Report 2018-124 Recommendation 2 Responses
Report 2018-124: Gold Coast Health Plan: Its Reimbursements to Pharmacies Are Reasonable, but Its Pharmacy Benefits Manager Did Not Always Process Claims Correctly (Release Date: August 2019)
Recommendation #2 To: Gold Coast Health Plan
To ensure that it addresses any significant performance issues by its contractors in a timely manner, Gold Coast should establish a process to immediately require contractors to take necessary corrective action to resolve such issues and ensure that they do not recur. This process should include deadlines for implementing the corrective action and the steps Gold Coast must take to ensure that the contractor has implemented the action as directed.
6-Month Agency Response
GCHP adopted the PBM Corrective Action Plan Policy to supplement GCHP's existing Delegated Oversight Policy (Policy Number DO-001 - Delegation Oversight - Subcontracting Arrangements). This PBM Policy governs responses to potential areas of performance issues under the PBM contract, including notice of the performance issue and potential remedies such as notices of default, and corrective action plans. This PBM Corrective Action Plan policy was approved by the California Department of Health Care Services on December 30, 2019.
- Completion Date: December 2020
- Response Date: February 2020
California State Auditor's Assessment of 6-Month Status: Fully Implemented
60-Day Agency Response
GCHP has developed a Policy and Procedure to supplement the existing GCHP policies and procedures that are currently in place for delegation oversight.The Policy developed is specific to the PBM.
The Policy is labeled "draft" as GCHP is contractually required to submit the policy and procedure to DHCS for review and approval. The policy is currently under DHCS review. GCHP is currently adhering to the Policy.
- Completion Date: October 2019
- Response Date: October 2019
California State Auditor's Assessment of 60-Day Status: Pending
Until DHCS approves the draft policy, we will continue to report the status of this recommendation as not fully implemented.
All Recommendations in 2018-124
Agency responses received are posted verbatim.