Advisory Board: Contra Costa Health Plan Joint Conference Committee
Subject: Interim CEO Report
To: Joint Conference Committee (JCC) Members
From: Irene Lo, MD FACS; Chief Executive Officer (Interim)
Date: December 19, 2025
Subject: Interim CEO Report
The purpose of this report is to provide Joint Conference Committee members with key updates regarding Contra Costa Health Plan (CCHP) business and operations. These updates are intended to enhance transparency, reinforce the JCC’s advisory oversight role, and ensure alignment on important developments impacting our organization and membership.
1. CCHP Staffing Update
Purpose: To promote transparency and accountability regarding organizational leadership and staffing developments.
CCHP is actively working to reinforce leadership stability and operational readiness across departments. Recent efforts include interim leadership appointments, targeted recruitment for key vacancies, and role realignments to support emerging priorities-particularly in preparation for the launch of new lines of business such as the Dual Eligible Special Needs Plan (D-SNP). These changes are part of CCHP's broader commitment to ensuring continuity of essential services while positioning CCHP to meet current and future demands.
Department Specific Updates
• Overall
CCHP submitted position modification requests for FY 2026-2027 to strengthen operational effectiveness, reinforce organizational alignment, and ensure that the health plan remains well-positioned to meet its strategic, regulatory, and financial responsibilities in a rapidly evolving environment.
These proposals were developed with close alignment to the Alvarez & Marsal (A&M) organizational assessment, advancing clearer role delineation, enhanced accountability, and improved functional integration across the plan. CCHP also incorporated proactive planning for potential impacts related to HR1 and the state budget, ensuring CCHP maintains stability and continuity amid fiscal uncertainty.
The requests further anticipate operational needs as Contra Costa County moves toward expanding access to basic health care services. In addition, transitioning per diem nursing positions into permanent roles remains a key priority, supporting workforce stability, continuity of care, and reliable clinical operations-while also advancing long-term cost-containment efforts by reducing reliance on higher-cost temporary staffing.
• Clinical Operations
Within Clinical Operations, Dr. Nicolas Barcelo has been appointed Deputy Chief Medical Officer, and Dr. Sara Levin will be serving as Deputy Chief Medical Officer and Chief Health Equity Officer. Dr. Levin’s portfolio encompasses the Advice Nurse Unit, CalAIM programs, Case Management, Clinical Quality Auditing, and the Quality and Health Equity functions. Dr. Barcelo provides leadership over Appeals and Grievances, the Behavioral Health Department, Pharmacy Services, and Utilization Management. As Dr. Irene Lo serves as Interim CEO, reinforcing the leadership structure within Clinical Operations and clarifying spans of control have been essential to ensuring organizational stability, operational continuity, and aligned clinical oversight during this period of transition.
• Business Operations
Beth Hernandez has been appointed as CCHP’s Interim Chief Operating Officer and is providing critical operational leadership during this period of organizational transition. In this capacity, she oversees Claims; Marketing and Sales; Member Services; Provider Relations, Credentialing and Contracting; Personnel, Facilities and Safety; Analysis and Reporting; and the Project Management Office. Under her direction, these functions are advancing stronger operational discipline, improved cross-functional coordination, and tighter alignment with CCHP’s strategic priorities. Recruitment efforts across these operational areas will continue as we refine leadership structure and strengthen departmental capacity. Recruitment for the permanent COO role has also been launched.
Compliance Department
The Compliance Department is continuing to build the organizational infrastructure required to meet an increasingly complex regulatory environment. Chanda Gonzales will serve as the Director of Regulatory Affairs and Communication (RAC), providing leadership in regulatory interpretation, policy alignment, and coordination with County and state partners. Sunny Cooper will continue as Interim Senior Director of Compliance and Regulatory Affairs and will serve as CCHP’s designated Compliance Officer, Fraud Prevention Officer, and Privacy Officer, ensuring leadership continuity across all core compliance domains.
