To: Joint Conference Committee (JCC) Members
From: Irene Lo, MD FACS; Chief Executive Officer (Interim)
Date: October 3, 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
• Compliance Department
CCHP has recently taken steps to strengthen leadership within our Compliance Department. Recognizing the need for additional support and direction, we engaged Sunny Cooper in August 2025 as an external consultant to serve as Interim Senior Director of Compliance. This proactive measure provides stability, consistent leadership, and positions the department for long-term success.
Sunny brings extensive experience in the California Medi-Cal managed care environment and is playing a critical role in establishing structure, providing guidance, and driving momentum as we continue to strengthen our compliance program, meet regulatory requirements, and prepare for upcoming program expansions.
• Provider Relations, Credentialing, and Contracting Department
In August 2025, CCHP welcomed Nancy McAdoo as our new Director of Provider Relations, Credentialing, and Contracting. This leadership role is central to strengthening provider partnerships, streamlining network development, and advancing provider satisfaction.
Nancy brings a wealth of Managed Medi-Cal experience and a fresh perspective to our team. She will play a pivotal role in optimizing contracting strategies and deepening provider engagement as we prepare for the launch of our D-SNP and future growth.
• Quality and Health Equity Department
To further strengthen our work in Quality and Health Equity, we have transitioned the Quality and Health Equity Department from Business Operations to Clinical Operations. This move fosters closer alignment with clinical leadership and ensures that the principles of quality and equity are fully integrated across all areas of Clinical Operations.
Dual-Special Needs Plan (D-SNP) Recruitment
In August 2025, CCHP received approval to add several much-needed positions in preparation for the launch of the D-SNP. These roles are essential to strengthening our operational capacity-enabling us to meet regulatory requirements, deliver robust care coordination, and respond more effectively to the needs of our members and providers. Recruitment is now underway, and we look forward to welcoming new colleagues who will help us continue building a strong foundation for CCHP’s future growth.
Dual-Special Needs Plan (D-SNP) Recruitment
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. We also conveyed that interim consultants are currently providing regulatory oversight and continuity in impacted departments while permanent hires are being pursued.
DMHC has indicated they plan to meet with us again before the end of the year to assess progress and ensure that permanent leaders have been placed into these roles. CCHP remains committed to maintaining strong communication with our regulators and to providing timely updates as recruitment advances and positions are filled.
2. Regulatory Update
Purpose: To promote transparency and accountability regarding organizational leadership and staffing developments.
CCHP continues to prioritize regulatory readiness through structured engagement with oversight agencies and internal corrective actions. Key updates are outlined below:
DHCS 2024 Medical Audit - Corrective Action Plan (CAP)
Contra Costa Health Plan (CCHP) continues to advance its response to the findings from the 2024 DHCS Medical Audit. CCHP submitted its initial Corrective Action Plan (CAP) on March 28, 2025, followed by supplemental submissions in May, July, and August that included updated policies, internal audit results, training documentation, and revised workflows.
On August 19, 2025, DHCS provided its most recent feedback. While DHCS indicated that the majority of corrective plans had been accepted and significant progress had been made, DHCS identified a couple of remaining open items - primarily related to audit follow-ups and evidence of sustained improvements.
The Plan remains on track for CAP closure and continues to prioritize long-term sustainability of corrective actions through leadership oversight and internal monitoring.
We will continue to keep the JCC informed of our progress and share any additional feedback from DHCS in future updates.
DHCS 2025 Medical Audit
Contra Costa Health Plan recently completed its 2025 Department of Health Care Services (DHCS) Medical Audit, which was conducted in person from August 18-28, 2025. The audit reviewed CCHP’s compliance and performance for the period of August 1, 2024, through July 31, 2025.
CCHP welcomed seven auditors from DHCS, who conducted a comprehensive review across all six audit categories:
• Utilization Management
• Case Management and Coordination of Care
• Access and Availability
• Member’s Rights
• Quality Improvement
• Administrative and Organizational Capacity
In preparation, CCHP engaged in extensive readiness activities, including mock audits and focused work sessions. As a result, staff were well prepared, professional, and confident in presenting information and participating in audit interviews.
During the closing session of the onsite audit, DHCS shared some initial concerns. A formal exit conference with DHCS, where findings will be officially presented, is tentatively scheduled to take place in early Spring 2025. The CCHP team has already identified areas for improvement based on the audit and is actively implementing process enhancements to address them.
We will provide the JCC with DHCS’s findings once they are formally released and continue to keep the committee informed as the process moves forward.
DHCS 2023 Behavioral Health and Transportation Focused Audit - Corrective Action Plan (CAP)
DHCS confirmed satisfactory closure of all Transportation related findings and several Behavioral Health Focused Audit findings. Responses to the remaining Behavioral Health audit findings have been submitted to DHCS. We are currently awaiting formal response and further instruction from DHCS.
DMHC Audits
The DMHC Financial Audit will be taking place in April 2026, starting 4/6/2025. Pursuant to Section 1382 of the California Health and Safety Code, the DMHC Division of Financial Oversight is responsible for conducting routine financial examinations of each health plan and issuing a public report at minimum of once every five years. The purpose of the financial examinations is to evaluate and report on regulatory compliance with the Knox Keene Act. Each financial examination discusses plan performance in the areas of health plan fiscal and administrative functions. Topics include claims, provider dispute resolutions, financial accounts review, and statutory compliance.
