To: Board of Supervisors
From: Dr. Grant Colfax, Health Services Director
Report Title: Payment Services Provided by mPulse Mobile, Inc.
☒Recommendation of the County Administrator ☐ Recommendation of Board Committee
RECOMMENDATIONS:
APPROVE and AUTHORIZE the Auditor-Controller, or designee, to pay mPulse, Mobile Inc. an amount not to exceed $98,000 to provide Contra Costa Behavioral Health (CCBH) with a secure, standards-based Provider Directory Application Programming Interface (API) compatible with the Fast Healthcare Interoperability Resources (“FHIR”) standard for Mental Health service providers as required by United States Department of Health and Human Services final rule CMS-9115-F, 85 FR 25510 during the period of December 23, 2024 through October 7, 2025.
FISCAL IMPACT:
Approval of this action will result in a one-time expenditure of up to $98,000 and will be funded by Mental Health Realignment funds.
BACKGROUND:
On July 27, 2023, the California Department of Health Care Services (DHCS) published Behavioral Health Information Notice 23-032, requiring Mental Health Plans to create a Provider Directory API comparable with FHIR standards as of July 1, 2023. CCBH submitted a procurement request and was informed that this would need to be added to the Contra Costa Health Plan (CCHP) contract 23-636 for the same product, and CCHP submitted an amendment to do this. The vendor was bought out by other parties twice and changed locations since the initiation of the CCHP contract, and the contract amendment is currently stalled while all parties determine how to process the multiple name changes; therefore no payments can currently be made through the contract.
On October 8, 2025, DHCS notified CCBH that if the Provider Directory API is not up and running by December 6, 2025, they will start implementing financial sanctions.
The vendor is entitled to payment for the reasonable value of its services under the equitable relief theory of quantum meruit. That theory provides that where a vendor has been asked to provide services without a valid contract, and the vendor does so to the benefit of the county, the vendor is entitled to recover the reasonable value of those services. The Department cannot pay the vendor for services rendered without a valid contract. As such, the Department recommends that the Board authorize the Auditor-Controller to issue a one-time payment not to exceed $98,000 payable to mPulse Mobile, Inc.
This payment is needed urgently, since it will take approximately three weeks after mPulse Mobile, Inc. receives the payment for the Provider Directory API to go live.
CONSEQUENCE OF NEGATIVE ACTION:
Failure to approve this action will cause CCBH to be in default of the DHCS deadline for implementing this Provider Directory API and will result in DHCS implementing financial sanctions, which will include the withholding of funds due to CCBH by DHCS and progressing to up to $25,000 per violation for a first violation, $50,000 for a second violation, and $100,000 for each subsequent violation, plus a separate violation for each Medi-Cal member impacted.