Human Services Agency (CHHS) to prepare and submit the report required, as specified, that identifies all employers in California that employ 50 or more employees and that have any employees who receive benefits from the Medi-Cal program, as specified, while employed in the past calendar year.
   1. Provides that the information used for this purpose is limited to information from the administration of personal income tax wage withholding, as specified, and the disability insurance program and may be disclosed to CHHS only for the purpose of preparing and submitting the report and only to the extent not prohibited by federal law.
2. Defines, for purposes of this section, “employer” to mean an individual or type of organization that employs for wages and salary 50 or more employees and has any employees enrolled in the Medi-Cal program, as specified, at any point during the reporting year while employed by the employer.
3. Requires CHHS, after obtaining the information from EDD, as specified, to prepare a report that includes all of the following:
   1. The name and address of each employer.
   2. The parent company of the employer, if applicable.
   3. The Employer Identification Number (EIN) of the employer.
   4. The North American Industry Classification System (NAICS) code assigned to the employer.
   5. The total number of employees of that employer.
   6. The number of employees of that employer enrolled in the Medi-Cal program by category of aid at any point during that reporting year.
   7. The number of months the employee received benefits through the Medi-Cal program while employed.
   8. The number of dependents of employees of that employer enrolled in the Medi-Cal program.
   9. The estimated annual cost to the Medi-Cal program provided to each identified employer’s employees and their dependents enrolled in the Medi-Cal program.
   10. A summary of the 100 employers with the highest number of employees and dependents enrolled in the Medi-Cal program and a summary of the 100 employers with the lowest number of employees and dependents enrolled in the Medi-Cal program.
   11. A summary of the 100 employers with the highest percent of employees and dependents enrolled in the Medi-Cal program and a summary of the 100 employers with the lowest percent of employees and dependents enrolled in the Medi-Cal program.
4. Requires CHHS to submit the prepared report to the Legislature no later than July 1, 2027, and annually thereafter, as specified.
5. Provides that individually identifiable information about employees or Medi-Cal enrollees contained in the prepared report, as specified, is exempt from disclosure under the California Public Records Act.
6. Provides that nothing in this section will be construed to permit authorization or publication of identifying information of employees enrolled in the Medi-Cal program.
7. Authorizes CHHS and EDD to enter into data-sharing agreements as necessary to implement this section, consistent with state and federal privacy laws.
8. Repeals an outdated provision, as specified, that sunset on January 1, 2020 and is now repealed.
9. Makes a finding and declaration that in order to ensure adequate privacy protections for Medi-Cal enrollees and beneficiaries, it is necessary for their individually identifiable information to be kept confidential.
10. Provides that no reimbursement is required by this act, as specified.

COMMENTS

1. Background:

EDD and Employer Reporting Requirements

The Employment Development Department (EDD) administers Unemployment Insurance (UI), Disability Insurance (DI), and Paid Family Leave (PFL) programs. EDD also provides employment service programs and collects the state's labor market information and employment data. Employers of all sizes are required to file a report of contributions, quarterly returns, and a report of wages paid to their employees to EDD. Employers are also required to withhold mandatory employee payroll deductions (State Disability Insurance (SDI) and Personal Income Tax (PIT)) and forward these to the EDD.

EDD is currently permitted to share data, but only with specified state agencies and for specific allowable purposes through Unemployment Insurance Code (UI Code) Section 1095 that outlines what the data can and cannot be used for.^[1] UI Code Section 1095 requires the EDD Director to permit the use of any information in their possession to the extent necessary, for the specified purposes, and allows EDD to requirement reimbursement for all direct costs incurred.

DHCS and Medi-Cal

The California Department of Health Care Services (DHCS) is single state agency overseeing Medi-Cal, California’s Medicaid program, and it provides health care for more than 14 million low-income people (around one-third of all Californians). DHCS provides health care to low-income individuals, children, older adults, and persons with disabilities. Medi-Cal covers physical and mental health, substance use disorder treatment, dental, pharmacy, and long-term services and supports. DHCS is also the single state agency for the Substance Use and Mental Health Services Administration for mental health and substance use disorder services.

Employer Mandate

As stated in the Senate Health Committee analysis, “According to the Internal Revenue Service (IRS), the [Affordable Care Act (ACA)] requires most employers with an average of 50 or more full-time equivalent employees in a calendar year to offer their full-time employees minimum essential health coverage that is affordable and provides a minimum value, as defined, to their employees or to potentially make an employer shared responsibility payment to the IRS. These provisions are also known as the “employer mandate.”

Employers are subject to this provision: 1) if they do not offer minimum essential coverage to at least 95% of their employees and have at least one full-time employee who receives premium tax credits through the state’s health insurance exchange (e.g. Covered California), or 2) if they do offer coverage to at least 95% of their employees, but a full-time employee gets premium tax credits because that employee was not offered coverage or the coverage was insufficient. In the first case, the 2024 amount of the penalty was $2,970 per employee, with the first 30 employees excluded from the calculation. In the second case, the 2024 amount of the penalty was $4,460 for each full-time employee receiving premium tax credits.

