State of California Health and Human Services Agency ...€¦ · State of California—Health and...

State of California—Health and Human Services Agency

Department of Health Care Services

JENNIFER KENT EDMUND G. BROWN JR. DIRECTOR GOVERNOR

Managed Care Quality and Monitoring Division 1501 Capitol Avenue, P.O. Box 997413, MS 4400

Sacramento, CA 95899-7413 Phone (916) 449-5000 Fax (916) 449-5005

www.dhcs.ca.gov

November 2, 2016

Matt Levin, Chief Compliance officer & Legal Counsel Alameda Alliance for Health 1240 South Loop Road Alameda, CA 94502

RE: Department of Managed Health Care 1115 Waiver Seniors and Persons with Disabilities Survey

Dear Mr. Levin:

The Department of Managed Health Care conducted an on-site 1115 Waiver Senior and Persons with Disabilities (SPD) Survey of Alameda Alliance for Health, a Managed Care Plan (MCP), from June 8, 2015 through June 12, 2015. The survey covered the period of April 1, 2014 through March 31, 2015.

On November 2, 2016, the MCP provided DHCS with additional information regarding its Corrective Action Plan (CAP) in response to the report originally issued on March 18, 2016.

All items have been reviewed and found to be in compliance. The CAP is hereby closed. The enclosed report will serve as DHCS’ final response to the MCP’s CAP.

Please be advised that in accordance with Health & Safety Code Section 1380(h) and the Public Records Act, the final report will become a public document and will be made available on the DHCS website and to the public upon request.

If you have any questions, feel free to contact me at (916) 552-8946 or Lyubov Poonka at (916) 552-8797.

Sincerely,

Jeanette Fong, Chief Compliance Unit

Enclosures: Attachment A CAP Response Form

cc: Stephanie Issertell, Contract Manager Department of Health Care Services Medi-Cal Managed Care Division P.O. Box 997413, MS 4408 Sacramento, CA 95899-7413

ATTACHMENT A Corrective Action Plan Response Form

Plan Name: Alameda Alliance For Health

Review/Audit Type: SPD Survey Review Period: April 1, 2014 – March 31, 2015

MCPs are required to provide a CAP and respond to all documented deficiencies within 30 calendar days, unless an alternative timeframe is indicated in the letter. MCPs are required to submit the CAP via email in word format which will reduce turnaround time for DHCS to complete its review.

The CAP submission must include a written statement identifying the deficiency and describing the plan of action taken to correct the deficiency, and the operational results of that action. For deficiencies that require long term corrective action or a period of time longer than 30 days to remedy or operationalize, the MCP must demonstrate it has taken remedial action and is making progress toward achieving an acceptable level of compliance. The MCP will be required to include the date when full compliance is expected to be achieved.

DHCS will maintain close communication with the MCP throughout the CAP process and provide technical assistance to ensure the MCP provides sufficient documentation to correct deficiencies. Depending on the volume and complexity of deficiencies identified, DHCS may require the MCP to provide weekly updates, as applicable.

CORRECTIVE ACTION PLAN FORMAT

Deficiency Number and Finding

Action Taken Implementation Documentation

Completion/ Expected

Completion Date

DHCS Comments

Utilization Management 1. The Plan does not

consistently make

decisions in a timely

manner, based on

medical necessity

determinations, to

approve, modify, or

AAH updated its UM Policy of

Authorization Process to include

the correct timeframe

requirements. Implemented daily

aging monitoring reports that are

reviewed by the UM supervisor to

monitor staff’s open authorization

1.A- MED-UM-

0001 UM Auth

Process Policy

10_22_15

1.B- UM

Authorization Daily

4/21/2016 04/21/16 – MCP submitted:

- “UM Authorization Process

Policy” (10/22/15). This updated

policy includes a table with the

correct authorization processing

timeframes that complies with

- 2 -




Completion Date

DHCS Comments

deny requests by

providers.

cases and ensure they are

processed timely. UM daily audits

are conducted by the UM

supervisor to ensure authorizations

are processed within appropriate

timeframes and that appropriate

notices with required elements are

sent timely. Internal audits are

conducted by AAH’s Compliance

department to monitor compliance

of medical authorization

turnaround timeframes.

