The CMS Plan Transition to Molina: What Providers Need To Know
Updated: 3 days ago
In January of 2026, Sunshine Health assumed direct management of its expressive therapies network in Florida from Medical Transportation Management. That change and the concerns surrounding it were covered across the state, including by this publication. Now, on October 1, the entire CMS Health Plan will transition from Sunshine to Molina Healthcare, another major insurer in Medicaid managed care. This article is intended to provide clarity about what this means for members and the expressive therapy providers who serve them.
What is CMS?
Children’s Medical Services (CMS) Managed Care Plan (“CMS Plan”) is a health plan for children with special health care needs who qualify either through Florida Medicaid (Title XIX) or Florida KidCare (Title XXI). As part of the Department of Health’s (DOH) broader Children's Medical Services program, the plan provides essential services to qualifying children who require extensive preventive and ongoing care.
Previously, DOH administered the CMS Plan contract. On July 1, 2025, that responsibility transferred to the Florida Agency for Health Care Administration (AHCA), while DOH retained responsibility for determining clinical eligibility. Since the transfer, the roles of those entities have looked like this:
Medicaid eligibility is determined at the Department of Children and Families (DCF). Florida Healthy Kids determines eligibility for the Title XXI option.
DOH determines whether the child meets the CMS Plan’s special health care needs criteria.
AHCA administers and oversees the CMS Plan contract.
Sunshine Health serves enrolled members under that contract.
In short, AHCA oversees the plan’s contract while the Department of Health determines whether children meet its clinical eligibility requirements. Sunshine Health (a subsidiary of Centene) has operated the plan under the oversight of AHCA.
On October 1, Molina Healthcare will replace Sunshine as the sole operator of the CMS Plan.
Why is Sunshine No Longer Managing the CMS Plan?
Florida periodically awards managed care contracts through competitive procurement. On July 1, 2025, administration of the existing CMS Managed Care Plan contract transferred from DOH to AHCA. Then, on November 3, AHCA announced its decision to award the next CMS Plan contract to Molina Healthcare.
According to the Home Care Association of Florida, Sunshine did not plan to challenge the award at that time, citing terms in the final procurement document it could not accept. The timing of the announcement, however, has raised questions for some. The decision followed a difficult period for expressive therapy providers and families. During 2025, providers reported payment and credentialing problems involving the network managed by Sunshine’s contractor, Medical Transportation Management (MTM). Sunshine also changed its guidance on the frequency of new expressive therapy authorizations. In October, Sunshine announced that it would end MTM’s role and manage the network directly beginning January 2026. Those events are important context for providers facing another transition; however, the publicly available information does not establish that they caused AHCA to ultimately select Molina.
What is certain is the practical change: Molina is scheduled to replace Sunshine as the CMS Plan operator on October 1. AHCA will continue to oversee the contract, and DOH will continue to determine clinical eligibility. The pressing question for members and providers is how Molina will handle network participation, authorizations, payment, and continuity of care during the transition.
Sunshine Health also continues to offer expressive therapy services to eligible members of its other Medicaid plans. Those plans are separate from the CMS Plan moving to Molina.
What’s Staying the Same
Children and families currently served by CMS do not have to reapply for coverage and will automatically transition to Molina on October 1. AHCA states their services and benefits will remain the same during the transition. The scope of responsibilities for the entities involved will also remain the same: AHCA will continue to oversee the plan contract while DOH will continue to determine clinical eligibility.
Molina and AHCA are working to ensure continuity of care. According to AHCA, existing appointments and prescriptions will be honored, and providers should continue delivering services. Molina says it will accept active Sunshine authorizations during the applicable continuity of care period. Providers, however, will need to request authorization from Molina for new services and for continued services after an existing authorization expires.
What’s Changing
Unlike member services, provider contracts do not transfer, so providers who want to remain in the CMS network must contract with Molina directly. That means providers will be working under a new agreement, with terms they should review carefully before signing. This article will not reproduce Molina’s agreement, but providers should pay close attention to its requirements for authorizations, documentation, claims, and payment.
What Remains Unclear
As of publication, Molina has provided guidance on submitting authorization requests and honoring existing Sunshine authorizations during the transition. But expressive therapy providers still need clearer answers about how Molina will evaluate new and continuing treatment after those authorizations expire.
A proposed provider agreement lists separately billed expressive therapy services, while a more recent Molina presentation describes expressive techniques used within PT, OT, and speech therapy and directs behavioral health music and art therapy requests through a different pathway. Molina has not yet clarified how these descriptions relate to one another.