To strengthen departmental capacity, we have also brought on additional temporary staff to streamline responsibilities, support timely audit response and follow-up, and enhance coordination across internal teams. These additions bring valuable managed care expertise and operational experience, positioning CCHP to meet the requirements of DHCS, DMHC, CMS, and NCQA and to maintain a high level of readiness for current and future regulatory reviews.
• Project Management Office
CCHP has formally launched the Project Management Office (PMO) as a dedicated operational department to drive disciplined project execution, enhance organizational coordination, and strengthen accountability across all major initiatives. In coordination with Contra Costa Health, the CCHP PMO is establishing a consistent project management framework that includes standardized tools, governance structures, and reporting processes to support high-priority operational and strategic work.
The PMO provides centralized oversight for project planning, implementation, and performance monitoring, including development of project charters, use of Jira and collaboration sites, and deployment of uniform status reporting and dashboards. This structure ensures that initiatives are appropriately scoped, resourced, and aligned with enterprise-wide priorities.
A key early focus for the PMO is supporting the Performance Improvement Workgroups (PIWs) and advancing CCHP’s strategic priorities by building the infrastructure, templates, and coordination mechanisms needed to manage cross-functional work effectively. As CCHP moves forward with its transformation efforts, the PMO will play a critical role in ensuring that complex, interdependent initiatives progress cohesively and with clear accountability.
Dual-Special Needs Plan (D-SNP) Recruitment
In August 2025, CCHP received approval to add several critical positions in preparation for the D-SNP launch. These roles are foundational to strengthening our operational capacity, ensuring we meet complex regulatory requirements, deliver high-quality care coordination, and respond effectively to the needs of our members and provider partners. We have already filled several key positions, and additional recruitments are currently open or pending. Recruitment efforts continue, and we look forward to welcoming new colleagues who will further reinforce our infrastructure and support CCHP’s continued growth and readiness for this next phase.
Regulatory Coordination and Transparency
In accordance with regulatory requirements, CCHP has kept both the Department of Health Care Services (DHCS) and the Department of Managed Health Care (DMHC) informed of key leadership changes and vacancies.
In our most recent communication, DMHC expressed concern regarding the number of concurrent leadership vacancies. We acknowledged these concerns and emphasized our active recruitment efforts, noting that interim consultants are currently providing regulatory oversight and operational continuity in affected departments while permanent hires are being secured.
We anticipate another meeting with DMHC before the end of the year, during which they will assess our progress and review the status of permanent placements. CCHP remains fully committed to maintaining open, proactive communication with our regulators and to providing timely updates as recruitment advances and leadership roles are filled.
2. REGULATORY UPDATE
Purpose: To ensure the JCC is informed of evolving regulatory requirements and how CCHP is maintaining compliance.
CCHP continues to prioritize regulatory readiness through structured engagement with oversight agencies and internal corrective actions. Key updates are outlined below:
DMHC Audits
The DMHC Financial Audit is scheduled to begin in April 2026, with fieldwork commencing on April 6, 2026. Pursuant to Section 1382 of the California Health and Safety Code, the DMHC Division of Financial Oversight conducts routine financial examinations of each licensed health plan at least once every five years and publishes a public report for each plan. The purpose of these examinations is to evaluate and report on a plan’s compliance with the financial and administrative requirements of the Knox-Keene Act.
Each examination assesses a plan’s fiscal soundness, operational controls, and adherence to statutory obligations. Areas of review typically include claims processing and timeliness, provider dispute resolution practices, financial account management, oversight of delegated arrangements, premium and encounter data reporting, and compliance with required financial ratios and reserve levels.
Recent financial examination reports issued for other health plans have highlighted several recurring areas of concern across the industry. These commonly include deficiencies in claims accuracy and timeliness, inadequate documentation or monitoring of delegated entities, inconsistent or incomplete financial reconciliations, weaknesses in internal controls over accounting processes, and gaps in regulatory reporting or required disclosures. DMHC has also noted concerns related to staffing levels, leadership turnover, and insufficient segregation of duties in financial operations.