Audit Sample

Report

1.C- UM

Authorization Daily

Aging Sample report

1.D- Compliance

Monthly UM TAT

Monitoring Report

Oct 2015

1.E- Compliance

Monthly UM Auth

Audit Reports

1.F- AAH Board

Meeting UM

Internal Audit

Results 10_9_15

1.G- AAH Board

Meeting UM

Internal Audit

Results 3_11_16

compliance and statutory

requirements (p.6)

- “UM Authorization Daily

Aging Report” sample report

which provides a snap shot of

unprocessed authorizations using

the TrueCare tool.

- “UM Authorization Daily Audit

Report” sample that tracks all PA

timeliness milestones (e.g.,

receipt date, processing date,

extension date, notification dates,

etc.).

- “Compliance Monthly UM

TAT Monitoring Report” (Oct

2015) as evidence that the MCP

tracks PA TATs on a monthly

basis. The percentage of

compliance has improved.

- “Compliance Monthly UM

Auth Audit Reports” as evidence

that the MCP conducts an

internal audit on a monthly basis.

It shows an increase in

compliance rate for PA TATs

- 3 -




Completion Date

DHCS Comments

from October 2014 through

August 2015.

- A Compliance Report (March

11, 2016) that was presented to

the Governing Board. The report

provides an update on the DHCS

CAP status on improving UM

TATs, including the results of the

MCP’s internal audit (page 3).

This deficiency is closed.

2. For decisions to

deny, delay, or

modify health care

service requests by

providers based in

whole or in part on

medical necessity, the

Plan does not

consistently include in

its written response:

A clear and concise

explanation of the

reasons for the

decision;

AAH’s UM department

implemented daily quality audit

review for monitoring staff prior

authorization cases for complete

and sufficient medical review.

2.A- UM

Authorization Daily

Audit Sample

Report

10/18/16

UM Audit Results

April 2016

UM Audit Results

May 2016

UM Audit Results

June 2016

4/21/2016 10/18/16 – MCP submitted:

-Three audit samples, “UM

Authorization Internal Audit”

(April, May, June, 2016) that

show review of PAs for 3

required components (clear &

concise, criteria/guideline,

clinical reason). The template

requires the reviewed to input all

three requirements. Audits are

conducted monthly.

This finding is closed.

- 4 -




Completion Date

DHCS Comments

A description of the

criteria or guidelines

used; and

The clinical reasons

for the decision.

3. The Plan does not

consistently make

decisions in a timely

manner, based on

medical necessity

determinations, to

approve, modify or deny

requests by providers for

pharmaceutical

treatments.

Starting 1/1/2015, a 24 hours’

turnaround time (TAT) has been

implemented for all pharmacy

authorizations. TAT compliance

is measured and monitored every

month. In 2015, the overall 24

hours TAT compliance rate was

99%.

3.A- 2015 Pharmacy

Prior Authorization

Summary MCAL

3.B- 2015 Pharmacy

Prior Authorization

Summary IHSS

4/21/2016 4/21/16 –The MCP submitted

“PerformRx Prior Authorization

Summary - 2015” as evidence

that the MCP monitors pharmacy

TAT on a monthly basis. This

summary report (January 2015

through December 2015) yielded

a 100% compliance rate average.



have adequate

mechanisms to detect

for under- and over-

utilization of out-of-

network specialty

referrals and behavioral

health services.

AAH regularly monitors requests

for out-of-network (OON)

specialty referrals using the OON

specialty referrals report. The

monitoring occurs at least

quarterly. AAH will be reporting

under-over utilization data at the

internal UM Subcommittee.

MCP’s Response 10/17/16: Our

internal UM sub-committee meets

to discuss various internal and

delegation reporting. Attached are

4A- Alliance OON

Specialist Referrals

4B- Behavioral

Health OON Report

09-14-16

8/31/2016

9/14/2016

4/21/16 – MCP submitted

“Alliance OON Specialist

Referrals” report which tracks the

number of OON requests and

approvals for the MCP and its

provider groups (Q3 2015).

