CurrentCalifornia Department of Health Care ServicesPolicy N/A

Doula Services — Coverage Criteria

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Defines coverage, billing, documentation, eligibility, and provider qualifications for doula services reimbursed by California Medi‑Cal; applies to doulas, enrolled doula groups, recommending licensed providers, and Medi‑Cal managed care plans and fee‑for‑service claims.

Policy Summary

PayerCalifornia Department of Health Care Services

PolicyDoula Services — Coverage Criteria

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateN/A

Last ReviewMar 1, 2025

Next Review DateN/A

Key ActionObtain a written recommendation from a physician or other licensed practitioner to authorize doula services and document dates, duration, nature of care, and support time for each visit.

SourceLink

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CurrentCalifornia Department of Health Care ServicesPolicy N/A

Doula Services — Coverage Criteria

Customize your policy alerts

Sign up for all California Department of Health Care Services policy alerts

Know when California Department of Health Care Services releases new policies or updates existing guidance.

Monitor payer policy activity

Receive email alerts as soon as relevant payer policies are published or updated.

Policy Summary

PayerCalifornia Department of Health Care Services

PolicyDoula Services — Coverage Criteria

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateN/A

Last ReviewMar 1, 2025

Next Review DateN/A

Key ActionObtain a written recommendation from a physician or other licensed practitioner to authorize doula services and document dates, duration, nature of care, and support time for each visit.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

Initial + up to 8Standard authorized visits

Up to 2 (3‑hr)Extended postpartum visits

Once/pregnancyLabor/delivery support limit

12 monthsPostpartum coverage length

16 hrs + 3 birthsTraining pathway

Coverage criteria and limits

Medical necessity / general eligibility

Covered when ALL of the following are met:

Eligibility and intent: Member is pregnant or was pregnant within the past year and would benefit from or requests doula services; services are provided during pregnancy, labor and delivery, miscarriage, abortion, or within one year after end of pregnancy.

See provider eligibility guidance and PE4PP billing details.

Recommendation: A written recommendation by a physician or other licensed practitioner of the healing arts acting within their scope of practice is required to authorize doula services.

Recommendation requirement and documentation details must follow state scope rules.

Provider enrollment for claims: Fee-for-service claims must be submitted by a doula enrolled in Medi-Cal or an enrolled doula group; for Medi-Cal plan (MCP) members the doula must be contracted with the member's plan or have other arrangements with the plan to receive reimbursement.

Verify member Medi-Cal eligibility for month of service prior to billing.

Authorized services and limits

Services authorized by a recommendation include the following limits:

Visit counts: One initial visit plus up to eight additional prenatal/postpartum visits (in any combination); up to two extended three-hour postpartum visits after the end of pregnancy; an additional recommendation is required for up to nine further postpartum visits billed with HCPCS code Z1038.

Extended three-hour postpartum visits do not require additional member criteria; additional recommendation required for Z1038 units beyond standard visits.

Labor/delivery/abortion/miscarriage support: Support during labor and delivery (including stillbirth), abortion, or miscarriage is covered; labor/delivery CPT codes and abortion/miscarriage codes are limited to once per pregnancy.

Labor/delivery support codes limited to one per pregnancy; miscarriage/abortion support codes limited to once per pregnancy and require clinical confirmation or documentation as specified.

Extended initial and postpartum visit billing rules: The extended initial visit must be 90 minutes to bill with Z1032. All visits are limited to one per day per member and only one doula may bill for a visit to the same member on the same day (excluding labor and delivery). For extended postpartum visits lasting at least three hours, bill T1032 in 15-minute units (up to 12 units per visit) and up to two such visits per pregnancy.

The following services are not covered under the Medi‑Cal doula benefit. Doulas must inform members that other Medi‑Cal providers can render these services when requested: behavioral health services; belly binding after cesarean section performed by clinical personnel; clinical case coordination; health care services related to pregnancy, birth, and the postpartum period; childbirth education group classes; comprehensive perinatal services (orientation, assessment, planning); hypnotherapy (non‑specialty mental health); lactation consulting, group classes, and supplies; nutrition services (assessment, counseling, and development of a care plan); and transportation.

