
March 2026
The Compliance4U newsletter offers insight into the day-to-day functions of the Health Plan’s Compliance Program and serves as a resource to help staff stay informed about key regulatory updates, reporting obligations, audit activities, and policy changes. Its goal is to promote awareness, accountability, and a culture of compliance across all departments within HPSJ/MVHP (“Health Plan”)
Spotlight: Why Department-Level Monitoring Matters
In Medi-Cal Managed Care, staying compliant isn’t just about passing audits it’s about being ready every day. Department-level monitoring plays a critical role in keeping the Plan ahead of potential regulatory findings and aligned with our mission to deliver high-quality care.
What makes monitoring so important?
• It catches issues early. Regular review of timeliness, accuracy, workflows, and data quality gives teams the chance to correct problems before they become formal findings or trigger Corrective Action Plans.
• Regulators expect real-time oversight. DHCS and other agencies increasingly look for evidence that plans are actively monitoring their operations not waiting for an audit to discover gaps.
• It protects our members. Timely authorizations, accurate provider data, clean encounters, and strong grievance processing directly impact access, safety, and member experience.
• It strengthens operational accountability. When departments own their monitoring, Compliance can focus on advising and supporting not firefighting.
• It builds continuous audit readiness. When documentation is current, processes are aligned with APLs and contract requirements, and data is reliable, audits become smoother, faster, and far more successful.
Bottom line: Department-level monitoring is not just a compliance requirement, it is a proactive strategy that protects members, reduces risk, and reinforces a culture of excellence. In the Managed Care world, it’s one of the most important things we do to stay ready, responsive, and resilient.
Our success in staying audit-ready doesn’t come from any one team, it comes from all of us working together. When each department leans in, monitors its processes, and shares insights openly, we create a stronger, more proactive Plan. This is true collaboration in action: Compliance, Operations, and every supporting function moving in the same direction, with the same commitment to excellence. Together, we’re not just meeting expectations, we’re setting the standard for what high-quality, member-focused Managed Care should look like.
Regulatory Affairs D-SNP Updates

CMS issues Health Plan Management System Memos (HPMS Memos). These are similar to APLs where it serves as a regulatory notification with new or updates to requirements or regulations, as well as information on what’s coming through in the near future. HPMS memos are less defined compared to an APL, therefore, Compliance must interpret, assess for business ownership, impact and action items. It is important to read each one sent to business areas to determine business impact.
Below is a list of HPMS memos that are actionable:
Frequently Asked Questions Related to the Medicare GLP-1 Bridge
Issue Date: March 3, 2026
Summary: This memo provides FAQs to Plans who intend to participate in the BALANCE Model and bridge Medicare GLP-1s. This is currently being reviewed through the CY 2027 Bid process.
Encounter Data Software Release Updates: March 20, 2026
Issue Date: March 16, 2026
Summary: This memo provides information concerning updates to the Encounter Data Processing System (EDPS) effective March 20, 2026. Changes described include deactivation of edits, updates to the validation criteria within existing edits, and new edits. Edits within the EDPS have two
possible dispositions: Informational and Reject. Edifecs will deploy updates to the HPSJ Encounter processing platform.
Release of the Updated Important Message from Medicare (IM) and Detailed Notice of Discharge (DND)
Issue Date: March 19, 2026
Summary: The Office of Management and Budget approved the updated Important Message from Medicare (IM) and Detailed Notice of Discharge (DND) for 3 years. CMS improved the notices’ readability and design. The new forms are posted in English and Spanish on CMS’ BNI webpage.
Part D-Medicare Part D Manufacturer Discount Program: April 2026 Participating Labeler Code List and Phase-In National Drug Code List
Issue Date: March 25, 2026
Summary: CMS has updated the Labeler and NDC-9 Lists, which lists the manufacturers that are participating in the Manufacturer Discount Program. PBM, MedImpact updates their system to capture this list monthly.
Computer-Based Training Series on Risk Adjustment: 2026 Calendar Year Updates
Issue Date: March 26, 2026
Summary: CMS is pleased to announce the next module of its computerbased training series on risk adjustment. The new module (Module 7) provides an overview of the updates for calendar year 2026 from the 2026 Rate Announcement.
Health Plan Management System (HPMS) Program Integrity (PI) Portal for Fraud, Waste and Abuse (FWA) Reporting Module - New Fee-For-Service (FFS) Payment Suspensions Report Announcement
Issue Date: March 26, 2026
Summary: CMS received requests from Plans to share the FFS payment suspension report on a more frequent basis. Therefore, the monthly FFS Payment Suspension report will be available in the FWA Report module. The information in the report is intended to support plan sponsors by enhancing transparency and assisting with plan sponsors’ own FWA efforts.