Some of the biggest questions providers currently have include:
Standalone services: Will Molina authorize music and art therapy delivered by expressive therapy providers as standalone services? How does that pathway relate to Molina’s recent guidance about expressive techniques used within PT, OT, and speech therapy?
Authorization limits: What clinical criteria will Molina apply, and how many sessions or units will it authorize per week and per authorization period?
Multiple therapies: Can a member receive more than one type of expressive therapy, and will authorization of one affect authorization of another?
Billing instructions: What final codes and modifiers should providers use for each service and delivery format?
Telehealth payment: Will Molina revise the proposed telehealth rate following providers’ request for reconsideration?
Care during the transition: What rate and billing method will apply to authorized services delivered during the continuity of care period by providers without a Molina contract?
Agreement requirements: Which insurance and record retention provisions apply to expressive therapy practices?
Implications for Members and Providers
AHCA’s continuity of care guidance is designed to prevent an immediate interruption in services. It does not, by itself, guarantee that every family will retain access to the same provider over the longer term. Sunshine contracts will not transfer to Molina. Providers must decide whether to enter a new agreement to remain in Molina’s CMS network beyond the continuity of care period, or stop serving CMS Plan members after that period. How those decisions affect access - particularly in areas with fewer available therapists - remains to be seen.
The proposed telehealth rate is one issue providers are weighing. The proposed provider agreement lists a lower reimbursement rate for telehealth music therapy than for in-person music therapy. A provider update shared with Clinical Praxis says a request to reconsider that rate has been sent to Molina leadership. Until Molina responds, it would be premature to say whether the final arrangement will make virtual services less available. It is nevertheless a consequential question for families who rely on remote care.
The transition also adds to providers’ administrative responsibilities. MTM’s expressive therapy portal provided a dedicated place to manage authorizations and claims. Molina uses Availity for provider functions, including authorization requests, and has published transition guidance for existing Sunshine authorizations. Providers will need to learn Molina’s requirements for verifying coverage, requesting continued services, documenting medical necessity, submitting accurate claims, and potentially coordinating with other disciplines (such as speech and occupational therapists) to ensure compliant billing.
And those tasks have financial consequences - some rather significant. An authorization supports treatment, but providers must also establish that the member was eligible on the date of service, follow the applicable billing rules, and keep records that support the care delivered. Clear clinical documentation will matter when requesting additional treatment and responding to a denial or review. It will also become a critical component for how providers substantiate submitted claims if or when audits occur. The questions Molina has not yet answered about expressive therapy criteria and billing make it especially important for providers to obtain written guidance and keep track of what they submit.
What Providers Should Do Now
Providers currently serving CMS Plan members should prepare for the October 1 transition at the level of each patient and each practice:
Review current authorizations. Record the services, approved units, expiration dates, and remaining visits for each member. Molina says it will honor active Sunshine authorizations during the applicable continuity of care period, but continued services will require a request to Molina when an authorization expires.
Decide whether to join Molina’s network. Sunshine contracts will not transfer. Providers who wish to serve CMS members beyond the continuity of care period should review Molina’s agreement, complete the contracting process, and confirm their status directly with the plan.
Prepare for Molina’s workflows. Verify each member’s coverage before providing services, learn how to submit authorization requests and claims, and retain copies of approvals, submissions, and correspondence.
Seek written answers to unresolved questions. Before relying on an assumed session limit, billing modifier, telehealth rate, or interpretation of the agreement, ask Molina for clarification and keep its response.
Providers should also communicate with families about any potential change in their network status while continuing care under the applicable transition guidance.
Conclusion
For members, the October 1 change is designed to preserve coverage and ongoing care. For expressive therapy providers, it brings a new contract, new administrative processes, and important questions that Molina has yet to answer. Those provider decisions will help determine how smoothly the promised continuity translates into access to care.
The most useful response now is careful preparation. Know which services are already authorized, understand when a new request is needed, review the terms of participation, and document care in a way that clearly supports its clinical purpose. Clinical Praxis will continue to follow Molina’s guidance as these outstanding questions are resolved.
For providers preparing for these changes, strong clinical documentation is one part of being ready. Telos Music Therapy’s upcoming webinar, Clinical Music Therapy Documentation in Insurance-Funded Care, will focus on documenting the clinical need for services and the care delivered in insurance-funded settings.
The webinar will be held on November 7, and is approved for 3 CMTEs (1 ethics credit). Registration is open and available here.
To contact Clinical Praxis with questions, updates, or interest in publishing, follow this link.
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