Given these trends, we anticipate that DMHC’s review of CCHP will place particular emphasis on claims operations, financial controls, reserve adequacy, administrative cost reporting, and the effectiveness of oversight structures. CCHP is preparing accordingly and remains committed to full transparency and proactive engagement throughout the examination process.
DMHC Enforcement Matters
Three enforcement matters remain under Department of Managed Health Care (DMHC) review.
• Enforcement Matter 22-710
o Pertains to 2021-2022 grievances involving a CCHP member delegated to Kaiser
o Received from DMHC: 4/4/2025
o Response provided to DMHC: 5/5/2025
o Received feedback from DMHC 8/28/2025
• DMHC found that there was sufficient evidence to establish a Plan violation of Health and Safety code section 1368.01, subdivision (b), and California Code of Regulations, title 28, section 1300.68.01, subdivision (a) (2)
• DMHC indicated that they would be willing to resolve this matter upon the payment of an administrative penalty of $70,000.
o CCHP sent an acknowledgement to DMHC on 9/12/2025, accepting the administrative penalty.
o Received Letter of Agreement from DMHC on 9/22/2025, indicating that payment of the administrative penalty is due 10/10/2025.
o CCHP submitted payment of administrative penalty by 10/10/2025
o CCHP finance confirmed that DMHC cashed the payment on 10/23/2025
• Enforcement Matter 23-348
o Stems from deficiencies that remain unresolved from DMHC’s 2019 Routine Survey
o Received from DMHC: 6/4/2025
• DMHC found that the Plan violated Health and Safety Code section 1380, subdivision (i)(1), by failing to resolve an identified deficiency to the director’s satisfaction within a reasonable period of time.
• DMHC indicated that they would be willing to resolve this matter upon the payment of an administrative penalty of $40,000 and submission of a proposed corrective action plan (CAP) for review/approval by the Department’s Office of Enforcement
o CCHP sent an acknowledgement to DMHC on 6/16/2025, accepting the administrative penalty. CCHP also submitted a proposed CAP.
o Status: Awaiting response from DMHC regarding CAP
• Enforcement Matter 24-143
o Focuses on interrogatories related to behavioral health services, including timely access to care, prior authorization practices, claims payments, provider satisfaction, staff training, and call center operations
o Received from DMHC: 3/26/2025
o Response provided to DMHC: 4/25/2025
o Status: Awaiting response from DMHC
3. D-SNP PROGRESS UPDATE
Purpose: To provide oversight on one of CCHP’s most significant programmatic expansions and ensure awareness of key milestones.
Background
Contra Costa Health Plan (CCHP) is preparing to launch Contra Costa Health Care Plus, a Medicare-Medi-Cal Dual Special Needs Plan (D-SNP) on January 1, 2026. This launch represents a major organizational milestone and an important opportunity to better serve dual-eligible individuals through a more coordinated, person-centered model of care.
Current Progress
CCHP continues to make strong progress toward the D-SNP launch, with work concentrated in three key areas: regulatory milestones, operational readiness, and oversight infrastructure.
CCHP is currently in the Annual Enrollment Period (AEP), and enrollment is underway. We have enrolled nearly 150 members, and outreach and education efforts continue to ensure eligible beneficiaries understand their options and receive timely support.
• Operational Readiness
Operational workstreams continue to advance, including:
o Finalizing agreements with vendors supporting key D-SNP functions.
o Advancing provider contracting to meet CMS and DHCS network adequacy standards.
o Refining workflows and configuring internal systems to support implementation.
o Conducting D-SNP education and outreach, including staff training and provider engagement.
o Ongoing recruitment for critical D-SNP roles to ensure readiness and sustainability
• Regulatory Readiness and Oversight
CCHP is finalizing Medicare-aligned policies and procedures, strengthening the Medicare Compliance Program, and building the oversight infrastructure required for long-term success as a Medicare plan. This includes establishing monitoring, reporting, and governance structures that meet CMS and DHCS expectations.
