To: Board of Supervisors
From: Dr. Grant Colfax, Health Services Director
Report Title: Contra Costa Health Plan Compliance Activities Report (October through December 2025)
☒Recommendation of the County Administrator ☐ Recommendation of Board Committee

RECOMMENDATIONS:
ACCEPT the Contra Costa Health Plan (CCHP) quarterly Compliance Activity Report for Quarter 4 (Q4) of 2025 as recommended by the CCHP Joint Conference Committee (JCC).
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 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 Report is included.
Summary:
During this period, the Compliance Department strengthened regulatory readiness across Medi-Cal, Medicare D-SNP, and Commercial lines of business while stabilizing the D-SNP Care Plus program launched on January 1, 2026. Key highlights:
• Regulatory Monitoring: All required submissions were timely except for a few remediated delays. No critical findings were identified. A $40,000 California Department of Managed Health Care (DMHC) sanction for 2018 audit deficiencies was resolved in January 2026.
• Audit Preparation: DMHC Financial Audit preparations missed initial internal deadlines due to competing priorities; revised timelines were set for February.
• Compliance Initiatives: Compliance Performance Improvement Workgroup (CPIW) projects are underway to enhance audit readiness and regulatory compliance.
• CalAIM Oversight: Enhanced Care Management (ECM) and Community Support Services (CSS) provider audits remain on schedule; corrective actions are in progress.
• Fraud, Waste & Abuse: No emerging risks; investigations and recoveries are in progress. Workforce training materials are in development.
• Privacy & Security: Low incident volume; no reportable breaches. Workforce training materials are in development.
CONSEQUENCE OF NEGATIVE ACTION:
If this action is not accepted, it could lead to non-compliance under the federal and state regulations.