Notably, there is only shared responsibility for employers if one of the employer’s full-time employees enrolls in Covered California and gets premium tax credits. If the employee is part-time, including part-time at multiple jobs, or their pay and household size make them ineligible for premium tax credits whether because they earn too much or too little, the employer pays nothing.”

H.R. 1 Work Requirements

In July 2025, the President signed H.R. 1— also known as the ‘One Big Beautiful Bill Act’ —which introduced significant changes to Medi-Cal. The changes made by H.R. 1 are being phased in, although some changes are already in effect. The Legislative Analyst’s Office (LAO) prepared a report to the Legislature in February 2026 highlighting the impacts of H.R. 1. Currently, Medi-Cal does not require beneficiaries to work in order to be eligible for coverage but beginning January 2027, H.R. 1 requires most able-bodied, childless adults in Medicaid (generally 19-64 year olds who received coverage through the 2014 Affordable Care Act expansion) to complete at least 80 hours per month of work, education, or community service.^[2] This requirement does not apply to certain exempt groups, and states can provide additional exceptions for short-term hardship such as living in high-unemployment counties. According to the LAO, after exemptions, the requirement is estimated to apply to around 3.5 million people and they estimate this policy could result in disenrollments of around 1 to 2 million people, both from insufficient hours of engagement as well as administrative burden.

AB 1792 (Gomez, 2014)

In 2014, AB 1792 (Gomez, Chapter 889) was signed into law, which required DHCS to annually inform EDD of the names and social security numbers of all recipients of the Medi-Cal program. It required DHCS to determine the average per individual cost of the state and federally funded benefits provided by the Medi-Cal program and inform EDD of those costs. EDD was required to collaborate with DHCS and DSS^[3] to determine the total average cost of state and federally funded benefits provided to each identified employer’s employees.

AB 1792 also required the Department of Finance (DOF) to prepare a report that included the following information obtained by EDD:

• the employer’s name
• the employer’s address
• the number of beneficiaries each employer employs who are enrolled in a public assistance program
• the percentage of the employer’s total workforce in the state that are beneficiaries
• the total average cost of state and federally funded benefits provided to each identified employer’s employees who are beneficiaries calculated using the average per individual cost of state and federally funded benefits excluding administrative costs, and
• the methodology used by DHCS, EDD, CDSS, and the DHCS to calculate the average total cost of state and federally funded benefits provided to an identified employer’s employees who are beneficiaries.

Additionally, the DOF report was required to be annually transmitted to the Legislature beginning in 2016 and posted on DHCS’s website and only list the 500 employers in the state with the most number of employees enrolled in a public assistance program ranked by the number of those employees. The report, and any list provided to the department, was not allowed to include the name or identifying information of an individual beneficiary.

AB 1792 also contained protections for employees from discrimination and retaliation in the workplace for applying to be or being enrolled in the Medi-Cal program. AB 1792 had a sunset date of January 1, 2020, and its provisions are now repealed.

This bill, as proposed to be amended

Note: The bill in print requires CHHS to prepare the below specified report, but the author has agreed to amend the bill to instead require that DHCS will be tasked with preparing the report, since DHCS administers the Medi-Cal program and is more equipped with the appropriate information. The author has also agreed to amend the bill to define an employer as an employer that has 100 or more employees, instead of 50 or more employees. Below, there is a description of the bill, as proposed to be amended (please see comment #2 below for specific language).

As proposed to be amended, this bill will require DHCS to prepare a report, after obtaining information from EDD, that identifies all employers in California that employ 100 or more employees and that have any employees who receive benefits from the Medi-Cal program, as specified, while employed in the past calendar year.

SB 1284 will require the report to be submitted to the Legislature no later than July 1, 2027, and annually thereafter, and to include the following information:

• The name and address of each employer.
• The parent company of the employer, if applicable.
• The Employer Identification Number (EIN) of the employer.
• The North American Industry Classification System (NAICS) code assigned to the employer.
• The total number of employees of that employer.
• The number of employees of that employer enrolled in the Medi-Cal program by category of aid at any point during that reporting year.
• The number of months the employee received benefits through the Medi-Cal program while employed.
• The number of dependents of employees of that employer enrolled in the Medi-Cal program.
• The estimated annual cost to the Medi-Cal program provided to each identified employer’s employees and their dependents enrolled in the Medi-Cal program.
• A summary of the 100 employers with the highest number of employees and dependents enrolled in the Medi-Cal program.
• A summary of the 100 employers with the highest percent of employees and dependents enrolled in the Medi-Cal program.

