Report 2020-613 All Recommendation Responses
Report 2020-613: Department of Health Care Services: Despite the COVID-19 Public Health Emergency, the Department Can Do More to Address Chronic Medi‑Cal Eligibility Problems (Release Date: July 2021)
Recommendation #1 To: Health Care Services, Department of
To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, begin monitoring statewide alerts related to individuals identified as eligible for Medi-Cal in a county eligibility data system but not identified as eligible in the state eligibility system.
DHCS continues to monitor counties regularly through the Medi-Cal Eligibility Database Systems (MEDS) Alert Pilot (MAP) reports. DHCS also published MEDS Alert Hierarchy policy letter ACWDL 23-14, providing counties guidance on what alerts impact eligibility and share of cost. DHCS will commence monitoring the alerts identified in ACWDL 23-14 on June 1, 2024. The new implementation date of June 1, 2024, aligns with the end of DHCS' eligibility and unwinding activities.
- Estimated Completion Date: 06/01/2024
California State Auditor's Assessment of Status: Pending
In addition to the previous update, the Centers for Medicare and Medicaid Services (CMS) has confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, (enacted December 29, 2022), and the continuous enrollment requirement ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of renewals, on April 1, 2023. The new implementation date to initiate these activities is May 1, 2024.
- Estimated Completion Date: 04/01/2024
California State Auditor's Assessment of Status: Pending
In the effort to begin monitoring these statewide alerts, DHCS will alert counties regularly through the MEDS Alert Pilot (MAP) reports. Covering the largest counties, these MAP reports will incorporate Medi-Cal Eligibility Database Systems (MEDS) alerts that indicate eligibility in Statewide Automated Welfare Systems (SAWS) but not in MEDS. Incorporating these alerts into the permanent, statewide MEDS Alert monitoring process is part of the California Advancing and Innovating Medi-Cal (CalAIM) county oversight and monitoring proposal, to be launched 12 months after the termination of the Public Health Emergency (PHE). This will allow counties the opportunity to focus on Centers for Medicare and Medicaid mandated PHE unwinding activities.
12 months after the termination of the PHE, DHCS will move forward with the original implementation plan as listed above and on the 30-day update.
- Estimated Completion Date: 04/01/2024
California State Auditor's Assessment of Status: Pending
The estimated implementation date was extended by four months and is now November 1, 2023, due to an extension of the PHE for COVID-19. The dates of implementation are dependent on the termination date of the PHE. Therefore, when the PHE termination date is extended, the dates must be recalculated based on the new termination date. Depending on the recommendation, the implementation plan cannot begin until a certain number of months after the PHE ends.
Otherwise, no change from the previous response, which was the 12-month program update submitted to CSA on July 12, 2022.
- Estimated Completion Date: 11/01/2023
California State Auditor's Assessment of Status: No Action Taken
DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the PHE with no modifications to the original plan. DHCS is working to incorporate Medi-Cal Eligibility Database Systems (MEDS) Alert number 6016, an alert that indicates eligibility in Statewide Automated Welfare Systems (SAWS) but not in MEDS, into the MEDS Alert Pilot (MAP) reports DHCS sends to counties on a regular basis. MAP consists of the largest counties in the state; therefore, MAP is sufficient to begin initial monitoring of the alert through the pilot. DHCS will incorporate alert number 6016 into a permanent, statewide MEDS Alert monitoring process as part of the California Advancing and Innovating Medi-Cal (CalAIM) county oversight and monitoring proposal effective July 1, 2023, or one year after the termination of the PHE.
- Estimated Completion Date: 7/1/2023
California State Auditor's Assessment of Status: Pending
DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the public health emergency (PHE) with no modifications to the original plan. DHCS is working to incorporate Medi-Cal Eligibility Database Systems (MEDS) Alert number 6016, an alert which indicates eligibility in Statewide Automated Welfare Systems (SAWS) but not in MEDS, into the MEDS Alert Pilot (MAP) reports DHCS sends to counties on a regular basis. MAP consists of the largest counties in the state; therefore, MAP is sufficient to begin initial monitoring of the alert through the pilot. DHCS will incorporate alert number 6016 into a permanent, statewide MEDS Alert monitoring process as part of the California Advancing and Innovating Medi-Cal (CalAIM) county oversight and monitoring proposal effective July 1, 2023, or one year after the termination of the PHE.
