Report 2018-603 Recommendation 4 Responses

Report 2018-603: Department of Health Care Services: It Paid Billions in Questionable Medi-Cal Premiums and Claims Because It Failed to Follow Up on Eligibility Discrepancies (Release Date: October 2018)

Recommendation #4 To: Health Care Services, Department of

To prevent future erroneous payments, Health Care Services should establish procedures by December 31, 2018, that define when it will use its authority as defined in state law to sanction unresponsive counties that do not remedy known discrepancies.

No change from the response originally provided to CSA on 07/01/2024:

The California Advancing and Innovating Medi-Cal Proposal, released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities, which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. DHCS resumed county oversight activities on June 1, 2024, when the Continuous Coverage Unwinding Period ended. Due to the sensitivity of the policy, DHCS will include stakeholders and business partners in the policy development process to ensure transparency and clarity. The process will take several months to complete. Therefore, the anticipated completion date has been adjusted to December 31, 2024.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until December 2024.


The California Advancing and Innovating Medi-Cal Proposal, released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities, which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. DHCS will resume county oversight activities on June 1, 2024, when the Continuous Coverage Unwinding Period ends. Due to the sensitivity of this policy, DHCS will include its stakeholders and business partners in the policy development process to ensure transparency and clarity. This process will take several months to complete. Therefore, the anticipated completion date has been adjusted to December 31, 2024.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until December 2024.


No change from the previous update: The California Advancing and Innovating Medi-Cal Proposal, released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities, which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. DHCS will resume county oversight activities on June 1, 2024, when the Continuous Coverage Unwinding Period ends.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, implementation of this recommendation is pending.


The California Advancing and Innovating Medi-Cal Proposal (CalAIM), released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities, which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. DHCS will resume county oversight activities on June 1, 2024, when the Continuous Coverage Unwinding Period ends.

California State Auditor's Assessment of Status: Pending

DHCS does not expect to fully implement this recommendation until June 2024.


The revised California Advancing and Innovating Medi-Cal Proposal (CalAIM), released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities, which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3, referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

the CalAIM Proposal

Otherwise, no changes from the 48 Month update submitted to CSA on August 4, 2022.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until March 2024.


The estimated implementation date was extended by four months to 3/1/2024, due to an extension of the PHE for COVID-19. No changes from 45-Month Program Update.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not implement this recommendation until March 2024.


The Estimated Implementation Date was extended by four months due to an extension of the PHE for COVID-19. Otherwise, no change from previous response:

The revised "California Advancing and Innovating Medi-Cal Proposal" released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3 referencing DHCS' response to the COVID-19 pandemic, and on pages 102-14 in the attachment below:

"California Advancing and Innovating Medi-Cal Proposal" (Attachment 9): https://www.dhcs.ca.gov/provgovpart/Documents/CalAIM-Proposal-Updated-1-8-21.pdf.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until November 2023.


DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the public health emergency with no modifications to the original plan. Response is unchanged from 39-Month Update: The revised "California Advancing and Innovating Medi-Cal Proposal" released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3 referencing DHCS' response to the COVID-19 pandemic, and on pages 102-14 in the attachment below:

"California Advancing and Innovating Medi-Cal Proposal" (Attachment 9): https://www.dhcs.ca.gov/provgovpart/Documents/CalAIM-Proposal-Updated-1-8-21.pdf

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until July 2023.


Response is unchanged from the 36-Month update: The revised California Advancing and Innovating Medi-Cal Proposal released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3 referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until June 2022.


Response is unchanged from 33-Month Update. The revised California Advancing and Innovating Medi-Cal Proposal released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3 referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, it will not fully implement this recommendation until June 2022.


The revised California Advancing and Innovating Medi-Cal Proposal released by DHCS on January 8, 2021, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities, which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3 referencing DHCS' response to the COVID-19 pandemic, and see Rec 4 - CalAIM Proposal - January 2021 (Attachment 3).

California State Auditor's Assessment of Status: Pending

Per the department's response, it will not fully implement this recommendation until June 2022.


Response is unchanged from 27-Month Update. The California Advancing and Innovating Medi-Cal Proposal released by DHCS on October 29, 2019, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to Recommendation 3 referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

- California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending

Per the department's response, it will not fully implement this recommendation until June 2022.