This bill also contains clarifying language around data de-identification for any public reporting and prohibits employers from discriminating and retaliating against employees for applying to be or enrolling in the Medi-Cal program. It authorizes DHCS and EDD to enter into data-sharing agreements as necessary to implement these requirements, consistent with state and federal privacy laws.

2. Amendments Taken in this Committee:

Senate Health Committee amendments

The author agreed to amendments in the Senate Health Committee, but due to timing, the author will be taking the agreed-upon amendments in this committee. The amendments agreed to in the Senate Health Committee:

1. Clarify that DHCS, not CHHS, is tasked with completing the report.
2. Increase the 50-employees threshold to 100 employees in the definition of employer.
3. Add findings to specify that the legislative intent is to ensure that the Medi-Cal program continues to operate as the payor of last resort, and to support the effective administration, oversight, and evaluation of the program by improving transparency regarding the relationship between employment and Medi-Cal enrollment.
4. Delete the requirement that the report includes a summary of the 100 employees with the lowest number and percentage of employees and dependents enrolled in the Medi Cal program.
5. Add clarifying language around data de-identification for any public reporting.

Author’s amendments

The author’s office plans to amend the bill in committee to 1) make a clarifying change to the definition of an employer and 2) add language to prohibit employers from discriminating and retaliating against employees for applying to be or enrolling in the Medi-Cal program.

Below is a mock-up of the Senate Health Committee and author’s amendments that will be taken in this committee:

UIC 1095. The director shall permit the use of any information in the director’s possession to the extent necessary for any of the following purposes, and may require reimbursement for all direct costs incurred in providing any and all information specified in this section, except information specified in subdivisions (a) to (e), inclusive: [. . .]

(af) To enable the California Health and Human Services Agency Department of Health Care Services to prepare and submit the report required by Section 11024.5 of the Welfare and Institutions Code that identifies all employers in California that employ 50 100 or more employees and that have any employees who receive benefits from the Medi-Cal program (Chapter 7 (commencing with Section 14000) of Part 3 of Division 9 of the Welfare and Institutions Code) while employed in the past calendar year. The information used for this purpose shall be limited to information from the administration of personal income tax wage withholding pursuant to Division 6 (commencing with Section 13000) and the disability insurance program and may be disclosed to the California Health and Human Services Agency Department of Health Care Services only for the purpose of preparing and submitting the report and only to the extent not prohibited by federal law.

WIC 11024.5. (a) The Legislature makes the following findings:

(1) Medi-Cal is intended to function as a public safety net and as the payor of last resort, consistent with state and federal law, providing coverage only when other sources of health coverage are unavailable or insufficient.

(2) One in three working Californians rely on Medi-Cal for health coverage, including individuals employed by employers that do not provide affordable employer-sponsored coverage or that pay wages insufficient to meet basic health care needs.

(3) House Resolution 1 (Public Law 119-21) work requirements have brought the intersection of work, employer-sponsored health care coverage, and Medi-Cal back to the forefront. To best administer the Medi-Cal program, policymakers need empirical data to understand if H.R. 1 requirements are leading to changes in the number of uninsured, number of persons covered by employer-sponsored coverage, and enrolled in Medi-Cal by employer, business type and industry.

(4) It is the intent of the Legislature in enacting this section to ensure that the Medi-Cal program continues to operate as the payor of last resort, and to support the effective administration, oversight, and evaluation of the program by improving transparency regarding the relationship between employment and Medi-Cal enrollment.

(b) For purposes of this section, “employer” means a private employer that has 100 or more employees an individual or type of organization that employs for wages and salary 50 or more employees and has any employees enrolled in the Medi-Cal program (Chapter 7 (commencing with Section 14000)) at any point during the reporting year while employed by the employer.

(c) The California Health and Human Services Agency State Department of Health Care Services shall, after obtaining the information from the Employment Development Department pursuant to subdivision (af) of Section 1095 of the Unemployment Insurance Code, prepare a report that includes all of the following:

(1) The name and address of each employer.

(2) The parent company of the employer, if applicable.

(3) The Employer Identification Number (EIN) of the employer.

(4) The North American Industry Classification System (NAICS) code assigned to the employer.

(5) The total number of employees of that employer.

(6) The number of employees of that employer enrolled in the Medi-Cal program by category of aid at any point during that reporting year.

(7) The number of months the employee received benefits through the Medi-Cal program while employed.

(8) The number of dependents of employees of that employer enrolled in the Medi-Cal program.

(9) The estimated annual cost to the Medi-Cal program provided to each identified employer’s employees and their dependents enrolled in the Medi-Cal program.

(10) A summary of the 100 employers with the highest number of employees and dependents enrolled in the Medi-Cal program and a summary of the 100 employers with the lowest number of employees and dependents enrolled in the Medi-Cal program.

(11) A summary of the 100 employers with the highest percent of employees and dependents enrolled in the Medi-Cal program and a summary of the 100 employers with the lowest percent of employees and dependents enrolled in the Medi-Cal program.

