California’s Senate Bill 306 reshapes the prior authorization landscape by codifying Health and Safety Code Section 1367.025 and granting the Department of Health Care Services broad authority to determine when insurers may require prior authorization for covered health care services. Beginning in 2026, DHCS must collect data on insurer approval and denial rates, and no later than January 1, 2028, direct insurers to remove prior authorization requirements on services approved at a rate of 90% or greater, subject to carve-outs for experimental, investigational, and out-of-network services. The program examines the mechanics of the new law, the scope and limits of DHCS’s exemption powers, and the narrow fraud and abuse provisions that allow insurers to retain prior authorization requirements. This program also situates the reform within the broader national debate over prior authorization and explores how the shift in regulatory power may reshape health insurance litigation. Attendees will leave equipped to advise clients on compliance obligations, exemption determinations, and emerging litigation risks under Section 1367.025.