Response is unchanged. The California Advancing and Innovating Medi-Cal Proposal released by DHCS on October 29, 2019, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 pandemic, efforts are now suspended. Please refer to the response to recommendation three referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

- California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending

Per the department's response, it will not fully implement this recommendation until June 2022.


Response is unchanged. The California Advancing and Innovating Medi-Cal Proposal released by DHCS on October 29, 2019, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 public health emergency, efforts are now suspended. Please refer to the response to recommendation three referencing DHCS' response to the COVID-19 public health emergency, and the attachment below:

- California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending

Per the department's response, it will not fully implement this recommendation until June 2022.


Response is unchanged. The California Advancing and Innovating Medi-Cal Proposal released by DHCS on October 29, 2019, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 public health emergency, efforts are now suspended. Please refer to the response to recommendation three referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

- California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending


The California Advancing and Innovating Medi-Cal Proposal released by DHCS on October 29, 2019, proposes to implement Enhanced County Eligibility Oversight and Monitoring Activities which include establishing procedures defining when DHCS will use authority to sanction unresponsive counties not remedying known discrepancies. Due to the COVID-19 public health emergency, efforts are now suspended. Please refer to the response to recommendation three referencing DHCS' response to the COVID-19 pandemic, and the attachment below:

- California Advancing and Innovating Medi-Cal Proposal

California State Auditor's Assessment of Status: Pending


DHCS will implement a holistic "Assessment and Expectations in the Administration of the Medi-Cal Program" policy, which will include the development of county performance standards expectations. DHCS will work with county partners to establish a tiered corrective action approach to:

- Ensure that DHCS provides technical assistance to counties upon request.

- Identify, address, and correct error trends found through the course of external and internal reviews.

- Impose a corrective action requirement for counties that do not meet performance expectations.

It is anticipated that utilizing this approach will allow the department the opportunity to:

- Isolate areas where additional oversight is required.

- Work collaboratively with stakeholders to correct deficiencies in the administration of the program.

- Develop a fair, and effective progressive disciplinary approach to leverage when, and if, necessary.

The proposed timeline for implementing this policy is outlined in the attachment.

California State Auditor's Assessment of Status: Pending

According to Health Care Services' response, implementation of this recommendation is still pending.


DHCS will implement a holistic "Assessment and Expectations in the Administration of the Medi-Cal Program" policy, which will include the development of county performance standards expectations. DHCS will work with county partners to establish a tiered Corrective Action approach to: ensure that DHCS provides technical assistance to counties upon request, identify, address and correct error trends found through the course of external and internal reviews, and impose a corrective action requirement for counties that do not meet performance expectations. It is anticipated that utilizing this approach will allow the Department the opportunity to isolate areas where additional oversight is required, work collaboratively with stakeholders to correct deficiencies in the administration of the program, and develop a fair, and effective progressive disciplinary approach to leverage when, and if, necessary. The proposed timeline for implementing this policy is outlined in the attachment.

California State Auditor's Assessment of Status: Pending

Per Health Care Services' response, implementation of this recommendation is pending.


DHCS is in the process of issuing a Medi-Cal Eligibility Division (MCED) Information Letter that notifies counties of the reinstatement of self-certification of performance standards. It should be noted that since this effort requires communications with stakeholder outside of DHCS, and due to other work efforts associated with other recommendations for this audit, the anticipated date of completion is now August 31, 2019.

California State Auditor's Assessment of Status: Pending

According to Health Care Services' response, implementation of this recommendation is still pending.


DHCS is in the process of issuing a Medi-Cal Eligibility Division (MCED) Information Letter that notifies counties of the reinstatement of self-certification of performance standards. It should be noted that since this effort requires communications with stakeholder outside of DHCS, and due to other work efforts associated with other recommendations for this audit, the anticipated date of completion is now August 31, 2019.

California State Auditor's Assessment of Status: Pending


DHCS is in the process of scheduling meetings with counties to clarify the department's expectations of overall performance. Upon completion of these meetings, DHCS will develop metrics to measure performance and accountability, and administrative procedures to address performance issues. DHCS is on target to establish these procedures by July 1, 2019.

California State Auditor's Assessment of Status: Pending


All Recommendations in 2018-603

Agency responses received are posted verbatim.