(d) Notwithstanding Section 10231.5 of the Government Code, the California Health and Human Services Agency shall submit the report prepared pursuant to subdivision (b) to the Legislature no later than July 1, 2027, and annually thereafter, in accordance with Section 9795 of the Government Code. Any public reporting shall adhere to the department’s existing guidelines on data de-identification.

(e) Individually identifiable information about employees or Medi-Cal enrollees contained in the report prepared pursuant to subdivision (b) shall be exempt from disclosure under the California Public Records Act (Division 10 (commencing with Section 7920.000) of Title 1 of the Government Code) in accordance Section 7930.170 of the Government Code and Section 14100.2 of the Welfare and Institutions Code.

(f) Nothing in this section shall be construed to permit authorization or publication of identifying information of employees enrolled in the Medi-Cal program.

(g) The California Health and Human Services Agency State Department of Health Care Services and the Employment Development Department may enter into data-sharing agreements as necessary to implement this section, consistent with state and federal privacy laws.

(h) Nothing in this section shall be construed to authorize an employer to engage in any conduct against an employee or an applicant for employment in violation of Section 230.9 of the Labor Code, including, but not limited to, discouraging or preventing an employee from applying for or enrolling in the Medi-Cal program.

LAB 230.9 (1) An employer shall not discharge or in any manner discriminate or retaliate against an employee who applies for, or is enrolled in, the Medi-Cal program (Chapter 7 (commencing with Section 14000) of Part 3 of Division 9 of the Welfare and Institutions Code).

(2) An employer shall not refuse to hire a person because that person is enrolled in the Medi-Cal program.

3. Need for this bill?

According to the author, “More than 3 million working Californians rely on Medi-Cal, not because they are unemployed, but because their wages are too low or employer coverage is unaffordable. Medi-Cal was designed to be a safety net and a last resort. But when wages do not keep pace and coverage is out of reach, Medi-Cal fills that gap—and taxpayers bear the cost. At a time when the state faces a real budget crisis, federal cuts threaten to weaken Medi-Cal further, and families are struggling to get by, we have to ask: Is it fair or sustainable for taxpayers to subsidize the labor costs of billion-dollar corporations?

SB 1284 increases transparency by requiring the state to publish an annual report identifying employers whose workers are enrolled in Medi-Cal and estimating the associated cost to taxpayers. If public dollars are being used to support a company’s workforce, the public deserves to know. The bill ensures the public has access to information about how Medi-Cal supports California’s workforce, and which large employers rely most heavily on the program. Specifically, SB 1284 requires the California Department of Health Care services to produce an annual public report identifying employers with 100 or more employees and at least 10 full-time employees enrolled in Medi-Cal during the reporting year.”

4. Proponent Arguments:

According to the co-sponsors of this bill, SEIU California:

“Employers that pay low wages and offer no or unaffordable benefits shift the costs of doing business onto taxpayers. The social and economic burden created by the lack of health care coverage for some workers and the coverage of other workers through the Medi-Cal program creates a burden on the state, affected workers, and the families of affected workers who suffer ill health and risk financial ruin. Employers that shift the costs of their business

expenses onto taxpayers put responsible employers at a competitive disadvantage too, creating an unfair playing field for business in the state.

As H.R. 1 work requirements have brought the intersection of work, employer-sponsored health care coverage, and Medi-Cal back to the forefront, policymakers should have empirical data to understand if H.R. 1 requirements are leading to changes in the number of

uninsured, number of persons covered by employer-sponsored coverage, and enrolled in Medi-Cal by business type and industry. To promote a deeper understanding of the dynamics of health care coverage and employment, and the economic impacts on Californians, business, and the state budget, it is appropriate for policymakers to possess a broader set of

empirical data at the employer level with which to make informed decisions. SB 1284 is a critical step forward to accomplish this.”

5. Opponent Arguments:

According to the Chamber of Commerce, opponents of this bill:

“SB 1284 would require the State Department of Health Care Services (DHCS) to report employer-specific data on employees enrolled in Medi-Cal to and then make that information available, identified by employer name. While SB 1284 does not expressly state that the names of employers will be disclosed publicly, it can be inferred that when DHCS submits the report to the legislature no later than July 1, 2027, there will likely be a hearing on the findings. In that hearing, that would be open to the public, there is a high likelihood that individual employers’ names are divulged or at minimum posted on the agency website. By placing individual employer names alongside the number of their workers receiving state-funded health care, SB 1284 would effectively create a government operated public shaming registry. One built on incomplete, decontextualized data that says nothing definitive about how an employer treats its workforce.

This implicit premise in SB 1284’s purpose is deeply concerning, and that premise is that any

employer with workers on Medi-Cal is offloading its obligations onto taxpayers. This premise, however, is demonstrably false, and using a state database to broadcast it will cause serious, undeserved harm to countless California employers, including small businesses.