- Estimated Completion Date: 7/1/2023
California State Auditor's Assessment of Status: Pending
No change from the 60-Day update response. DHCS is working to incorporate Medi-Cal Eligibility Database Systems (MEDS) Alert number 6016, an alert which indicates eligibility in Statewide Automated Welfare Systems (SAWS) but not in MEDS, into the MEDS Alert Pilot (MAP) reports DHCS sends to counties on a regular basis. MAP consists of the largest counties in the state; therefore, MAP is sufficient to begin initial monitoring of the alert through the pilot. DHCS will incorporate alert number 6016 into a permanent, statewide MEDS Alert monitoring process as part of the California Advancing and Innovating Medi-Cal (CalAIM) county oversight and monitoring proposal no later than December 31, 2022.
- Estimated Completion Date: 12/31/2022
California State Auditor's Assessment of Status: Pending
No change from the draft report response. DHCS is working to incorporate MEDS Alert number 6016, an alert which indicates eligibility in SAWS but not in MEDS, into the MAP reports DHCS sends to counties on a regular basis. MAP consists of the largest counties in the state; therefore, MAP is sufficient to begin initial monitoring of the alert through the pilot. DHCS will incorporate alert number 6016 into a permanent, statewide MEDS Alert monitoring process as part of the CalAIM county oversight and monitoring proposal no later than December 31, 2022.
- Estimated Completion Date: 12/31/2022
California State Auditor's Assessment of Status: Pending
Recommendation #2 To: Health Care Services, Department of
To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, instruct counties to resume processing overdue determinations for individuals who have received temporary eligibility and make a determination on each applicant's Medi-Cal eligibility.
On April 7, 2022, DHCS instructed counties to terminate eligibility for individuals enrolled in an Accelerated Enrollment program and who have failed to provide requested information, as instructed in MEDIL 20-26, Section J. Please see attached agenda, Item Number 11, for confirmation.
- Completion Date: April 2022
California State Auditor's Assessment of Status: Fully Implemented
No later than May 31, 2022, DHCS will instruct counties to terminate eligibility for individuals enrolled in an Accelerated Enrollment program and who have failed to provide requested information, as instructed in MEDIL 20-26, Section J. DHCS will provide such instruction at one of the standing monthly meetings DHCS has with counties.
- Estimated Completion Date: 5/31/2022
California State Auditor's Assessment of Status: Pending
DHCS will communicate with counties through email to process alerts related to presumptive eligibility programs in accordance with MEDIL 20-26 section J.
Link to MEDIL 20-26:
https://www.dhcs.ca.gov/services/medi-cal/eligibility/letters/Documents/I20-26.pdf
Due to changes from the previous implementation plan, additional time is needed to complete the process resulting in an extension of the estimated implementation date to 01/31/22.
- Estimated Completion Date: 01/31/2022
California State Auditor's Assessment of Status: Pending
No change from draft report response. On August 14, 2020, DHCS released MEDIL 20 26 (section J) which notifies counties it is allowable to terminate eligibility for individuals enrolled in an Accelerated Enrollment program who fail to provide requested information.
Link to MEDIL 20-26:
https://www.dhcs.ca.gov/services/medi-cal/eligibility/letters/Documents/I20-26.pdf
- Completion Date: August 2020
California State Auditor's Assessment of Status: Pending
As we note in the report on page 37, rebuttal point 2, Health Care Services' claim that it has already fully implemented our recommendation is not correct. We acknowledge in the report that the department notified counties it is allowable to take action on cases with temporary eligibility. However, we also note that the department instructed counties to suspend processing reports, which include alerts for temporary eligibility.
- Auditee did not substantiate its claim of full implementation
Recommendation #3 To: Health Care Services, Department of
To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, expand its workgroup planning efforts to address all high-risk eligibility alerts included in the pilot program.
