To: Board of Supervisors
From: Dr. Grant Colfax, Health Services Director
Report Title: Contra Costa Health Plan Compliance Activities Report (January through March 2026)
☐Recommendation of the County Administrator ☒ Recommendation of Board Committee
RECOMMENDATIONS:
ACCEPT the Contra Costa Health Plan (CCHP) Compliance Quarterly Activity Report for January through March 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.
During this reporting period, the CCHP Compliance Department continues to strengthen regulatory readiness across Medi-Cal, Medicare D-SNP and Commercial lines of businesses. CCHP Compliance Department is also stabilizing the D-SNP Care Plus program launched on January 1, 2026. Here are key highlights:
• Regulatory Monitoring: All required submissions were timely except for a few remediated delays. No critical findings were identified.
• Enforcement Matter: On March 13, 2026, the Department of Managed Health Care (DMHC) issued a follow‑up subpoena requesting additional information related to Enforcement Matter 24‑143. This interrogatory investigation sought the corrective action plans the Plan submitted in May 2023 to address deficiencies identified during the 2021 Mental Health and Substance Use Disorder investigation. The Plan submitted all requested supporting documents to DMHC timely, meeting the submission deadline on April 13, 2026. This remains an area of operational risk and the Plan continues to monitor it closely.
• Audit Findings: DHCS has issued the final report for the 2025 Medical Survey Audit, identifying nine findings. The complete set of corrective action plans was submitted to DHCS on April 20, 2026. On May 4, 2026, DHCS responded by requesting additional supporting documentation. This is due back to DHCS on May 28, 2026.
• DMHC Financial Audit: Plan staff submitted approximately 4,475 supporting documents in preparation for the DMHC Financial Audit. The audit team also conducted multiple mock audit sessions, along with internal reviews and discussions. This was to ensure readiness. Virtual interview sessions began with the entrance conference on April 6, 2026. The auditors completed their final interview session on May 5, 2026. An exit conference is expected at the end of May.
• DMHC Follow-Up Survey: DMHC has initiated a Follow‑Up Review to assess outstanding deficiencies from the 2025 Final Report tied to the 2022 Full Scope Medical Survey. Virtual interviews are scheduled to begin on August 31, 2026. Between May and early June, the Plan must submit required questionnaires, logs and evidence of compliance for sampled cases. Internal mock audits are planned for August. Compliance is coordinating preparation across all affected operational areas. The operational areas include Claims, Appeals and Grievances, Information Technology (IT), Member Services, Pharmacy, Quality and Health Equity, Provider Network Operations, Clinical QA and Utilization Management. The preparation with all operational areas is to ensure timely and complete responses are submitted to all pre‑onsite requests.
• Compliance Initiatives: Compliance Performance Improvement Workgroup (CPIW) initiatives are progressing. The priority is on establishing a Policy Management Program. While work is moving forward, the project is currently not on track due to competing organizational priorities, regulatory audits and limited resources. The project team continues to actively monitor and mitigate risks when identified.
• Third-Party Oversight: Though slow, Enhanced Care Management (ECM) and Community Support Services (CSS) provider corrective actions are in progress. The team is working with these non-traditional providers closely to ensure progress is made. Staff plans to start more formal corrective discussions with select ECM providers who have not completed their Corrective Action Plans (CAPs) on time. Continued noncompliance may result in contract termination.
• Fraud, Waste & Abuse (FWA): No emerging risks; investigations and recoveries are in progress. The Plan has started issuing recoupment letters to four providers because of our FWA investigation. The total recoupment amount issued to the four providers was approximately $7,856,000.
• Privacy & Security: There is currently a low incident volume. There are no reportable breaches. Compliance Department is developing workforce training materials.
Overall, compliance health is stable and trending positively. CPIW initiatives continue to address the identified gaps.
CONSEQUENCE OF NEGATIVE ACTION:
If this action is not accepted, it could lead to noncompliance under the federal and state regulations.