Medi-Cal enrollment is driven by a complex set of factors that have nothing to do with employer malfeasance, including but not limited to:

• • Workers who voluntarily choose Medi-Cal over employer sponsored coverage because it is more affordable or comprehensive for their family situation;
  • Part-time or seasonal workers who are not eligible for employer-sponsored benefits under existing law;
  • Workers whose income qualifies them for Medi-Cal regardless of whether their employer offers coverage;
  • New hires still in waiting periods before employer benefits take effect;
  • Workers in households with other enrolled family members who are on Medi-Cal for independent reasons;
  • Industries such as agriculture, construction, food service, retail, and healthcare that employ high proportions of lower-wage workers who qualify for Medi-Cal by income threshold, regardless of an employer’s robust benefit offerings.

SB 1284 does nothing to account for any of these factors. Sharing an employer’s name alongside a Medi-Cal enrollment count, without context or explanation, implies that the employer is wholly responsible, when the reality is far more complicated and nuanced.”

6. Dual Referral:

The Senate Rules Committee referred this bill to the Senate Health Committee, where it passed with a vote of 8-1, and the Senate Labor, Public Employment and Retirement Committee.

7. Prior/Related Legislation:

SB 1054 (Cabaldon, 2025) would require specified employers and other affected entities to also report total monthly wage, industry, occupation, worker type, and hours worked for each employee, as specified. This bill is currently pending in the Senate Appropriations Committee.

SB 1202 (Weber Pierson, 2025) requires DHCS to establish a dashboard to track enrollment data related to the implementation of recently enacted federal enrollment barriers, including work requirements. Requires DHCS, counties, and Medi-Cal managed care plans to undertake linguistically and culturally appropriate outreach efforts to Medi-Cal recipients to educate them on the changes to federal law and maintaining Medi-Cal eligibility. This bill is pending in the Senate Appropriations Committee.

AB 2161 (Bonta, 2025) codifies H.R. 1’s work requirements; requires DHCS to implement H.R. 1’s work requirements in California in the least administratively burdensome way to Medi-Cal applicants and recipients as possible; and prohibits DHCS from applying H.R. 1’s work requirements to state-only Medi-Cal populations. This bill is pending in the Assembly Appropriations Committee.

AB 2729 (Bonta, 2025) creates the Employer Responsibility for Medi-Cal Trust Fund consisting of new taxes and deposits, including employer penalties, to fund direct and indirect costs of administering the Medi-Cal program in a manner necessary to prevent the loss of or restore health care coverage, benefits, or access to care, following the passage of H.R. 1. This bill is pending in the Assembly Health Committee.

AB 1792 (Gomez, Chapter 889, Statutes of 2014) required the Department of Health Care Services (DHCS) to annually inform the Employment Development Department (EDD) of the names and social security numbers of all recipients of the Medi-Cal program; required DHCS to determine the average per-individual cost of state and federally funded benefits provided by the Medi-Cal program and inform EDD of these costs; defined an employer as an individual or organization that employs 100 or more beneficiaries of the Medi-Cal program; required the Department of Finance (DOF) to, after obtaining specified information from EDD, annually transmit to the Legislature and post on the DOF Internet Web site a report that, among other things, identified the 500 employers in the state with the most number of employees enrolled in a public assistance program ranked by the number of those employees, as specified; and established a January 1, 2020 sunset date.

AB 880 (Gomez, 2013) would have required employers with 500 or more employees to pay an employer responsibility penalty if their employees working more than 12 hours per week and more than 45 days in a calendar year are enrolled in Medi-Cal based on the Modified Adjusted Gross Income eligibility standard. This bill failed on the Assembly Floor.

SUPPORT

California Federation of Labor Unions (Co-Sponsor)

California State Council of Service Employees International Union (SEIU California) (Co-Sponsor)

California LGBTQ Health and Human Services Network

California Physicians Alliance

CFT – a Union of Educators & Classified Professionals

Courage California

End Poverty in California (EPIC)

Health Access California

Teamsters California

UFCW - Western States Council

United Domestic Workers/AFSCME Local 3930

OPPOSITION

California Chamber of Commerce

-- END --

1. UI Code Section 1095 ↑

2. Key Impacts of H.R. 1 on Medi-Cal and CalFresh. Legislative Analyst’s Office. February 11, 2026. https://lao.ca.gov/handouts/health/2026/H.-R-1-Key-Impacts-021126.pdf ↑

3. California Department of Social Services ↑

SENATE COMMITTEE ON HEALTH

Senator Dr. Akilah Weber Pierson, Chair

BILL NO: SB 1284

SUBJECT: Medi-Cal benefits: employer reports

SUMMARY:

Requires the California Health and Human Services Agency to prepare an annual report of all employers with 50 or more employees that calculates the estimated cost to the Medi-Cal program for each identified employee and employee’s dependents receiving Medi-Cal.