• Health System & Community Alignment
CCHP continues to coordinate closely with Contra Costa Health-including Contra Costa Regional Medical Center (CCRMC) and Health Centers-to ensure systemwide alignment. CCHP is also engaging the Safety Net Council, which includes Federally Qualified Health Centers, as well as key external providers across the county, to prepare the broader provider network for integrated care delivery.
Risk Management & Challenges
CCHP is actively monitoring and mitigating risks:
• Workforce Readiness: Recruitment for Medicare-specific expertise remains a priority; mitigation includes phased onboarding and cross-training.
• Regulatory Oversight: CMS and DHCS impose extensive requirements; mitigation includes early submission of deliverables, mock audits, and strengthened compliance monitoring.
• Network Adequacy: Ensuring sufficient specialty, behavioral health, primary care, and hospital capacity remains challenging; mitigation includes targeted contracting and close coordination with CCRMC/HC and external providers.
• Operational Complexity: Integrating Medicare and Medi-Cal systems requires robust oversight; mitigation includes structured testing, vendor monitoring, and readiness drills.
Next Quarter Priorities
The first three months following the D-SNP launch will be critical for establishing operational stability, demonstrating regulatory readiness, and ensuring a positive experience for new members and providers. CCHP’s priorities for Q1 2026 include:
• Member Onboarding and Care Coordination - CCHP will focus on timely completion of Health Risk Assessments, development of individualized care plans, and assignment of care coordinators for all newly enrolled members. Early outreach, welcome calls, and care transitions support will be central to building trust and ensuring continuity of care.
• Operational Performance Monitoring - We will actively monitor key operational indicators-including claims accuracy and timeliness, encounter data submission, call center performance, enrollment file processing, and grievance and appeals activity-to identify trends quickly and resolve issues before they escalate.
• Regulatory Compliance and Reporting - The first quarter requires completion of initial CMS and DHCS monitoring activities, including reporting, oversight meetings, and compliance attestations. CCHP will ensure strict adherence to Medicare Advantage regulatory expectations and maintain continuous communication with regulators.
• Provider Engagement and Issue Resolution - CCHP will continue targeted provider outreach to address operational questions, support adoption of Medicare requirements, and ensure providers have the resources and clarity needed to serve D-SNP members effectively.
• Network Adequacy and Access Monitoring - As utilization patterns emerge, CCHP will monitor network capacity, appointment availability, and access metrics to ensure compliance with CMS and DHCS standards and to identify any areas that may require additional contracting or targeted interventions.
• Workflow Refinement and Staffing Optimization - Based on early operational experience, CCHP will refine workflows, adjust staffing allocation as needed, and strengthen cross-functional coordination to enhance efficiency and ensure sustained readiness.
• Preparation for Early CMS Deliverables - The organization will prepare for initial CMS-required submissions associated with the first quarter of operations, including reporting packages, monitoring requests, and any follow-up documentation from the implementation review process.
Next Steps and Ongoing Commitment
CCHP remains deeply committed to launching a high-quality, fully compliant D-SNP that enhances care coordination, supports member needs, and advances accessible, comprehensive care for Contra Costa’s dual-eligible population. Regular updates will continue to be provided to the Joint Conference Committee as implementation progresses.
4. Organizational Transformation Update
Overview of 2025 Organizational Transformation Work
2025 was a foundational year for Contra Costa Health Plan (CCHP), beginning with a transition to new interim leadership at the Plan. This change provided an important opportunity to take a fresh look at long-standing challenges, reassess organizational priorities, and realign operations to better meet regulatory expectations, operational demands, and systemwide needs.
During this period, Contra Costa Health also welcomed new departmental leadership, establishing clearer expectations, stronger alignment across the integrated delivery system, and improved collaboration with CCHP. These system-level changes created momentum for deeper coordination between the Plan and key delivery system partners.
As part of this broader alignment effort, CCHP completed a comprehensive Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis, which identified key opportunities to improve workflow efficiency, cross-departmental coordination, data utilization, internal communication, fiscal literacy, and governance.
CCHP also underwent an organizational and operational assessment by Alvarez & Marsal (A&M). This evaluation highlighted structural and operational gaps and provided actionable recommendations to strengthen accountability, streamline processes, clarify roles, and modernize core functions.