Additional specifically non‑covered items include: belly binding (traditional/ceremonial); birthing ceremonies (for example, sealing or "closing the bones"); group babywearing classes; maternal or infant massage; still and video photography; placenta encapsulation; shopping; vaginal steams; and yoga.

Doula services explicitly do not include diagnosing medical conditions, providing medical advice, or performing any clinical assessment, examination, or procedure. Doulas are not licensed clinical providers and must not represent or perform clinical care beyond nonmedical support.

If a member requests or requires a pregnancy‑related service that falls outside the doula benefit, the doula should notify the member that the requested service can be provided by another Medi‑Cal provider and, when appropriate, refer the member to that provider type (for example, lactation consultants for lactation support or clinical staff for medical care).

Doulas may teach classes that are available at no cost to individuals, including Medi‑Cal members to whom they provide services; however, when the requested service is specifically listed as non‑covered (see list of exclusions), the doula should direct the member to the appropriate Medi‑Cal provider or program.

When delivering services, doulas must remain within the nonmedical scope of the benefit and clearly communicate limits of the doula role to members. This includes advising members about alternatives for services not covered under the doula benefit and documenting any referrals or information given to the member.

Services that are not covered under the doula benefit are not billable as doula services; doulas and enrolled doula groups must follow Medi‑Cal billing rules and ensure claims include only covered doula codes paired with required ICD‑10 diagnosis codes.

Billing codes and diagnosis requirements

Covered CPT/HCPCS CodesmixedCovered

Z1032	Extended initial visit 90 minutes
Z1034	Prenatal visit
Z1038	Postpartum visit
T1032	Extended postpartum doula support, per 15 minutes
59409	Doula support during vaginal delivery only
59612	Doula support during vaginal delivery after previous caesarean section
59620	Doula support during caesarean section
T1033	Doula support during or after miscarriage
59840	Doula support during or after abortion

Required ICD-10-CM Diagnosis CodesICD-10

Z32.2	Encounter for childbirth instruction
Z32.3	Encounter for childcare instruction
Z33.1	Pregnant state, incidental
Z39.0	Encounter for care and examination of mother immediately after delivery
Z39.1	Encounter for care and examination of lactating mother
Z39.2	Encounter for routine postpartum follow-up

Extended initial visit duration — Z1032

Extended initial visit duration90 minutes required to bill HCPCS code Z1032; only one visit per day per member; only one doula may bill for the same member on the same day (excluding labor/delivery)

Billing constraintsExtended initial visit billed with Z1032 must be a single 90‑minute session; a prenatal or postpartum visit may be billed on the same day as labor/delivery, abortion, or miscarriage support (may be billed by a different doula)

General visit limitAll visits limited to one per day per member; labor/delivery visits are excluded from the single‑doula same‑day billing restriction

Extended postpartum visit units — T1032

Unit structureHCPCS T1032 billed in 15‑minute units for extended postpartum support

Documentation, recommendations, and billing operations

Prior Authorization

Second recommendation required for up to 9 additional postpartum visits

A second, separate written recommendation from a physician or other licensed practitioner acting within their scope of practice is required to authorize up to nine additional postpartum visits billed with HCPCS code Z1038; this additional recommendation cannot be established by standing order.

Applies only to additional postpartum visits billed with HCPCS code Z1038
The additional recommendation cannot be established by standing order

Prior Authorization

No prior authorization specified

No separate prior authorization form or programmatic prior authorization requirement is specified in the cited policy chunks for doula services.

Definitions and qualification pathways

Doula — definition, roles and scope

DefinitionA doula is a birth worker who provides health education, advocacy, and physical, emotional, and nonmedical support for pregnant and postpartum persons before, during, and after childbirth, including support during miscarriage, stillbirth, and abortion

ScopeProvides nonclinical services: health education, advocacy, physical and emotional support; does not perform licensed clinical assessments or require supervision

Role limitationsDoulas are not licensed or clinical providers and must not provide medical assessment, diagnosis, or clinical procedures

Full‑spectrum doula care — definition

DefinitionFull‑spectrum doula care includes prenatal and postpartum doula care, presence during labor and delivery, and doula support for miscarriage, stillbirth, and abortion

Services included

Background and scope

Doulas provide nonmedical physical, emotional, educational, and advocacy support across the perinatal period, including prenatal care, presence during labor and delivery, and postpartum care; support also extends to miscarriage, stillbirth, and abortion. Their role is to help prevent perinatal complications and improve outcomes through continuous, person‑centered support rather than by delivering clinical care.