Existing federal law:

1. Establishes the Medicaid program to enable each state to furnish medical assistance on behalf of individuals whose income and resources are insufficient to meet the costs of necessary medical services. [42 USC §1396, et seq.]
2. Requires states to provide safeguards restricting the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the program with limited exceptions for school nutrition programs. [42 USC §1396a]
3. Starting January 1, 2027, as enacted by H.R. 1 (Public Law No. 119-21), requires individuals with incomes below 138% of the federal poverty level who are under age 65, not pregnant, and have no Medicaid-eligible dependents to demonstrate community engagement through at least 80 hours of work, community service, or participation in a work program, or at least half-time participation in an educational program, or have a monthly income not less than 80 times the federal minimum wage in a specified month. Provides for some exceptions to this requirement. This is referred to as the “work and community engagement” requirements. [42 USC §1396a]
4. Requires an applicable large employer, defined as an employer with an average of 50 or more full-time equivalent employees in a calendar year, to offer its full-time employees and their dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan or be subject to an assessable payment if any of their full-time employees enroll in a state-based health insurance exchange. [26 USC §4980H]

Existing state law:

1. Establishes the California Health and Human Services Agency (CHHS), which consists of the following departments and offices: Aging, Child Support Services, Community Services and Development, Developmental Services, Health Care Access and Information, Health Care Services (DHCS), Managed Health Care, Public Health, Rehabilitation, Social Services (DSS), State Hospitals, the Center for Data Insights and Innovation, the Emergency Medical Services Authority, the Office of Technology and Solutions Integration, the Office of Law Enforcement Support, the Office of the Surgeon General, the Office of Youth and Community Restoration, and the State Council on Developmental Disabilities. [GOV §12803 and §12806]
2. Establishes the Medi-Cal program, administered by DHCS, under which qualified low-income individuals receive health care services. [WIC §14000, et seq.]
3. Requires an individual’s information given for purposes of receiving Medi-Cal to be kept confidential and not open to examination other than for purposes directly connected with the administration of the program. Limits the use of Medi-Cal applicant and recipient information to encompass those activities and responsibilities in which DHCS and its agents are required to engage in to ensure effective program operations, which include but are not limited to, establishing eligibility and methods of reimbursement; determining the amount of medical assistance; providing services for recipients; conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the Medi-Cal program; and conducting a legislative investigation or audit related to the administration of the Medi-Cal program, with limited exceptions for the coordination of other benefits, namely school nutrition programs. [WIC §14100.2]
4. Exempts confidential Medi-Cal applicant or recipient information from disclosure pursuant to the California Public Records Act [GOV §7930.170]

This bill:

1. Requires the Employment Development Department (EDD) to share information based on personal income tax wage withholding and the disability insurance program that identifies all employers in California employing 50 or more employees, and that have employees who receive benefits from the Medi-Cal program while employed in the last calendar year, with CHHS, to the extent not prohibited by federal law.
2. Requires CHHS, after obtaining the above information, to prepare a report to the Legislature by July 1, 2027, and annually thereafter, that includes:
3. The employer’s name and address; parent company, if applicable; Employer Identification Number; North American Industry Classification System code; total number of employees; number of employees enrolled in Medi-Cal by aid category at any point during the reporting year; the number of months the employees received Medi-Cal benefits while employed; the number of employee dependents enrolled in Medi-Cal; and the estimated annual cost to the Medi-Cal program for each identified employee and their dependents;
4. A summary of the 100 employers with the highest number of employees and dependents enrolled in Medi-Cal and of the 100 employers with the highest percentage of employees and dependents enrolled in Medi-Cal; and,
5. A summary of the 100 employers with the lowest number of employees and dependents enrolled in Medi-Cal and of the 100 employers with the lowest percentage of employees and dependents enrolled in Medi-Cal.
6. Exempts individually identifiable information about employees or Medi-Cal enrollees contained in the report from disclosure under the California Public Records Act and makes legislative findings about the importance of the privacy of Medi-Cal enrollees.
7. Prohibits authorization or publication of identifying information of employees enrolled in the Medi-Cal program.
8. Authorizes CHHS and EDD to enter into data-sharing agreements necessary to implement this bill, consistent with state and federal privacy laws.
9. Repeals the sunsetted law requiring DHCS and DSS to share with EDD the social security numbers of all Medi-Cal and CalFresh recipients.

FISCAL EFFECT:

This bill has not been analyzed by a fiscal committee.