9/14/16 – MCP’s written

response indicated that the OON

specialty referrals are discussed

quarterly and will be discussed at

the UM Sub-committee in

October 2016 and March 2017.

- 5 -




Completion Date

DHCS Comments

the minutes and reports discussed

which includes Beacon’s data with

behavioral health utilization.

10/14/16 – MCP submitted

“Behavioral Health OON Report”

(09-14-16) as evidence of

monitoring of OON referrals for

Behavioral Health.

- “Monthly Utilization

Management Sub-Committee”

minutes and corresponding

attachments including several

Beacon utilization reports (01-27-

16). The minutes document

review, discussion, and follow up

of behavioral health utilization.

(Item V)


Continuity of Care 5. The Plan does not

monitor or ensure the

timely provision of an

Initial Health

Assessment for each

new member.

AAH revised its IHA policy to

include a procedure for monitoring

the completion of all new member

IHAs within the required

timeframe. AAH’s IHA

workgroup meets quarterly to

review IHA completion reports,

discuss improvements,

interventions, and activities.

Targeted interventions

implemented in the past 6 months

5.A- MED-QM-

0041 Initial Health

Assessment

12_17_15

5.B- AAH IHA

Work Flow 9_24_15

5.C- IHA Work

Group Minutes

7_7_14

4/21/2016 4/21/16 –MCP submitted:

- “MED-QM-0041 Initial Health

Assessment” policy and

procedure (revised 12/17/15) that

demonstrates alignment with the

contractual requirements

regarding timely completion of

IHAs (p.1).

- 6 -




Completion Date

DHCS Comments

include:

Included an IHA

requirement in P4P for

direct-contract providers;

Added IHA education in

provider orientation

packets for Q1 2016; and

Added new member flag in

provider portal. Providers

can download list of new

members in Excel format

from AAH’s portal.

AAH will be conducting quarterly

outreach to providers in the lowest

quartile beginning in Q4 2016.

5.D- IHA Work

Group Minutes

8_14_15

5.E- IHA Work

Group Minutes

10_28_15

5.F- IHA Work

Group Minutes

2_10_16

5.G- New Members

IHA Report July

2015

5.H- New Members

IHA Report Oct

2015

5.I- New Members

IHA Report Feb

2016

5.J- Kaiser IHA

Report 2015

5.K- AAH P4P

Program

5.L- P4P Program

Guide Presentation

5.M- AAH Member

ID Card IHA

Reminder

This P&P also addresses IHA

monitoring. The MCP indicates

that Current Procedural

Terminology (CPT) codes that

represent IHA completion will be

queried to retrieve and track IHA

completion (p.2).

- “New Members IHA Report”

(Oct 2015 & Feb 2016) as

evidence that the MCP is

monitoring IHA completion

based on CPT codes.

- “IHA Work Group Minutes”

for 7/7/14, 8/14/15, 10/28/15,

2/10/16 committee meetings

document review of the above

mentioning reports, discussion,

and follow-up.

- “IHA For Medi-Cal New

Members” provider education

material that reiterates the

requirement and directs PCPs to

the Plan’s web-site for available

resources. These resources

include:

- 7 -




Completion Date

DHCS Comments

5.N- Medi-Cal EOC

Health Exam New

Members

5.O- Provider IHA

Education

5.P- MCAL Member

Welcome Letter

SHA forms, SHA provider

training power point presentation,

Attestation form and handouts

that are available for use when

providing counseling and

guidance on topics covered by

the SHA.

- “AAH Pay For Performance

(P4P)” spreadsheet that shows

the MCP’s point base incentive

system for different measures,

one of which is IHA.

- “Program Guide – MY 2015 &

2016. Pay for Performance

Program – Directly Contracted

PCPs” which educates providers

on the point based incentive

system.

- “Welcome to AAH” welcome

letter that encourages the new

member to schedule a well exam.

- “AAH Member ID Card IHA

Reminder” – a sample of ID Card

mailed to the member which

includes another IHA reminder.