Together, these leadership transitions, assessments, and alignment efforts laid the foundation for the organizational progress achieved throughout 2025.
Organizational Assessment & Structural Alignment
Following the SWOT analysis and A&M assessment, CCHP began strengthening its internal infrastructure by:
• Clarifying leadership roles and spans of control
• Reinforcing expectations around accountability and performance
• Updating internal processes to improve operational consistency
• Enhancing cross-departmental alignment to reduce silos
These efforts improved clarity, coordination, and stability across key functions.
Integration With Contra Costa Health
CCHP strengthened its relationships with the broader CCH integrated delivery system through enhanced coordination with key partners. Major accomplishments included:
• Enhanced collaboration with CCRMC/Health Centers, Public Health, Behavioral Health, and H3
• Joint planning with Behavioral Health and H3 on the launch of Transitional Rent, a new CalAIM Community Support going live January 1, 2026, including workflow design, model of care development, and cross-system coordination.
These efforts reinforced CCHP’s role as a managed Medi-Cal plan embedded within a coordinated county health delivery system.
Provider Network Engagement & Communications
As part of its 2025 transformation efforts, CCHP expanded its provider engagement and communication infrastructure to strengthen transparency and alignment.
• Closer collaboration with providers - CCHP enhanced its collaboration with providers in the CCHP network to further strengthen alignment on access, quality, care coordination, and member experience.
• Enhanced Joint Operations Meetings - CCHP modernized Joint Operations Meetings with CCRMC/Health Centers and contracted provider groups, implementing structured agendas, discussion of key issues and metrics, and systematic follow-up to support accountability.
• Provider Newsletter - The Plan introduced a redesigned Provider Newsletter, offering timely updates on operational changes, regulatory requirements, quality initiatives, and network expectations.
• Safety Net Council Engagement - CCHP leveraged the Safety Net Council as a platform for coordinated communication with Aliados Health, external FQHCs, and community clinics, supporting improved access, quality, and readiness for new benefits such as D-SNP.
Establishment of the Project Management Office (PMO)
CCHP launched a Project Management Office to formalize project governance and improve oversight across initiatives. Key accomplishments included:
• Developing standardized project charters, templates, and documentation
• Establishing Jira-based project tracking and centralized PMO infrastructure
• Supporting leadership with structured reporting on milestones and risks
The PMO will serve as a central coordinating body for CCHP’s operational improvement work.
Performance Improvement Workgroups (PIWs)
CCHP established Performance Improvement Workgroups to coordinate improvement efforts across core operational areas. In 2025, PIWs:
• Held kickoff meetings
• Developed charters and defined deliverables
• Improved collaboration across departments
• Aligned with CCH’s divisional PIWs for systemwide cohesion
The PIW structure is now embedded as a central mechanism for operational improvement and oversight.
Dashboards and Reporting Infrastructure
In 2025, CCHP made important progress in building the foundation for a modern, data-driven reporting system to support transparency, accountability, and informed decision-making across the organization.
Key accomplishments included:
• Initial development of core dashboards that provide visibility into financial performance, claims operations, utilization management, provider network status, member experience, quality, and D-SNP readiness.
• Initial development of the key metrics needed to support consistent reporting and improve organizational insight into operational performance.
These efforts represent an important shift toward a more data-driven culture, strengthening CCHP’s ability to monitor performance, support regulatory readiness, and drive improvement through transparent and reliable information.
Regulatory Readiness Improvements
CCHP made progress improving its regulatory posture in preparation for DHCS, DMHC, CMS, and NCQA oversight. Accomplishments included:
• Strengthening policy and procedure management
• Enhancing delegation oversight
• Initiating internal monitoring and early mock audit preparation
• Increasing coordination between Compliance and Operations
• Maintaining proactive communication with regulators
These improvements increased readiness for upcoming reviews and surveys.