The DMHC Follow Up Medical Survey will also take place in April 2026, starting 4/26/2025. California law requires the DMHC to conduct a routine medical survey of each licensed full service and specialty health plan at least once every three years. When the survey is complete, the DMHC issues a Final Report that is publicly available. The DMHC may perform a Follow-Up Survey within 18 months of the Final Report for any uncorrected deficiencies. The medical survey is a comprehensive evaluation of the plan's compliance with the law in the following health plan program areas:
• Quality assurance
• Grievance and appeals
• Access and availability
• Utilization management
• Overall plan performance in meeting enrollee’s health care needs
DMHC Audits
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.
• 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 and Medi-Cal Dual Special Needs Plan (D-SNP) on January 1, 2026. This launch represents a major organizational milestone and a critical opportunity to better serve dual-eligible individuals-those who qualify for both Medicare and Medi-Cal-through a more coordinated and person-centered care model.
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.
On 9/19/2025, the Centers for Medicare and Medicaid Services (CMS) informed CCHP that they had reviewed and approved all 2026 contracting documents and post-application requirements for our D-SNP Contract (Contract ID H5119).
• Operational Readiness
o Finalizing contracts with vendors supporting key D-SNP functions
o Advancing provider contracting to meet CMS and DHCS network adequacy requirements
o Internal workgroups refining workflows and configuring systems to support implementation
o Education and outreach initiatives underway, including staff training and provider engagement
o Recruitment in progress for critical D-SNP positions to ensure implementation and sustainability
• Regulatory Readiness and Oversight
o Finalizing policies and procedures that align with Medicare Advantage and Medi-Cal integration standards
o Building a comprehensive Medicare Compliance Program to ensure sustained compliance with CMS and DHCS expectations
o Establishing oversight infrastructure to support long-term success as a Medicare plan sponsor
• Regulatory Readiness and Oversight
o Coordinating closely with Contra Costa Health, particularly Contra Costa Regional Medical Center and Health Centers, to ensure systemwide alignment
o Engaging the Safety Net Council, which includes the majority of external Federally Qualified Health Centers (FQHCs) as well as other key external providers across the county, to prepare the broader provider community for integrated care
Strategic Importance
The D-SNP launch is not only a compliance milestone but also a strategic cornerstone for CCHP’s future direction:
• Creating a Scalable Model: Building an integrated care framework adaptable for future products and lines of business.
• Leadership in California’s Medi-Cal Transformation: Positioning CCHP as a leader in CalAIM by demonstrating how local health plans can deliver integrated care to vulnerable populations.
• Quality and Equity Infrastructure: Leveraging D-SNP investments to advance continuous improvement in quality, equity, and member experience.
Risk Management & Challenges
CCHP is proactively identifying and mitigating key risks to ensure a successful launch:
• Workforce Readiness: Recruitment for Medicare-specific expertise is ongoing. Mitigation includes phased onboarding, training, and cross-training to ensure depth of knowledge.
• Regulatory Oversight: CMS and DHCS impose rigorous requirements. Mitigation includes early deliverable submission, mock audits, and strong compliance monitoring.
• Network Adequacy: Building and maintaining a robust network of hospitals, specialists, behavioral health, and primary care providers remains a challenge. Mitigation includes targeted contracting outreach and close coordination with CCRMC/HC and external providers.
• Member Experience: Ensuring clear, culturally and linguistically appropriate communication during the Annual Enrollment Period is critical. Mitigation includes member materials review, staff training, and expanded call center support.
• Operational Complexity: Integrating Medicare and Medi-Cal workflows requires new systems and oversight. Mitigation includes structured testing, vendor performance monitoring, and internal readiness drills.
Next Quarter Priorities
CCHP’s near-term implementation priorities include:
• Finalizing provider and vendor contracts
• Submitting required deliverables to CMS, DHCS, and DMHC
• Continuing recruitment for approved D-SNP staffing roles
• Expanding internal staff education and training
• Ongoing operational readiness testing
• Continuing communications and education for network providers
• Preparing for Annual Enrollment Period (October - December 2025)
Next Steps & 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. Commercial Plan Update
Purpose: To ensure effective oversight and promote transparency for CCHP’s Commercial Line of Business.
CCHP continues to work closely with Segal and Contra Costa County on the 2026 Commercial Plan.
• On 8/20/2025, CCHP was informed that Contra Costa County had accepted our renewal, subject to Board Approval
• Benefit summaries and Summaries of Benefits and Coverage (SBCs) were also sent to Segal/Contra Costa County in August 2025 for review
• CCHP sent Explanations of Coverage (EOCs) to Segal/Contra Costa County in late September 2025 for review
On 8/29/2025, 2026 CCHP Health Plan Premium Renewal Letters, with rate information, were sent to all relevant organizations:
• In-Home Support Services
• VistAbility (Contra Costa ARC)
• Superior Court of California, County of Contra Costa
Additional updates will be provided to the Joint Conference Committee as implementation progresses.