- 8 -




Completion Date

DHCS Comments



consistently ensure the

provision of complex

case management

services.

AAH expanded its criteria of

members who qualify for

Complex Case Management. AAH

is currently in the process of hiring

additional Nurse Case Managers

to build the program and increase

the number of members receiving

Complex Case Management

services.

6.A- AAH 2015

Case Management

Program Description

6.B- 2015 Complex

Case Management

Program Evaluation

6.C- AAH Complex

Case Management

Criteria

6.D- AAH Case

Management

Referral Form

6.E- AAH Case

Management

Website

12/31/2016 04/21/16

MCP submitted the following

supporting documents:

- “Comprehensive Case

Management Program

Description” (2015) which

describes the MCP’s Complex

Case Management Program

including criteria for

identification (pages 16-17).

- “Complex Case Management

Measures of Effectiveness

Report” (2015) which evaluates

the effectiveness of the MCP’s

CCM program.

- “Alliance Complex Case

Management Criteria” which

specifies criteria for CCM

eligibility.

-Screenshot of the MCP’s “Case

and Disease Management

Program” webpage which

- 9 -




Completion Date

DHCS Comments

provides providers with

accessibility to referral forms.

08/23/16

MCP provided two case

examples that demonstrated care

plans which address all of the

members' needs identified in the

assessment (“Referral for

Complex Case Management”

p.3,5-14). age 3).


Availability & Accessibility 7. The Plan does not

implement prompt

investigation and

corrective action when

compliance monitoring

discloses that the Plan’s

provider network is not

sufficient to ensure

timely access to

appointments.

AAH revised its Timely Access

policies. AAH’s Access

Subcommittee monitors providers’

compliance with timely access

standards on a quarterly basis

through various monitoring

reports such as out-of-network

authorizations, grievances and

appeals related to access, provider

capacity levels, geographic access

reports, and annual appointment

access & availability provider

survey results. The Access

Subcommittee reports all

monitoring activities to the Health

7.A- AAH-CMP-

0024 Monitoring of

Access &

Availability

Standards

7.B- MED-DEL-

0025 Appointment

Access &

Availability

7.C- MED-DEL-

0024 Access to

Behavioral Health

Services

7.D- AAH-CMP-

0028 Access &

4/21/2016 4/21/16 –MCP submitted:

-Minutes from two Access

Committee meetings (9-17-15 &

11-19-15) showing that timely

access and monitoring reports are

being reviewed.

- The Plan submitted examples

of three corrective action plans

(AHS Timely Access CAP 8-21-

15, Beacon Timely Access CAP

2-18-15 & CHCN Timely Access

CAP 4-16-15) issued to delegates

that were out of compliance with

- 10 -




Completion Date

DHCS Comments

Care Quality Committee (HCQC).

AAH issued three Access

Corrective Action Plans (CAPs) in

2015.

Availability

Committee Policy

7.E- MED-QM-

0023 Provider

Access and

Availability Survey

7.F- 2015 ICE

DMHC

Appointment

Availability Survey

Tool

7.G- AAH Access

Committee Minutes

9_17_15

7.H- AAH Access

Committee Minutes

11_19_15

7.I- AHS Timely

Access CAP

8_21_15

7.J- Beacon Timely

Access CAP

2_18_15

7.K- CHCN Timely

Access CAP

4_16_15

7.L- HCQC Minutes

11_23_15

timely access standards. The

CAPs were discussed in the

Access Committee meetings.


- 11 -




Completion Date

DHCS Comments

7.M- HCQC Packet

12_17_15


ensure that during

normal business hours,

the waiting time for a

member to speak by

telephone with a Plan

customer service

representative does not

exceed ten minutes.

AAH revised its policy for Quality

Monitoring Member/Plan

Interactions. Monthly Member

Services Performance Dashboards

are reported to Senior Leadership

and the Governing Board.

Member Services staff routinely

monitors call performance

measures and call center

timeliness. Since November 2015,

90% or more of AAH’s member

services calls are answered within

30 seconds.