COMMENTS:

1. Author’s statement. According to the author, over the past decade, California has expanded health care coverage and grown into the fourth largest economy in the world, proving that we can build prosperity while protecting working families. Today, more than three million working Californians rely on Medi-Cal because their employers do not provide affordable health insurance. Nearly one in five jobs in California is held by a worker enrolled in Medi-Cal, representing over $20 billion annually in public spending tied to the workforce. When companies fail to provide affordable coverage or livable wages, Medi-Cal fills the gap. That means taxpayers are subsidizing a significant share of health care costs for California’s low-wage workforce. That should not happen in the dark. If taxpayers are covering the cost of health care for a company’s workforce, the public deserves to know. This bill brings transparency and accountability to this issue by requiring CHHS to publish the names of employers with workers enrolled in Medi-Cal, along with the estimated annual cost to the program associated with those employees.
2. Medi-Cal recipients and work. According to a January 2025 report by the California Health Care Foundation, almost one in five of all California workers was enrolled in Medi-Cal in 2023. In some industries, such as agriculture and the restaurant industry, that percentage is considerably higher, 35% and 36% respectively. Other industries with higher-than-average numbers of workers on Medi-Cal include administrative and building services; other services; retail; transportation and warehousing; arts, entertainment, recreation, and accommodation; and construction. Of all nondisabled, nonelderly adults (age 19-64) in Medi-Cal, 62% reported working full-time or part-time in 2021 (the latest data available) and 82% reported being in a working family where at least one person is working full- or part-time. These workers turn to Medi-Cal because low-wage workers are less likely to be offered job-based coverage than higher-income workers or may not be able to afford the coverage they are offered at work. The report also states that many are seasonal or hourly workers with fluctuating income or may be between jobs. In addition, for those that do not work, 14% reported being a caretaker, 6% said they were going to school, and 9% reported an illness or disability, though likely not meeting the strict requirements for federal disability benefits.
3. H.R. 1 and work requirements. H.R. 1, the federal budget reconciliation bill passed in July 2025, makes a number of changes primarily to lower taxes, increase funding for immigration control and national defense, and restrict access to and funding for SNAP and Medicaid. More relevant to this bill is the new “community engagement requirement” (or “work requirement”) that requires nondisabled adults between the ages of 19 and 65 who gained coverage through the Affordable Care Act (“ACA expansion adults”) to demonstrate 80 hours of work, education, or volunteer activities a month to be eligible for Medicaid coverage, unless they qualify for a limited exemption. Because the work requirement is calculated based on federal minimum wage, many may be exempt if they earn at least $580 in monthly income. States are required to verify that an individual meets the community engagement requirements twice a year, starting January 1, 2027. This provision was included to reduce state Medicaid rolls. The UC Berkeley Labor Center estimates that 1.87 million adults will lose coverage due to the work requirements. According to an estimate from DHCS given in a presentation Implementation Plan for New Eligibility and Enrollment Changes Under H.R. 1 on February 5, 2026, by June 2028, 1.4 million recipients will have lost Medi-Cal coverage due to this requirement. Both of these estimates assume that a large number of people to whom the requirements apply will be exempted and that outreach efforts will be largely successful in reaching people who do work and enabling them to comply. However, it is anticipated that some people who are working will lose coverage under this requirement due to the administrative burden of reporting work.
4. Employer-shared responsibility penalties. According to the Internal Revenue Service (IRS), the ACA requires most employers with an average of 50 or more full-time equivalent employees in a calendar year to offer their full-time employees minimum essential health coverage that is affordable and provides a minimum value, as defined, to their employees or to potentially make an employer shared responsibility payment to the IRS. These provisions are also known as the “employer mandate.” Employers are subject to this provision: 1) if they do not offer minimum essential coverage to at least 95% of their employees and have at least one full-time employee who receives premium tax credits through the state’s health insurance exchange (e.g. Covered California), or 2) if they do offer coverage to at least 95% of their employees, but a full-time employee gets premium tax credits because that employee was not offered coverage or the coverage was insufficient. In the first case, the 2024 amount of the penalty was $2,970 per employee, with the first 30 employees excluded from the calculation. In the second case, the 2024 amount of the penalty was $4,460 for each full-time employee receiving premium tax credits.

Notably, there is only shared responsibility for employers if one of the employer’s full-time employees enrolls in Covered California and gets premium tax credits. If the employee is part-time, including part-time at multiple jobs, or their pay and household size make them ineligible for premium tax credits whether because they earn too much or too little, the employer pays nothing. This bill requires counting the number of employees and dependents that an employer has who receive Medi-Cal and calculating the cost to the state but does not impose a penalty.

1. Double referral. This bill is double referred. Should it pass out of this committee, it will be referred to the Senate Committee on Labor, Public Employment, and Retirement.
2. Related legislation. SB 1202 (Weber Pierson) requires DHCS to establish a dashboard to track enrollment data related to the implementation of recently enacted federal enrollment barriers, including work requirements. Requires DHCS, counties, and Medi-Cal managed care plans to undertake linguistically and culturally appropriate outreach efforts to Medi-Cal recipients to educate them on the changes to federal law and maintaining Medi-Cal eligibility. SB 1202 passed the Senate Health Committee by a vote of 11-0 on April 8, 2026.

