To: Board of Supervisors
From: Dr. Grant Colfax, Health Services Director
Report Title: Contra Costa Health Plan Compliance Activities Report (April through June 2026)
Recommendation: Recommendation of the County Administrator
RECOMMENDATIONS:
ACCEPT the Contra Costa Health Plan (CCHP) Compliance Quarterly Activity Report for April through June of 2026, as recommended by the CCHP Joint Conference Committee.
FISCAL IMPACT:
There is no fiscal impact for this action.
BACKGROUND:
To promote transparency and accountability, CCHP quarterly submits the Compliance Activities Report for review by the governing body. The Compliance Activities Report provides required oversight information on the effectiveness of the Plan’s Compliance Program, the status of key compliance activities, and any significant risks or issues that warrant attention, in accordance with Department of Health Care Services (DHCS), Centers for Medicare and Medicaid Services (CMS) contractual obligations and Knox Keene Act of 1975 for Medi-Cal, Commercial and Medicare D-SNP managed care regulations. Attachment A - Compliance Quarterly Activities Report is included.
This reporting period has been marked by significant achievements, proactive risk management, and continued progress in compliance initiatives. Here are key highlights:
• Regulatory Monitoring: All required regulatory submissions were completed on time. There were only minor delays that were swiftly remediated. The Compliance Department successfully monitored and disseminated regulatory changes. This includes HPMS guidance, DHCS contract amendments and updates to regulatory management processes. No critical findings were identified in this period. This underscores our robust compliance posture.
• Operational Challenges: The team overcame operational hurdles related to regulatory submission portals. This included troubleshooting DHCS, DMHC and CMS reporting systems. Intensive recruitment efforts and panel interviews were conducted alongside ongoing regulatory audits. This demonstrates our capacity to balance multiple priorities. High-volume regulatory communications were reviewed rapidly, ensuring timely compliance with evolving requirements.
• Audits and Enforcement Highlights:
o 2022 DMHC Financial Audit: On June 11, 2026, DMHC issued Enforcement Matter 23-331 for the 2022 DMHC Financial Audit findings. This resulted in a $75,000 administrative penalty. The Plan accepted the penalty, with most findings already remediated.
o 2022 Behavioral Health Investigation (Commercial plan only): On August 5, 2026, DMHC issued Enforcement Matter 24-143. DHMC imposed a $300,000 administrative penalty related to the Behavioral Health Investigation (BHI) initiated in 2022. The penalty was also related to two subsequent interrogatory investigations conducted in 2025 and 2026. The Plan reviewed and responded to DMHC’s findings and submitted a formal rebuttal to the penalty assessment on August 18, 2026. CCHP is waiting for DMHC’s review of Plan’s rebuttal and will continue to keep the JCC members apprised of material developments.
o 2023 DHCS Focused Audit: On July 31, 2026, DHCS issued a notice to the Plan closing nine CAPs resulting from the 2023 Focused Audit on Mental Health and Transportation Services. This notice means that DHCS accepted the corrective actions submitted and the audit is officially closed.
o 2024 Medical Survey Audit: On August 11, 2026, DHCS issued a notice to the Plan closing 19 CAPs resulting from the 2024 Medical Survey Audit. This notice signaled that DHCS accepted the corrective actions submitted and the audit is officially closed.
o 2025 DHCS Medical Survey Audit: The 2025 Medical Survey Audit identified nine findings. Of the nine corrective action plans submitted, five have been closed. The Plan submitted the fourth round of updates to DHCS at the end of July for the four remaining CAPs. Those CAPs required additional clarification and pending deliverables.
o 2026 DMHC Financial Audit: The 2026 audit concluded with one finding related to late claim payment interest calculation. The finding was promptly remediated. The preliminary report is expected soon.
o 2026 DMHC Medical Follow-Up Survey Audit: Preparation is complete for the upcoming audit, with all universe files and supporting documents submitted on time. Internal mock audits have been conducted during the first two weeks of August. The mock audits prepared team members for the interviews with the DMHC auditors. The interviews started on August 31, 2026.
• Compliance Initiatives: The Compliance Performance Improvement Workgroup (CPIW) continues to advance key projects, including the launch of the Policy Management Program (PMP) and the first Policy Management Committee (PMC) meeting. The Plan is updating policies with identified policy owners and establishing standardized workflows. Recruitment for two Planner and Evaluator Level B positions and two Compliance Director positions have closed. Onboarding was completed between late July and early September. The compliance dashboard reflects strong progress, with several initiatives nearing completion.
• Third-Party Oversight: With the newly onboarded staff, the Audit and Oversight Program (AOP) implementation has been initiated. This was done by reviewing the Plan’s vendor contracts to determine delegation status. The Audit and Oversight team will continue developing the AOP per the workplan.
• Fraud, Waste and Abuse (FWA): There are no emerging risks. There are 41 active investigations and recoveries in progress. The Plan has issued recoupment letters to eight providers because of our FWA investigation. The total recoupment amount issued to the eight providers was $15,153,153.
• Privacy and Security: Incident volume remains low. Three breaches were identified and promptly addressed through member notifications and staff coaching. The HIPAA Privacy Incidents dashboard shows stable trends, with proactive measures in place to maintain compliance.
• Mandatory Compliance Training: The Compliance Department continues to work with individuals who have not completed the 2026 training and their supervisors to ensure 100% compliance is achieved. FWA Training has been assigned to all CCHP Workforce on August 5, 2026. CCHP staff has 30 business days to complete the training from the date of assignment.
Overall, CCHP’s compliance health is stable and trending positively. Compliance continues to address gaps, innovate processes and uphold the highest standards of regulatory readiness. We celebrate the dedication and achievements of our team and look forward to continued success in the coming quarter.
CONSEQUENCE OF NEGATIVE ACTION:
If this action is not accepted, it could lead to noncompliance under the federal and state regulations.