8.A- MEM GEN

003 Quality Monitor

Member Plan

Interaction Dec

2015

8.B- AAH Member

Services Staff

Performance

Evaluation Tool

8.C- AAH Board

Report Call

Statistics 1_22_16

8.D- AAH Board

Report Call

Statistics 4_8_16

8.E- Member

Services

Performance

Dashboard 2015

4/21/2016 4/21/16 –MCP submitted:

- P&P MEM GEN 003: “Quality

Monitoring of Member/Plan

Interactions and Electronic

Communications” (revised

12/2015) which establishes the

MCP’s standard of answering

80% of calls within 30 secs with

an abandonment rate less than or

equal to 5%.

- “Member Services Dashboard”

(2015) as evidence that the MCP

is monitoring call center activity

(e.g., incoming calls,

abandonment rate, calls answered

in 30 secs). The results show an

improved rate of compliance

from January to December 2015.

- “Board of Governors Report”

(1-22-16 and 4-8-16) as evidence

that call center data including

abandonment rates and calls

answered in 30 seconds is

- 12 -




Completion Date

DHCS Comments

reported to the Board of

Governors.


Members’ Rights

9. The Plan’s grievance

system does not

consistently ensure that

all expressions of

dissatisfaction are

captured as grievances

and that a written record

is made for each

grievance received.

AAH has revised its Exempt

Grievance policy. Staff trainings

were conducted on the exempt

grievance process and

documentation standards.

9.A- MEM-GEN-

0024 Exempt

Grievances Policy

9.B- Member

Services Exempt

Grievances Report

9.C- Member

Services

Documentation

Training 3_31_16

9.D- Member

Services Training

4_13_16

9.E- Member

Services Exempt

Grievance Training

4_20_16

4/21/2016 4/21/16 –MCP submitted:

- “MEM-GEN-0024 Exempt

Grievances” (revised 04-13-15)

policy that demonstrates

alignment with the requirements

of Section 1368(a)(4)(B) and

Rule 1300.68(d)(8) regarding

process of receiving, identifying,

documenting and monitoring of

exempt grievances.

- “Member Services Dashboard

2015

Informal Complaint Reasons for

Member Services” as evidence

that the MCP is tracking and

trending exempt grievances.

- Evidence of the staff trainings

conducted on documenting calls.

“Elements of Good

documentation” (A tip sheet for

documenting Member Service

delivery).

- 13 -




Completion Date

DHCS Comments

- “MSD Bi-Monthly

Meeting/Training” (04/13/16 and

04/20/16) agenda/minutes and

attendees sign in sheet. “Informal

Complaints

MSR Documentation Guidelines”

are included as part of the

training materials (04/13/16,

pages 5-7) and gives instruction

on how to utilize Health Suite to

properly enter Informal

Complaints. Informal complaints

(exempt), formal grievance and

appeals, timely filing, definitions,

and documentation standards are

discussed.


10. The Plan’s grievance

system does not

consistently ensure

adequate consideration

of exempt grievances

and rectification when

appropriate.

AAH has revised its Exempt

Grievance Policy. Staff trainings

were conducted on the exempt

grievance process and

documentation standards.

9.A- MEM-GEN-

0024 Exempt

Grievances Policy

9.B- Member

Services Exempt

Grievances Report

9.C- 9.C- Member

Services

Documentation

Training 3_31_16

4/21/2016 10/14/16 – MCP submitted:

MCP’s response (10/14/16)

indicating that they have had staff

trainings focusing on exempt

grievances and how to adequately

resolve the complaint.

- “Member Services Department

Stand-Up/Training Meetings”

sign-in sheets (September 8-9,

- 14 -




Completion Date

DHCS Comments

9.D- Member

Services Training

4_13_16

9.E- Member

Services Exempt

Grievance Training

4_20_16

2016) and Power Point training

as evidence that member services

representatives were trained on

how to fully resolve exempt

grievances.

- “Agent Scored Evaluation”

three samples of call evaluation

form results as evidence that the

member services representative is

evaluated on how well he/she

solved the problem.



consistently ensure that

Limited English

Proficient members

receive coordinated

interpreter services at

the time of scheduled

appointments.