Note, limited information will be provided in the monthly report, while additional information regarding the FFS suspension will continue to be provided in the FWA Quarterly Plan Report. The report will be available April 8, 2026.
Part C Independent Review Entity (IRE) Contract Award and Transition Notification
Issue Date: March 31, 2026
Summary: CMS has awarded C2C Innovative Solutions, Inc. (C2C) on February 26, 2026. Effective May 1, 2026, C2C will be responsible for conducting appeals for adverse reconsiderations issued by Part C plans, as well as reviews of plan dismissals of appellant reconsideration requests.
Existing IRE vendor, MAXIMUS, will continue to process appeals received on or before April 30, 2026. To date, Health plan has not submitted any appeals to IRE.
Regulatory Affairs Medi-Cal Updates
All Plan Letters (APLs)
DHCS and DMHC issue All Plan Letters (APLs) to formally communicate updates to federal or state policy, regulatory requirements, or operational procedures. These directives are intended to guide Managed Care Plans (MCPs) on how to implement changes and ensure compliance with applicable laws and regulations.
RA reviews and analyzes each APL to interpret its impact, coordinate internal implementation, and ensure timely compliance and required filings.
Draft APLs often identified with placeholder codes such as “XXX” are released by the regulators to solicit feedback from MCPs before finalization. During this comment period, MCPs can raise concerns or seek clarification, which may influence the final version of the policy.
Below is a list of recently released APLs for your awareness:
A. DHCS Regulatory Notices
APL 26-003 Quality Measures for Encounter Data Update: Quality Measures for Encounter Data 2.0 (QMED 2.0) (Supersedes APL 14-020)
Attachment: Quality Measures for Encounter Data- Version 2.0
Issue Date: March 13, 2026
Summary: This APL notifies Health Plan about an update to the DHCS QMED requirements
APL 26-004 Medi-Cal Managed Care Plan (MCP) Responsibilities for Behavioral Health Data-Sharing
Issue Date: March 16, 2026
Summary: This APL provides Health Plan with clarified guidance regarding existing responsibilities for data sharing, including ensuring data privacy and security of Members’ behavioral health data with Medi-Cal Third-Party Entities in real time pursuant to Assembly Bill 133, Health and Safety Code section 130290, the California Health and Human Services Data Exchange Framework (DxF) Policies and Procedures (P&Ps), MCP’s DHCS contract requirements, relevant APLs, and other state and federal statutes and guidance including HIPAA, recent updates to the 42 Code of Federal Regulations Part 2 regulations, Information Blocking, and CMS Interoperability and Patient Access Final Rule (May 2020), and CMS Interoperability and Prior Authorization Final Rule (January 2024).
APL 26-005 Maternity Services for Pregnant and Postpartum Medi-Cal Members (Not Yet Posted Online) (Supersedes APLs 00-012, 18-022, and PLs 98-006, 98-010, and 12-003)
Issue Date: March 25, 2026
Summary: Referred to as the Omnibus Maternity Services APL, this APL consolidates and updates guidance for MCPs on the maternity benefits that MCPs are required to provide to pregnant and postpartum Members. This APL also retires APL 01-003 and Policy Letters (PLs) 98-001 and 02-004.
APL 26-006 Skilled Nursing (SNF) Facility Workforce Quality Incentive Program (WQIP) (Not Yet Posted Online) (Supersedes APL 25-002)
Issue Date: March 30, 2026
Summary: This APL provides MCPs with instructions on the payment and data sharing process required for the SNF WQIP for Rating Periods between
01/01/2023 and 12/31/2025. The Calendar Year 2023 Rating Period is referred to as Program Year 1, Calendar Year 2024 as Program Year 2, and so forth.
B. DMHC Regulatory Notices
APL 26-005 Compliance with Assembly Bill 904, Maternal and Infant Health Equity Program
Issue Date: March 20, 2026
Summary: This APL informs plans covering maternity services of the filing requirements necessary to demonstrate compliance with and implementation of Assembly Bill 904. Medi-Cal plans such as Health Plan are considered to already meet the requirements of Assembly Bill 904 as long as DHCS continues to require MCPs to have doulas in their provider networks.
Regulatory Reports
Under the terms of our contract with DHCS and in alignment with our KnoxKeene license requirements regulated by DMHC the Plan is required to routinely submit reports that demonstrate operational performance and regulatory compliance. RA tracks and coordinates these submissions to ensure timeliness and accuracy across all departments.
