Medicaid Doula Requirements in California (Medi-Cal)

As of Jan 21, 2026

California’s Medicaid program is called Medi-Cal—and Medi-Cal covers doula services as a preventive benefit. That’s a major opportunity for access (more families can receive doula support) and for sustainability (doulas can build a steadier stream of paid work). But Medi-Cal is also a regulated payer, which means requirements matter: eligibility, enrollment, recommendations, documentation, and (often) managed-care contracting.

1) “Medical requirements” in California (what Medi-Cal requires of doulas)

Even though doulas are non-clinical, Medi-Cal is a regulated payer—so it requires specific qualifications and compliance items.

Minimum eligibility requirements (California)

To enroll as a Medi-Cal doula, DHCS states you must:

• Be 18+
• Have adult/infant CPR certification
• Have completed basic HIPAA training
  …and you must qualify via one pathway below.

Qualification pathways (choose one)

Training pathway

• Complete at least 16 hours of training in required topic areas (lactation support, childbirth education, pregnancy/childbirth anatomy foundations, nonmedical comfort measures and labor techniques, community resource list), and
• Attest you have supported at least 3 births.
• Newmom.me Academy Labor and Birth Doula meets the Medi Cal requirements

Experience pathway

• At least 5 years active doula experience within the past 7 years, and
• 3 testimonial/recommendation letters meeting DHCS criteria.

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2) Enrollment basics: NPI + PAVE (the operational gate)

Even though doulas are non-clinical, California treats enrolled doulas as providers in the Medi-Cal system, so you’ll need:

• An NPI (National Provider Identifier)
  • DHCS states all doulas must apply for an NPI.
  • If you’ve formed an LLC or corporation, DHCS notes you must use a Type 2 NPI for the entity.
• Enrollment through DHCS’ PAVE portal (Provider Application and Validation for Enrollment).

Also note: DHCS points out you may need to meet local business requirements (business license, fictitious business name filing) depending on your city/county and business setup.

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3) What Medi-Cal covers for doula care in California

Under California’s Medi-Cal doula benefit, members can receive:

• One initial visit (90 minutes)
• Up to eight additional visits (any mix of prenatal and postpartum)
• Support during labor & delivery and also during miscarriage and abortion
• Up to two extended postpartum visits (three hours each)

Postpartum window: Medi-Cal doula services are available through one year postpartum.

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4) Medi-Cal reimbursement rates in California (what doulas get paid)

DHCS publishes fee-for-service (FFS) doula rates and confirms doula services are covered in both FFS and managed care.

Current Medi-Cal FFS doula rates (DHCS)

As listed by DHCS (updated September 19, 2025; TRI rates effective for services on/after January 1, 2024):

• Initial visit (90 minutes): $197.98
• Prenatal visit: $162.11
• Postpartum visit: $162.11
• Extended postpartum support (3 hours): $486.36
• Support during vaginal delivery: $685.07
• Support during cesarean section: $795.73
• Support during/after miscarriage: $250.85
• Support during/after abortion: $250.85

DHCS states the TRI (Targeted Rate Increase) rates for managed care plan members apply to providers who are contracted with the plan (or have an unbroken chain of contracts). In other words, plan contracting can affect whether you receive the TRI rate.

“How much can a doula earn per pregnancy?” (maximum reimbursement example)

DHCS also provides examples of maximum reimbursement amounts (FFS) when a doula delivers the full set of services under the standing recommendation. For example, all initial recommendation visits plus support during a vaginal delivery is shown as $3,152.65 (TRI).

And if a client receives a second recommendation for additional postpartum visits (up to nine), DHCS notes that can add $1,458.99 if all nine visits are provided.

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5) Billing codes doulas use in California (and the rules that come with them)

The core billing codes (California)

Here are the key codes and what they represent:

https://www.dhcs.ca.gov/provgovpart/Pages/Doula-Billing-Codes.aspx

Two California billing requirements that trip people up

A) Modifier XP is required for doula billing
DHCS states doulas use the same billing codes as certain licensed providers, and must use modifier “XP” when billing doula services (FFS and managed care) to indicate the service was provided by a doula.

B) A diagnosis code is required—even though doulas don’t diagnose
DHCS confirms a diagnosis code is required on claims, and DHCS identifies general ICD-10 codes doulas may use.

Here’s the official “pairing” concept (procedure code → acceptable ICD-10 codes) from the Medi-Cal Provider Manual’s doula section:

• Z1032 → Z32.2, Z32.3, Z39.1, Z39.2
• Z1034 → Z32.2, Z32.3
• 59409 / 59612 / 59620 → Z33.1, Z39.0
• 59840 / T1033 → Z33.1
• T1032 / Z1038 → Z39.0, Z39.1, Z39.2

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6) How to file for reimbursement (California): FFS vs Managed Care

California Medi-Cal payments happen through two main routes:

1. Fee-for-service (FFS) claims (you submit a Medi-Cal claim), and
2. Managed care plan (MCP) reimbursement (you bill the member’s plan per plan process).

Step 1 — Confirm the member’s coverage route

Before you render services, confirm whether the member is:

• Medi-Cal FFS, or
• Enrolled in a Medi-Cal managed care plan (common)

This matters because it determines where you submit your claim (Medi-Cal vs plan).

Step 2 — Provide service within Medi-Cal rules + document it

Follow the code rules (duration/limits) and keep clean notes: date, time, service type, support provided, next steps. The “Doula Services” manual includes key billing limits like “one visit per day per member,” labor code frequency limits, and how to bill T1032 in units.

Step 3 — Prepare the claim correctly (FFS and MCP both care about this)

At minimum, you’ll need:

• Correct procedure code (e.g., Z1032, Z1034, T1032, etc.)
• Modifier XP
• An allowed ICD-10 diagnosis code for that service
• Date of service, units (if applicable), provider identifiers, member identifiers

Step 4A — If the member is Medi-Cal FFS: submit a Medi-Cal claim

Medi-Cal FFS claims can be submitted:

• electronically via EDI (ASC X12N 837) through the Medi-Cal Provider Portal (described as the most efficient method), or
• as a paper claim using the CMS-1500 form (common for professional/allied health services).

Timeliness matters: The Medi-Cal Provider Manual states original claims must be received within six months following the month of service (with delay reason exceptions).

Step 4B — If the member is in a Medi-Cal managed care plan: bill the plan

DHCS still requires correct coding conventions for doula services (including modifier XP and diagnosis code), but plans may have additional contracting/credentialing and submission workflows. The safest rule: treat plan billing as “Medicaid, but through the plan’s pipeline.”

7) Quick “Do Not Skip” checklist (California doula billing-ready)

Enrollment & eligibility

• ☐ 18+ + CPR + HIPAA training
• ☐ Training pathway (16 hours + 3 births) or experience pathway (5 years + letters)

Billing essentials

• ☐ Use the correct code (Z1032, Z1034, T1032, etc.)
• ☐ Add modifier XP
• ☐ Include a valid ICD-10 code per DHCS table
• ☐ Remember: Z1038 requires a second recommendation

Submission

• ☐ Submit FFS claims via Provider Portal EDI or CMS-1500
• ☐ File on time: within six months following the month of service

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Disclaimer: This blog's content is provided for informational purposes only, and does not intend to substitute professional medical advice, diagnosis, or treatment and you should not rely solely on this information. Always consult a professional in the area for your particular needs and circumstances prior to making any personal, professional, legal, medical and financial or tax-related decisions.