Kaiser Permanente California Is Limiting Access to Care

October 29, 2025

The American Speech-Language-Hearing Association (ASHA) and the California Speech Language Hearing Association (CSHA) have received concerning reports that Kaiser Permanente is inappropriately limiting access to medically necessary care in California. This is impacting Medicaid managed care and commercial insurance beneficiaries in different ways, with patients losing access to services or waiting months to get an appointment.

ASHA and CSHA have been contacting Kaiser to resolve the issues. Now we’re turning to California Medicaid and the local state insurance commissioner for help.

The insurance commissioner has requested that providers and beneficiaries submit commercial insurance complaints for investigation. ASHA is also collecting member complaints regarding coverage of Kaiser Medi-Cal patients through a form listed below.

Medicaid Managed Care

According to reports from providers, Kaiser has been limiting the number of sessions a Medicaid beneficiary can receive and calling its model “episodic care.” Episode-based payment models in value-based care focus on an episode of illness or injury where all aspects of a patient’s care related to that diagnosis are carefully coordinated with all health care providers.

For example, an open-heart surgery and all related care by all providers for 30 days post-operation could be considered an episode of care that is paid for in a lump sum. The goal is to provide coordinated quality care that is cost-effective and avoids redundancies. In this model, there are quality metrics to assess the patient’s progress and effectiveness of care. But provider complaints show the hallmark requirements of true episodic care are not present in the Kaiser model. There are no initiating events, quality metrics, or care coordination.

Episodic care is not in and of itself a value-based care model. It’s a service delivery model that focuses on a short-term, goal-oriented approach to health care focused on a specific health need rather than ongoing, continuous treatment for a chronic condition. There is usually an emphasis on carry-over services at home to continue progress.

Regardless of the service delivery model, Medicaid patients should not have visit limits for medically necessary care. Medicaid beneficiaries under the age of 21 are under the Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) benefit, even if they receive care through a Medicaid managed care plan managed by a private insurance company.

Though EPSDT does permit utilization management techniques like prior authorization and pre- or post-payment review, all medically necessary services—a term defined under the Medicaid state plan but one which often involves physician referral—must be made available for treatment. Medically necessary services provided under EPSDT are not subject to arbitrary restrictions such as mandated service delivery models that are chosen for administrative or cost reasons rather than clinical reasons.

Commercial Insurance

The issue facing Kaiser commercial insurance beneficiaries is different as they do not fall under the EPSDT benefit but are subject to a California law with timely access requirements for private insurers. Speech-language pathologists (SLPs) report that beneficiaries who need medically necessary pediatric habilitation services are unable to access timely care or an appropriate number of sessions. Although patients are receiving approval for three months of therapy services under their Kaiser plan, they often have to wait months to schedule an appointment with an in-network SLP.

These long waitlists are preventing patients from getting the clinically appropriate number of sessions within the approved timeframe. In some cases, providers and patients report being able to attain as few as two to three sessions during the entire three-month authorization period even when weekly sessions are clinically indicated.

This situation directly violates California Health and Safety Code 1367.03, which requires that patients have access to nonurgent care within 15 business days of requesting an appointment. This would ensure that patients have access to more services during their three-month treatment window.

Because of the long waitlists, many out-of-network providers report Kaiser beneficiaries seeking cash-pay arrangements to supplement the clinically insufficient services available through Kaiser—despite receiving approval for three months of therapy services and California’s requirement for timely access to care.

What’s Next?

ASHA and CSHA have met with Kaiser and communicated directly via letter to address this issue, but we have not been able to reach a resolution. So we are going to regulators to address the problem.

Medicaid Managed Care

ASHA and CSHA first met with Kaiser in January 2025 to discuss member concerns.
After no follow-up from Kaiser, ASHA and CSHA reached out again in hopes of meeting to discuss the problems further in August 2025.
In late September, Kaiser said that it did not impose a predetermined number of therapy visits to pediatrics for any condition.
ASHA and CSHA sent a letter to California Medicaid detailing the problem, requesting a meeting to discuss, and seeking its help to ensure Kaiser complies with requirements of the EPSDT benefit.
ASHA, CSHA, and Medi-Cal are discussing the issues identified by members.

Commercial Insurance Plans

ASHA has met with the California insurance commissioner to discuss this issue and followed up with a letter detailing the challenges faced by speech-language pathology providers and their Kaiser beneficiaries. The commissioner has asked for beneficiaries and providers to submit complaints for investigation.
ASHA encourages SLPs and Kaiser beneficiaries experiencing this problem to use ASHA’s template letters to submit complaints directly to the insurance commissioner. The insurance commissioner cannot investigate a complaint made by an association, but they can investigate complaints made by providers and beneficiaries in their state.
Complaints can be submitted anonymously, but they cannot be investigated in the same manner as non-anonymous complaints. Beneficiaries cannot be removed from their insurance plan for submitting a complaint to an insurance commissioner and providers should not be penalized. If an insurer penalizes a beneficiary or provider for submitting a complaint, the insurance commissioner should be notified. For more on confidentiality, see the California Department of Insurance Website Privacy Policy Notice and the last page of the California Health Care Provider Request for Assistance Form.