AAH distributed “Point to Your

Language" signage and contact

information for AAH interpreter

services to all providers in Q3

2015 and Q4 2015 provider office

visits. Grievances and any issues

related to interpreter services are

reported to the Language

Assistance Subcommittee.

11.A- MED-CL-

0003 Language

Assistance Services

11.B- MED-CL-

0010-Cultural and

Linguistic Services

Program Staff

Training

11.C- Point to Your

Language Signage

11.D- Interpreter

Services Quick

Guide

11.E- Language

Assistance

4/21/2016 4/21/16 –MCP submitted:

-Policy & Procedure “MED-CL-

0010, Cultural and Linguistic

Services Program: Staff

Training” (02/13/15) indicates

that the Plan ensures that all staff,

providers and subcontractors are

compliant with the Cultural and

Linguistic Services Program

through cultural competency

training that is provided on an

annual basis.

Additionally, Bilingual staff that

is hired receives bilingual

- 15 -




Completion Date

DHCS Comments

Committee Minutes

10_21_15

11.F- Language

Assistance

Committee Minutes

1_20_16

proficiency assessments upon

becoming employed with the

Plan. (p.1)

- “Point to Your Language We

Will Get You an Interpreter”

signage that informs the

beneficiaries of the availability of

free language assistance services,

as well as in the EOC, welcome

packet and member newsletters.

(MED-CL-0010 p.3)

- “Alameda Alliance for Health

Interpreter Services Quick

Reference Guide” informs

providers of the availability of

free language assistance services

for members as well as the new

provider orientation, provider

bulletins, through their contract

and in the provider manual.

(MED-CL-0010 p.3)

- “Quarterly Language Assistance

Program Sub-Committee October

21, 2015” The minutes indicate

that the common theme in the G

& A trending report and Member

- 16 -




Completion Date

DHCS Comments

Services informal complaints was

interpreter no shows and

members not being informed.

All complaints, informal and

formal should be reported to IEC

and follow-up documented.

Grievance data re: C & L is now

communicated to appropriate

departments and documented.

(p.2)

- “Language Assistance Services

Sub-Committee January 20,

2016” sub-committee minutes

show evidence that issues such as

language capacity of providers,

consideration of a change in

interpretation vendors, tracking

of threshold languages were

discussed. Minutes document that

a report documenting

unfulfilled/cancelled interpreter

requests (Oct-Dec 2015) was

reviewed and no significant

trends were noted.


Quality Management

- 17 -




Completion Date

DHCS Comments


conduct adequate review

of potential quality

issues to ensure that all

problems are being

identified and that

grievances related to

medical quality issues

are consistently referred

to the Plan’s medical

director.

Policies & Procedures, the Work

Plan and the Potential Quality

Issues (PQI) Tracking System

were revised:

To require Medical

Director review of all

PQIs, both administrative

& quality related; and

To create an interrater

reliability process.

A Monthly Monitoring Report was

created for the Quality

Management Subcommittee and

HCQC.

12.A- MED-QM-

0002 Potential

Quality Issues (PQI)

12.B- PQI

Workflow

12.C- 2016 PQI

Master Log

Redacted

12.D- PQI Report to

Committee

8/31/2016 8/31/16 –MCP submitted:

-Revised policy and procedure

“MED-QM-0002, Potential

Quality Issues (PQI)” (4/13/15)

requires Medical Director to

review all PQI cases, both

administrative and clinical. (§10

(3))

- “PQI Referral log 2016 De-

identified” as evidence that the

MCP is required to capture a

number of elements, including

the date of MD review. The new

process was developed and

initiated Spring 2016 and

approved/finalized by QI

Committee (HCQC) in June

2016. All new PQI cases now

have MD review prior to closing

the case.

- “PQI Report to Quality

Management Committee” as

evidence that the MCP has

implemented its process for

providing updates to the QIC. All

PQI case statuses, required

CAPs, and inter-rater reliability

- 18 -




Completion Date

DHCS Comments

reviews are captured in this

monthly report.



have effective oversight

procedures in place to

ensure that providers are

continuously fulfilling

all delegated

responsibilities.