As non‑clinical birth workers, doulas offer comfort measures, informational and emotional support, and assistance accessing community resources; they do not replace licensed clinical providers and must coordinate with the member’s care team when clinical assessment or medical intervention is needed.

Policy Summary

PayerCalifornia Department of Health Care Services

PolicyDoula Services — Coverage Criteria

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateN/A

Last ReviewMar 1, 2025

Next Review DateN/A

Key ActionObtain a written recommendation from a physician or other licensed practitioner to authorize doula services and document dates, duration, nature of care, and support time for each visit.

SourceLink

On This Page

90 minutes; T1032 up to 12 units per visit; up to 2 visits per pregnancy

When billing on same day as labor/delivery, special billing rules apply and modifier XP must be used for certain claims.

Up to 12 units per visit (equivalent to 3 hours)

Per‑pregnancy limitUp to 2 extended postpartum visits (24 units total) per pregnancy; visits must be on separate days

Billing noteExtended postpartum visits lasting at least three hours qualify for T1032 billing; standard one‑visit‑per‑day rule applies

Step Therapy

Use of PE4PP for specified doula codes

Specified doula services and codes may be delivered under the Presumptive Eligibility for Pregnant People (PE4PP) program; providers may deliver CPT 59840, HCPCS T1033, HCPCS Z1032, and HCPCS Z1034 under PE4PP per Part 2 guidance.

PE4PP applies to CPT 59840 (abortion support), HCPCS T1033 (miscarriage support), HCPCS Z1032 (extended initial visit 90 minutes), and HCPCS Z1034 (prenatal visit)
Refer to Part 2 of the Provider Manual (Presumptive Eligibility for Pregnant People: Billing Codes) for billing details

Documentation Required

Obtain written recommendation and document all services

A written recommendation from a physician or other licensed practitioner of the healing arts acting within their scope of practice is required to authorize doula services; doulas must also document dates, time/duration, nature of care provided, and the length of time spent with the member, and make documentation accessible to DHCS upon request.

The recommending licensed provider need not be enrolled in Medi‑Cal or in the member’s MCP network
Documentation examples should state activities and duration (e.g., 'Discussed childbirth education... for 1 hour')

Documentation Required

Retain training and experience documentation for DHCS review

Maintain evidence of completed training and continuing education and make it available to DHCS upon request; for the Experience Pathway retain three written client testimonial letters or professional letters of recommendation (written within the last seven years) with at least one letter from a licensed provider, community‑based organization, or enrolled doula.

Make completed training and continuing education records available to DHCS upon request
Experience Pathway requires three written letters (one from a licensed provider, CBO, or enrolled doula) dated within the last 7 years

Documentation Required

Document Training Pathway: 16 hours + 3 births

For the Training Pathway, retain documentation showing completion of a minimum of 16 hours of training covering specified topics (lactation support; childbirth education; pregnancy/childbirth anatomy; nonmedical comfort measures, prenatal support and labor support techniques; developing a community resource list) and verification of support at a minimum of three births.

Training must be at least 16 hours and cover the listed topic areas
Document verification of support at a minimum of three births

Note

Keep CPR and HIPAA certifications on file

Retain proof of current adult and infant CPR certification and evidence of completed basic HIPAA training as part of baseline qualifications.

All doulas must be at least 18 years old
Keep copies of adult/infant CPR certification and basic HIPAA training records for inspection

Billing Rule

Include required ICD‑10 diagnosis codes with each claim

Ensure each claim pairs the billed CPT/HCPCS code with one of the required ICD‑10‑CM diagnosis codes (Z32.2, Z32.3, Z33.1, Z39.0, Z39.1, Z39.2); failure to list an appropriate diagnosis with the billing code may cause claim denial.