AB 2161 (Bonta) codifies H.R. 1’s work requirements; requires DHCS to implement H.R. 1’s work requirements in California in the least administratively burdensome way to Medi-Cal applicants and recipients as possible; and prohibits DHCS from applying H.R. 1’s work requirements to state-only Medi-Cal populations. AB 2161 is pending in the Assembly Appropriations Committee.

AB 2729 (Bonta) creates the Employer Responsibility for Medi-Cal Trust Fund consisting of new taxes and deposits, including employer penalties, to fund direct and indirect costs of administering the Medi-Cal program in a manner necessary to prevent the loss of or restore health care coverage, benefits, or access to care, following the passage of H.R. 1. AB 2729 is in the Assembly Health Committee.

1. Prior legislation. AB 1792 (Gomez, Chapter 889, Statutes of 2014) requires the Department of Finance to publish an annual report listing the 500 employers in the state with the most number of employees enrolled in a public assistance program, including Medi-Cal, ranked by the number of those employees after receiving the relevant information from EDD, DHCS, and DSS. The relevant pieces of this bill sunsetted in 2020.

AB 880 (Gomez of 2013) would have required employers with 500 or more employees to pay an employer responsibility penalty if their employees working more than 12 hours per week and more than 45 days in a calendar year are enrolled in Medi-Cal based on the Modified Adjusted Gross Income eligibility standard. AB 880 failed on the Assembly Floor.

1. Support. Sponsors California State Council of Service Employees International Union write that employers that pay low wages and offer no or unaffordable benefits shift the costs of doing business onto taxpayers and also put responsible employers at a competitive disadvantage. They explain that as H.R. 1 work requirements have brought the intersection of work, employer-sponsored health care, and Medi-Cal back to the forefront, policymakers should have empirical data to understand if H.R. 1 requirements are leading to changes in the number of uninsured, number of persons covered by employer-sponsored coverage, and enrolled in Medi-Cal by business type and industry. The California Federation of Labor Unions, AFL-CIO point to data on the country’s largest low-wage employers showing median worker pay declining and high reliance on Medicaid while CEOs of the companies earned an average of 900 times more than the median worker. They also point out that Massachusetts published a similar report beginning in 2006 that was used to analyze program utilization, financing of publicly subsidized programs, identify trends, and track the effect of policies on the use of public programs.
2. Policy comments. In light of the recent imposition of work requirements on Medi-Cal recipients, this bill asks the inverse question: why do so many California workers rely on Medi-Cal? While this is a valid question, and perhaps the first step in crafting policy to address the problem, this bill raises the following important considerations:
   1. Confidentiality of Medi-Cal recipient information. State and federal law mandate that personal information provided for the purposes of receiving Medi-Cal is confidential. The California Public Records Act already acknowledges this and specifies an exemption for this information, thus the language exempting such information from disclosure under the Public Records Act is superfluous. However, more care should be given as to how this information will be reported and used given the small numbers of individuals that may be involved and the potential for uncovering the identity of an individual even when the information presented is de-indentified.
   2. Clarifying the administrative purpose of the bill. State and federal law specify that information provided by a Medi-Cal applicant or recipient may only be used for the direct administration of the program, with limited exceptions. This bill could use language explicitly connecting the use of this information and the creation of the report of employers with the most and least Medi-Cal employees to the administration of the Medi-Cal program.
   3. Protections for employees on Medi-Cal. Scrutiny regarding the numbers of employees receiving Medi-Cal could create a situation where employers do not want to hire or retain workers who are on Medi-Cal or whose dependents are on Medi-Cal. A bill requiring the reporting of this information should also contain language to protect Medi-Cal recipients (or parents of Medi-Cal recipients) from discrimination on that basis in the workplace. AB 1792 included this language, but it sunsetted in 2020 when the reporting requirements expired.
   4. Employer threshold. Proponents state that the 50-employee threshold is intended to align with the ACA employer mandate requirements. It should be noted that those requirements are an average of 50 full-time-equivalent employees over the calendar year, which in many cases could be considerably more than 50 employees. Regardless, this relatively low threshold makes reporting the employers with the least number of employees and lowest percentage of employees unwieldy as there could be numerous employees with only zero or one employee on Medi-Cal. It also means the overall data to be matched is quite large. Finally, the low threshold increases the likelihood that employees will be inadvertently de-identified if any information is released.
   5. Entity tasked with compiling the report. This bill tasks CHHS with completing the report despite all the data being held within DHCS. In all likelihood, CHHS would assign the report to DHCS. However, given DHCS’s holding of the data and experience in handling confidential Medi-Cal data, they should be responsible for handling the report.

SUPPORT AND OPPOSITION:

Support: California State Council of Service Employees International Union (sponsor)

California Federation of Labor Unions AFL-CIO

Health Access California

United Domestic Workers/AFSCME Local 3930

Oppose: None received.

-- END --