Per our previous response, DHCS continues to leverage PHE workgroups to level set expectations of county staff during the continuous coverage unwind. Additionally, DHCS began a quarterly series of MEDS trainings for the counties through the end of the continuous coverage unwind. DHCS published an All County Welfare Directors Letter (ACWDL) 23-14 informing counties to the MEDS Alerts hierarchy. The ACWDL prioritized MEDS alerts which impacts eligibility. Listed in the letter are the MEDS alerts which are monitored in MAP.
CMS confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, which ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of renewal activities on April 1, 2023, beginning unwinding annual renewals for the renewal due month of June 2023. The new implementation date is June 1, 2024.
- Estimated Completion Date: 06/01/2024
California State Auditor's Assessment of Status: Pending
As indicated in the previous response, DHCS leveraged PHE workgroups to level set expectations of county staff upon the termination of the PHE. Based on these discussions, DHCS issued ACWDL 22-18. This ACWDL provides extensive guidance on case processing actions after the termination of the PHE. Page 10 of the document specifically instructs counties to resolve all high-risk MEDS alerts. DHCS is currently exploring the possibility of providing counties with additional MEDS trainings that focus on resolving high priority MEDS alerts.
CMS has confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, (enacted December 29, 2022), which ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of renewals, on April 1, 2023. The new implementation date to initiate these activities is May 1, 2024.
Link to ACWDL:
https://www.dhcs.ca.gov/services/medi-cal/eligibility/letters/Documents/22-18.pdf
- Estimated Completion Date: 05/01/2024
California State Auditor's Assessment of Status: Pending
DHCS leveraged PHE workgroups to level set expectations of county staff upon the termination of the PHE. Based on these discussions, DHCS issued All County Welfare Letter (ACWDL) 22-18. This ACWDL provides extensive guidance on case processing actions after the termination of the PHE. Page 10 of the document specifically instructs counties to resolve all high-risk MEDS alerts.
Link to ACWDL: https://www.dhcs.ca.gov/services/medi-cal/eligibility/letters/Documents/22-18.pdf
- Estimated Completion Date: 06/24/2024
California State Auditor's Assessment of Status: Pending
The estimated implementation date was extended by four months and is now September 30, 2023, due to an extension of the PHE for COVID-19. The dates of implementation are dependent on the termination date of the PHE. Therefore, when the PHE termination date is extended, the dates must be recalculated based on the new termination date. Depending on the recommendation, the implementation plan cannot begin until a certain number of months after the PHE ends.
Otherwise, no change from the previous response, which was the 12-month program update submitted to CSA on July 12, 2022.
- Estimated Completion Date: 9/30/2023
California State Auditor's Assessment of Status: No Action Taken
The implementation plan dates were extended seven months due to the extension of the PHE. There has been no change to the implementation plan. DHCS began a cross-divisional workgroup to review all MEDS alerts, and to prioritize MEDS alerts for counties to follow. This will ensure that counties process the most critical alerts accurately and timely. As previously stated, DHCS will ensure the PHE lift workgroup planning efforts incorporate resolution of system discrepancies as a component of the activities counties will perform once the PHE is lifted.
- Estimated Completion Date: 1/31/2023
California State Auditor's Assessment of Status: Pending
DHCS began a cross-divisional workgroup review for all MEDS alerts and is working to prioritize MEDS alerts for counties to follow. This will ensure that counties process the most critical alerts accurately and timely. As previously stated, DHCS will ensure the PHE lift workgroup planning efforts incorporate resolution of system discrepancies as a component of the activities counties will perform once the PHE is lifted.
- Estimated Completion Date: 6/30/2022
California State Auditor's Assessment of Status: Pending
Through various discussions, DHCS does not believe that the PHE lift workgroup has the participants needed to address the issue. Therefore, high-risk MEDS alerts will be addressed through the MEDS pilot which will be expanded to include all counties in discussions related to MEDS alerts processing upon termination of the PHE.
Due to the anticipated extension of the PHE that may result in updated guidance from the Centers for Medicare and Medicaid Services additional time is needed to complete the process. This resulted in the extension of the estimated implementation date to 04/30/2022.
- Estimated Completion Date: 04/30/2022
California State Auditor's Assessment of Status: Pending
No change from draft report response. DHCS will ensure PHE lift workgroup planning efforts incorporate resolution of system discrepancies as a component of the activities counties will perform once the PHE is lifted.