For Z1032 use Z32.2, Z32.3, Z39.1, or Z39.2
For Z1034 use Z32.2 or Z32.3
For 59409/59612/59620 use Z33.1 or Z39.0
For 59840/T1033 use Z33.1
For T1032/Z1038 use Z39.0, Z39.1, or Z39.2

Note

Verify basic eligibility and member Medi‑Cal status

Confirm baseline eligibility and qualification requirements before enrollment or submitting claims: doulas must be at least 18 years old and possess adult/infant CPR and basic HIPAA training; verify member Medi‑Cal eligibility for the month of service for fee‑for‑service claims.

Verify member Medi‑Cal eligibility for the month of service for FFS claims
Baseline doula requirements: age ≥18, adult/infant CPR, basic HIPAA training

Denial Risk

Risk of denial if qualification pathways are not met

Not completing the Training Pathway (minimum 16 hours training plus support at ≥3 births) or failing to meet the Experience Pathway (≥5 years active doula experience within past 7 years plus required attestations) risks denial of enrollment or claims.

Training Pathway threshold: 16 hours of specified training and verification of support at minimum three births
Experience Pathway threshold: at least 5 years active doula experience within prior 7 years plus three written attestations

Note

Enrollment and contracting required for claim submission

Additional operational/provider actions: doulas submitting fee‑for‑service claims must be enrolled in Medi‑Cal or be part of an enrolled doula group; for Medi‑Cal MCP members, the doula must be contracted with the member’s plan or have other arrangements with the plan to be reimbursed.

Fee‑for‑service claims must be submitted by an enrolled doula or enrolled doula group
For MCP members, doulas must be contracted with the member’s plan or have other arrangements to provide services

Physical, emotional, and other nonmedical care across the perinatal period

Coverage implicationFull‑spectrum care is recognized by Medi‑Cal as within the doula benefit and may be provided across pregnancy, labor, and up to 12 months postpartum

Postpartum period — coverage window

Postpartum period lengthDoulas may provide services for up to 12 months from the end of pregnancy

Member coverageMembers are eligible to receive full‑scope Medi‑Cal coverage for at least 12 months after pregnancy

Service windowPostpartum doula services delivered within 12 months of pregnancy end fall within covered benefit period

Training Pathway — minimum training and requirements

Minimum training hoursComplete a minimum of 16 hours of training in specified topics (lactation support; childbirth education; anatomy of pregnancy and childbirth; nonmedical comfort measures, prenatal and labor support techniques; developing a community resource list)

Birth support requirementProvide support at a minimum of three births to satisfy the Training Pathway

DocumentationTraining completion must be documented and verification of support at minimum three births maintained and made available to DHCS upon request

Experience Pathway — experience and attestations

Experience durationAt least five years of active doula experience in a paid or volunteer capacity within the previous seven years

Attestation lettersThree written client testimonial letters or professional letters of recommendation required; letters must be written within the last seven years and one must be from a licensed provider, community‑based organization, or enrolled doula

Continuing educationDoulas must complete three hours of continuing education in maternal, perinatal, and/or infant care every three years and maintain evidence of training for DHCS review

Enrollment qualification criteria

Covered enrollment as a Medi-Cal doula provider requires ALL baseline items plus at least ONE of the two qualification pathways:

Baseline requirements: Must be at least 18 years old; possess adult/infant CPR certification; have completed basic HIPAA training; and maintain evidence of completed training and continuing education available to DHCS upon request.

Baseline items are required regardless of which pathway is used.

Qualification pathways

Training Pathway: Complete a minimum of 16 hours of training covering lactation support; childbirth education; foundations on anatomy of pregnancy and childbirth; nonmedical comfort measures, prenatal support and labor support techniques; and developing a community resource list; and provide support at a minimum of three births.16 hours; 3 births
Training completion and verification of support at three births must be documented.
Experience Pathway: At least five years of active doula experience in the previous seven years AND attestation demonstrated by three written client testimonial letters or professional letters of recommendation written within the last seven years, with at least one letter from a licensed provider, community-based organization, or enrolled doula.5 years experience; 3 letters
Letters must meet source and recency requirements described in policy.