AAH revised its delegation

oversight policies. AAH’s

Compliance Department

conducted all annual delegation

audits for 2015. Delegation

reporting is monitored routinely

and CAPs were issued in response

to reporting of non-compliance.

Delegation oversight activities and

CAPs are reported quarterly to the

Compliance Committee.

13.A- CMP-0042

Delegation

Oversight Policy

13.B- MED-QM-

0040 Delegation of

Quality

Management

13.C- AAH

Delegation Grid_

June 2015

13.D- 2015

Delegation Audit

Schedule 10_1_15

13.E- Compliance

Committee Minutes

8_4_15

13.F- Compliance

Committee Minutes

11_24_15

13.G- Compliance

Committee Agenda

3_22_16

13.H- Beacon Audit

Report

4/21/2016 4/21/16 –MCP submitted:

- “CMP-0042 Delegation

Oversight” policy, which

commits MCP to pre-delegation

review, annual delegation review,

delegation oversight meetings

and contractual and regulatory

reporting. (p.2)

- “MED-QM-0040 Delegation of

Quality Management”

(rev.12/17/15) policy and

procedure requires audits of each

delegate prior to contracting to

evaluate the delegate capacity

meets DHCS requirements. (§

A.) The MCP performs annual

delegation oversight audit to

verify compliance. If needed

MCP will issue a CAP. (§ D.)

- “Compliance Committee

Meeting Minutes” (06/03/15 &

11/24/15) shows review and

discussion of delegation activities

- 19 -




Completion Date

DHCS Comments

13.I- CFMG Audit

Report

13.J- CHCN Audit

Report

13.K- CHME Audit

Report

13.L- EviCore Audit

Report

13.M- Kaiser Audit

Report

13.N- March Vision

Audit Report

13.O- PerformRx

PBM Audit Report

13.P- LPCH Audit

Report

13.Q- UCSF Audit

Report

13.R- AAH

Delegation CAP

Report 11_24_15

13.S- AAH Board

Compliance Report

1_22_16

13.T- AAH Board

Compliance Report

2_12_16

(e.g., audit schedule, audits,

CAPs, etc.) (agenda item # 5)

- MCP submitted 10 delegated

entity reports and subsequent

Corrective Action Plans as

evidence of ongoing monitoring.

- “Board of Governors Regular

Meeting” (01/22/16 & 02/12/16)

memo as evidence that the

Compliance Department provides

updates on delegated audits and

issued CAPs to the Board.


- 20 -




Completion Date

DHCS Comments


maintain a system of

accountability for its

Quality Improvement

System by ensuring that

reports to the governing

body are sufficiently

detailed to identify

significant or chronic

quality of care issues.

Components of the Quality

Improvement System were

discussed during December 2015

and January 2016 Board of

Governor’s meeting.

14.A- AAH Board

Meeting Minutes

12_11_15

14.B- AAH Board

Meeting Minutes

1_22_16

4/21/2016 10/28/16 – MCP submitted:

- “BOG Regular Meeting”

packet (06/10/16; 07/08/16;

09/09/16; 10/14/16) which

includes evidence of the Board

receives and reviews monitoring

reports including the “Medical

Services Report.”

-Evidence of review and approval

of the QI program, work plan,

and evaluation in the 07/08/16

Board meeting packet (page 65).

11/02/16 – MCP submitted:

-An e-mail indicating, “We are

planning to include the HCQC

minutes in the Board packets for

reporting activities, findings, and

recommendations. The HCQC

minutes will be in the Board

packets beginning January 2017.”


Submitted by: Matt Levin, Esq. Date: 4/21/2016 Title: Chief Compliance Officer/General Counsel

Scott Coffin, CEO Matt Levin, Chief Compliance Officer/General Counsel

State of California Health and Human Services Agency ...€¦ · State of California—Health and...

Documents

Transcript of State of California Health and Human Services Agency ...€¦ · State of California—Health and...