- Estimated Completion Date: 10/31/2021
California State Auditor's Assessment of Status: Pending
Recommendation #4 To: Health Care Services, Department of
To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, resume monitoring pilot program counties' progress in resolving high-risk eligibility alerts.
CMS has confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, (enacted December 29, 2022), which ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of annual renewals for beneficiaries due for renewal in the month of June 2023, on April 1, 2023. Please see DHCS' Covid-19 PHE Unwind Plan here for comprehensive information regarding the resumption of annual renewals. Included in the Unwind Plan is CMS' guidance supporting state agencies in returning to normal operations through a series of State Health Official (SHO) letters - December 2020, August 2021, and March 2022 and the guidance DHCS has released throughout the PHE. The new implementation date to initiate the activities is June 1, 2024.
- Estimated Completion Date: 06/01/2024
California State Auditor's Assessment of Status: Pending
In addition to the previous update, CMS has confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, (enacted December 29, 2022), which ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of renewals, on April 1, 2023. The new implementation date to initiate these activities is May 1, 2024.
- Estimated Completion Date: 05/01/2024
California State Auditor's Assessment of Status: Pending
DHCS plans to resume all pilot program related activities, including resolution of high-risk eligibility alerts, as of the implementation date 12 months after the termination of the PHE. This will allow counties the opportunity to focus on Centers for Medicare and Medicaid Services (CMS) mandated PHE unwinding activities.
12 months after the termination of the PHE, DHCS will move forward with the original implementation plan as listed above, and on the 30-day update.
- Estimated Completion Date: 04/01/2024
California State Auditor's Assessment of Status: Pending
The estimated implementation date was extended by four months and is now November 1, 2023, due to an extension of the PHE for COVID-19. The dates of implementation are dependent on the termination date of the PHE. Therefore, when the PHE termination date is extended, the dates must be recalculated based on the new termination date. Depending on the recommendation, the implementation plan cannot begin until a certain number of months after the PHE ends.
Otherwise, no change from the previous response, which was the 12-month program update submitted to CSA on July 12, 2022.
- Estimated Completion Date: 11/01/2023
California State Auditor's Assessment of Status: No Action Taken
DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the PHE with no modifications to the original plan. DHCS plans to resume all pilot program related activities, including resolution of high risk eligibility alerts, as of the implementation date, effective July 1, 2023, or one year after the termination of the PHE.
- Estimated Completion Date: 7/1/2023
California State Auditor's Assessment of Status: Pending
DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the PHE with no modifications to the original plan. DHCS plans to resume all pilot program related activities, including resolution of high risk eligibility alerts, as of the implementation date, which is projected to be 12 months after the end of the PHE.
- Estimated Completion Date: 7/1/2023
California State Auditor's Assessment of Status: Pending
No change from the 60-Day update response. DHCS plans to resume all pilot program related activities, including resolution of high risk eligibility alerts, as of the implementation date.
- Estimated Completion Date: 01/31/2023
California State Auditor's Assessment of Status: Pending
No change from draft report response. DHCS plans to resume all pilot program related activities, including resolution of high risk eligibility alerts, as of the implementation date.
- Estimated Completion Date: 01/31/2023
California State Auditor's Assessment of Status: Pending
Recommendation #5 To: Health Care Services, Department of
To ensure that it is addressing weaknesses in the counties' processes for making eligibility redeterminations, Health Care Services should review data collected during the focus reviews it conducted in 2018 and 2019 to identify areas in policy for which further county guidance is needed and, by September 1, 2021, share a written summary of the identified concerns with all counties.
DHCS will analyze the data collected from focus reviews between 2018 and 2019 and share common trends with counties as of the implementation date.
On December 15, 2021, DHCS issued Medi-Cal Eligibility Division Information Letter (MEDIL) No. 21-40.
This MEDIL serves as formal communication to counties of statewide error trends identified through the 2018-2019 Focus Reviews.