Below is a list of upcoming regulatory reports due to our regulators in April 2026. The table includes the accountable Director and Executive sponsor for awareness and coordination. Please review the list to determine which reports fall within your area. Reports due for the upcoming month should be saved in this Dropbox Folder.
Report Name
Monthly Certification and Enrollment Reporting: Report Summarizing the previous month's D-SNP enrollment numbers
Accountable DT
Accountable ET
Somatra Sourng Michelle Tetreault
Monthly CBAS Waiver
Monthly 274 File
Monthly ECM/CS JSON
Pamela Lee Lakshmi Dhanvanthari
Clarence Rao
Clarence Rao
Monthly MCPD/PCPA JSON Clarence Rao
Monthly Data Certification
Monthly Post Payment Recovery (PPR)
Monthly Member Data Discrepancy Notification
Monthly Member Death Notification
Monthly Restricted Provider Site Verification
Monthly Consolidated Billing
Monthly Provider Information Network (PIN)
Monthly Encounter Data
Victoria Worthy
Victoria Worthy
Victoria Worthy
Tamara Hayes Betty Clark
Christopher Navarro
Michelle Tetreault
Tamara Hayes Betty Clark
Tamara Hayes
Betty Clark
Toni White Betty Clark
Clarence Rao
Victoria Worthy
Ana Aranda Liz Le
Clarence Rao
Monthly New Member Mailing Vena Ford
Monthly NMT-NEMT
Monthly Provider Directory
Dale Standfill
Ana Aranda
Victoria Worthy
Evert Hendrix
Liz Le
Liz Le
Monthly Financial Somatra Sourng Michelle Tetreault
Quarterly PHM Key Performance Indicator (KPI)
Quarterly CBAS Report
Quarterly Consumer Governance Boards: Committee Meeting Minutes and Agendas
Quarterly MOU Good Faith Efforts Status Report
Quarterly Pending & Unresolved Grievances Report
Quarterly Provider Network Impact Report
Quarterly Interoperability API Utilization
Semi-Annual Provider Directory
Johnathan Yeh Lakshmi Dhanvanthari
Pamela Lee Lakshmi Dhanvanthari
None
Tracy Hitzeman
Jeanette Lucht Lakshmi Dhanvanthari
RJ Ruiz
Lakshmi Dhanvanthari
Ana Aranda
Clarence Rao
Ana Aranda
Liz Le
Victoria Worthy
Liz Le
Annual CAC Demographic None Tracy Hitzeman
Annual Key Personnel Disclosure Form Tamara Hayes Betty Clark
Annual Marketing Plan Vena Ford Liz Le
Provider
Complaints
Provider complaints come to Health Plan in different forms (e.g., direct call to us or dispute submission to DMHC). While our Provider Services and Claims teams address those coming into us, Compliance is the point of contact for those coming through DMHC. In 2026, Health Plan received 21 requests (18 new Provider Complaints and 3 additional information requests), disputing 26 claims. In 2025, Health Plan received 70 requests (41 new Provider Complaints and 29 additional information requests), disputing 48 claims.
Compliance coordinates a cross-functional group to review each complaint we receive. This group investigates the cases (from the original request to claim processing and dispute resolution) and prepares a comprehensive response to the DMHC about the provider’s concerns and the actions taken by us. These tables outline the status:
DMHC Consumer Complaints and Independent Medical Review (IMR):
Effective May 2025, RA manages the intake, tracking, and submission of all DMHC consumer complaints and Independent Medical Reviews (IMR) to ensure timely, compliance, and coordinated responses in collaboration with Grievance & Appeals.
DMHC Consumer Complaints
The following reflects the Consumer Complaints received, including analyses by case reason, urgency and outcome.
• Table A displays the Consumer Complaint reasons for Standard Cases, Expedited Cases and Additional Information Requests.
• Table B shows the Consumer Complaint outcomes for Standard Cases, Expedited Cases and Additional Information Requests.
DMHC Independent Medical Review
Table C below reflects the number of IMR cases received from the Department since May 30, 2025, and their outcomes
Table C: DMHC Independent Medical Review (IMR) (May 30, 2025- April 3, 2026

What’s going on at the State and Federal levels? To support you in your role and ensure timely awareness of changes to regulatory and contractual requirements, Regulatory Affairs staff attend regulatory calls (e.g., DHCS Managed Care Plan Call - MCPC) and other regulatory meetings/calls where key regulatory information is shared.
Calls Held by Health Plan’s Regulators
Regulatory Affairs staff maintain materials from regulator calls. Check out previous meetings HERE.
Do you have a question for Compliance? To submit an inquiry, go to Team Sites > Compliance > Requests > Submit an Inquiry on SharePoint or simply use this link: check it out here.