D-SNP Readiness and Medicare Integration
Throughout 2025, CCHP advanced critical work for the January 1, 2026, launch of the Dual Eligible Special Needs Plan (D-SNP). Major accomplishments included:
• CMS approval of 2026 contracting documents
• Initial enrollment during the 2025 Annual Enrollment Period
• Development of Medicare-compliant policies, procedures, and oversight structures
• Completion of operational readiness testing with vendors and internal systems
• Recruitment of staffing needed to support operational and compliance work associated
with D-SNP
This work laid the foundation for CCHP’s Medicare entry.
Financial Literacy & Internal Education
In 2025, CCHP launched a series of internal education initiatives to strengthen organizational understanding of key operational, fiscal, and regulatory concepts. These efforts were designed to support more informed decision-making, improve cross-departmental alignment, and reinforce a shared knowledge base across the Plan.
Key accomplishments included:
• Financial literacy sessions to improve understanding of medical cost drivers, PMPM trends, MLR/ALR components, and fiscal impacts across operational areas.
• CCHP 101 Educational Series, a foundational curriculum providing staff with an overview of CCHP’s structure, operations, lines of business, regulatory landscape, and role within the Contra Costa Health system.
• D-SNP Educational Series, offering targeted training on Medicare concepts, integrated care models, CMS requirements, member communication standards, and operational changes associated with D-SNP implementation.
These initiatives supported CCHP’s transition toward a more knowledgeable, aligned, and data-informed culture.
Alternative Health Care Program Preparation
In 2025, CCHP supported Contra Costa Health’s early discussions regarding an alternative health care program.
Conclusion
CCHP made significant progress in 2025 to strengthen internal operations, modernize infrastructure, enhance provider and system integration, and prepare for new lines of business. The establishment of the PMO, launch of PIWs, expansion of provider engagement, development of dashboards, and preparation for the D-SNP launch represent major steps forward in building a more aligned, accountable, and high-performing managed care organization.
At the same time, meaningful opportunities for improvement remain-including strengthening core operational functions, improving data integration, enhancing financial and regulatory readiness, deepening collaboration with system partners, and continuing to build organizational capacity. The foundation established in 2025 positions CCHP to address these opportunities with greater discipline, coordination, and momentum.
CCHP enters 2026 with stronger alignment, clearer structures, improved accountability mechanisms, and a renewed commitment to continued transformation and operational excellence.
5. COMMUNITY SUPPORTS
Background
Community Supports (CS), a key component of CalAIM, provide voluntary, health-related services aimed at addressing social drivers of health and supporting alternatives to higher levels of care. Health plans are required to annually assess each service for utilization, impact, operational feasibility, and sustainability.
In 2025, CCHP completed a comprehensive review of its CS portfolio. Based on this assessment, three services were identified for discontinuation due to low utilization, operational challenges, redundancy, and limited return on investment (ROI):
1. Asthma Remediation
2. Day Habilitation
3. Personal Care & Homemaker Services
These services also have existing alternatives available through County divisions, community programs, or Medicaid-funded benefits.
Next Steps
• CCHP has formally notified the Department of Health Care Services (DHCS) of its intent to discontinue three Community Supports-Asthma Remediation, Day Habilitation, and Personal Care & Homemaker Services- effective January 1, 2026.
• DHCS has informed CCHP that, per contractual and policy requirements, discontinuation of these Community Supports cannot occur earlier than December 31, 2026.
• CCHP has requested a meeting with DHCS to discuss further.
CONCLUSION
In summary, while CCHP had notified DHCS of its intent to pursue discontinuation of Asthma Remediation, Day Habilitation, and Personal Care & Homemaker Services effective January 1, 2026, DHCS has advised that, under contractual and policy requirements, these services may not be discontinued prior to December 31, 2026. CCHP has requested a meeting with DHCS to further discuss this determination and clarify expectations for any future discontinuation.
In parallel, CCHP will maintain an ongoing evaluation of its Community Supports portfolio throughout 2026 to ensure sustainability, alignment with member needs, provider capacity, operational viability, and broader Contra Costa Health priorities, subject to DHCS review and approval.