Link to the MEDIL: https://www.dhcs.ca.gov/services/medi-cal/eligibility/letters/Documents/I21-40.pdf
- Completion Date: December 2021
California State Auditor's Assessment of Status: Fully Implemented
No change from the draft report response. DHCS will analyze the data collected from focus reviews between 2018 and 2019 and share common trends with counties as of the implementation date.
- Estimated Completion Date: 09/30/2021
California State Auditor's Assessment of Status: Pending
Recommendation #6 To: Health Care Services, Department of
To ensure that it is addressing weaknesses in the counties' processes for making eligibility redeterminations, Health Care Services should resume county monitoring via focus reviews within four months of the end of the public health emergency.
CMS has confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, (enacted December 29, 2022), which ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of renewals for beneficiaries due for renewal in the month of June 2023, on April 1, 2023. Please see DHCS' Covid-19 PHE Unwind Plan here for comprehensive information regarding the resumption of annual renewals. Included in the Unwind Plan is CMS' guidance supporting state agencies in returning to normal operations through a series of State Health Official (SHO) letters - December 2020, August 2021, and March 2022 and the guidance DHCS has released throughout the PHE. The new implementation date to initiate the activities is June 1, 2024.
- Estimated Completion Date: 06/01/2024
California State Auditor's Assessment of Status: Pending
In addition to the previous update, CMS has confirmed the continuous enrollment requirement is now delinked from the PHE in the Consolidation Appropriations Act of 2023, (enacted December 29, 2022), which ended on March 31, 2023. DHCS began the continuous coverage requirement unwinding activities, including the resumption of renewals, on April 1, 2023. The new implementation date to initiate these activities is May 1, 2024.
- Estimated Completion Date: 05/01/2024
California State Auditor's Assessment of Status: Pending
DHCS will resume focus reviews 12 months after the termination of the PHE. This will allow counties the opportunity to focus on CMS mandated PHE unwinding activities.
12 months after the termination of the PHE, DHCS will move forward with the original implementation plan as listed above, and on the 30-day update.
- Estimated Completion Date: 04/01/2024
California State Auditor's Assessment of Status: Pending
The estimated implementation date was extended by four months and is now November 1, 2023, due to an extension of the PHE for COVID-19. The dates of implementation are dependent on the termination date of the PHE. Therefore, when the PHE termination date is extended, the dates must be recalculated based on the new termination date. Depending on the recommendation, the implementation plan cannot begin until a certain number of months after the PHE ends.
Otherwise, no change from the previous response, which was the 12-month program update submitted to CSA on July 12, 2022.
- Estimated Completion Date: 11/01/2023
California State Auditor's Assessment of Status: No Action Taken
The implementation plan dates were extended six months due to the extension of the PHE. CSA recommends focus reviews to resume four months after the termination of PHE; however, due to work volume post-PHE operation, counties should be allowed a 12-month timeframe. DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the PHE with no modifications to the original plan. DHCS will resume focus reviews effective July 1, 2023, or one year after the termination of the PHE due to the level of effort needed at the county level in the year after the end of the PHE, and to ensure counties perform all PHE related activities timely.
- Estimated Completion Date: 7/1/2023
California State Auditor's Assessment of Status: Pending
DHCS plans to move forward with the implementation plan provided in the previous update upon termination of the PHE with no modifications to the original plan. DHCS will resume focused reviews 12 months after the termination of the PHE (currently projected to be July 2023) due to the level of effort needed at the county level in the year after the end of the PHE, to ensure counties perform all PHE related activities timely.
- Estimated Completion Date: 7/1/2023
California State Auditor's Assessment of Status: Pending
No change from the 60-Day update response. DHCS will resume focused reviews in January 2023, due to the level of effort needed at the county level in the 12 months preceding the end of the PHE, to ensure all PHE related activities are completed timely.
- Estimated Completion Date: 01/31/2023
California State Auditor's Assessment of Status: Pending
No change from draft report response. DHCS will resume focused reviews in January 2023, due to the level of effort needed at the county level in the 12 months preceding the end of the PHE, to ensure all PHE related activities are completed timely.
- Estimated Completion Date: 01/31/2023
California State Auditor's Assessment of Status: Pending
All Recommendations in 2020-613
Agency responses received are posted verbatim.