HomeMy WebLinkAboutSTATE Department of Health Care Services-Medi-Cal County Inmate Program Participation Agreement_A-22-101 A-20-262.pdf COIj County of Fresno Hall of Records,Room 301
2281 Tulare Street
Fresno,California
Board of Supervisors 93721-2198
O� 185 0 Telephone:(559)600-3529
FRE`' Minute Order Toll Free: 1-800-742-1011
www.co.fresno.ca.us
March 22, 2022
Present: 5- Supervisor Steve Brandau, Supervisor Nathan Magsig, Supervisor Buddy Mendes,
Chairman Brian Pacheco, and Vice Chairman Sal Quintero
Agenda No. 53. Public Health File ID: 22-0018
Re: Approve and authorize the Chairman to execute a retroactive Administrative Activities Addendum to
the Participation Agreement with the California Department of Health Care Services (DHCS)for
participation in the Medi-Cal County Inmate Program(MCIP), effective January 1,2022,to remain in
effect upon the same terms and conditions as long as the County has an active Administrative
Services Agreement with DHCS with no change to the compensation maximum of$800,000
APPROVED AS RECOMMENDED
Ayes: 5- Brandau, Magsig, Mendes, Pacheco, and Quintero
Agreement No.22-101
County of Fresno Page 56
co
Board Agenda Item 53
0 1856 0
FRESH
DATE: March 22, 2022
TO: Board of Supervisors
SUBMITTED BY: David Luchini, RN, PHN, Director, Department of Public Health
Margaret Mims, Sheriff-Coroner, Public Administrator
SUBJECT: Retroactive Administrative Activities Addendum to Medi-Cal County Inmate Program
Participation Agreement with the California Department of Health Care Services
RECOMMENDED ACTION(S):
Approve and authorize the Chairman to execute a retroactive Administrative Activities Addendum
to the Participation Agreement with the California Department of Health Care Services (DHCS)for
participation in the Medi-Cal County Inmate Program (MCIP), effective January 1,2022, to remain in
effect upon the same terms and conditions as long as the County has an active Administrative
Services Agreement with DHCS with no change to the compensation maximum of$800,000.
There is no additional Net County Cost associated with the recommended action. The original Participation
Agreement did not include necessary reference language from 42 U.S.C. §12101, et. seq., related to the
Americans with Disabilities Act(ADA). The Participation Agreement allows medical providers in Fresno
County to seek reimbursement from the DHCS MCIP for covered inpatient hospital services, rendered to
eligible County adult inmates and juvenile wards, alleviating approximately 50% of inpatient service cost that
would otherwise be covered through county funds. This item is countywide.
ALTERNATIVE ACTION(S):
Should your Board not approve the recommended action, the current MCIP Participation agreement would
not contain the necessary ADA language and DHCS would immediately revoke the existing MCIP
Participation and Administrative agreements resulting in the termination of the County's ability to participate
in the MCIP Program. Should this happen, medical providers in Fresno County would not be able to seek
reimbursement from the DHCS MCIP for covered inpatient hospital services.
RETROACTIVE AGREEMENT:
The recommended Addendum is retroactive to January 1, 2022 as the Addendum was received from DHCS
on February 4, 2022.
FISCAL IMPACT:
There is no increase in Net County Cost associated with the recommended action. The estimated yearly
maximum compensation for the MCIP Participation Agreement remains at$800,000. The maximum
compensation covers the non-federal share of the DHCS MCIP eligible services billed to DHCS by medical
providers. Sufficient appropriations and estimated revenues are included in the Department's Org 5620 FY
2021-22 Adopted Budget and will be included in subsequent budget requests as needed.
County of Fresno page 1 File Number.22-0018
File Number:22-0018
DISCUSSION:
On July 7, 2020, your Board ratified an MCIP Participation Agreement(A-20-262) and Administrative
Agreement(A-20-263)with DHCS. The Participation Agreement allows medical providers in Fresno County
to seek reimbursement from the DHCS MCIP for covered inpatient hospital services (covered services)
rendered to eligible County adult inmates and juvenile wards (eligible inmates). The Administrative
Agreement provides for reimbursement to DHCS for their service costs to administer the MCIP for State
Fiscal Years 2020-23. Although there is no stated term end date to the Participation Agreement, the
County's continued participation in MCIP is contingent upon having an executed Administrative Agreement.
The County has been participating in the DHCS MCIP since 2017. On April 3, 2018, the Board approved
Agreement Nos. 18-169 and 18-170 with California Forensic Medical Group, Inc., (now Wellpath), which
provide for participation in MCIP for covered services. On October 23, 2018, the Board approved the
designation of the Sheriffs Office as an entity to assist eligible inmates at the County's Adult Detention
Facilities (Jail)to assist and act on behalf of those inmates in the MCIP application process.
During 2021, DHCS conducted speech, hearing, and vision disability, and language needs surveys to gauge
that the needs of eligible inmates are being met in the MCIP. DHCS issued Policy and Procedure Letter
(PPL) No. 21-017 on August 11, 2021, and PPL No. 21-017R on December 15, 2021, to clarify local
governmental agencies' responsibilities to provide eligible inmates who have speech, hearing, or vision
disabilities with auxiliary aids and services, including materials in alternative formats to ensure that they can
effectively communicate and participate in public programs, services, or activities, including MCIP.
The recommended addendum is a result of those surveys and PPLs and incorporates the County's
assurance to comply with the ADA(42 U.S.C. §12101, et. seq.) prohibiting discrimination on the basis of
disability, and section 508 of the Rehabilitation Act of 1973 as amended (29 U.S.C. § 794 (d)), which
ensures that visual-impaired, hearing-impaired, and other special needs eligible inmates are provided
material in the formats needed to provide the most assistance in making informed choices.
The existing Participation Agreement contains language stating that the County agrees to indemnify DHCS
and neither the Participation Agreement nor the recommended Addendum contains the standard County
indemnification language or insurance requirements; however, given the nature of the Agreement, including
the recommended Addendum, County Risk Management has approved of the agreement as being in the
County's best interest. The Participation Agreement remains in effect unless written notice of non-renewal
is given by either party to the other party by providing a 30-day written notice. Termination of the
Administrative Services Agreement will automatically terminate the Participation Agreement.
REFERENCE MATERIAL:
BAI#40, July 7, 2020
BAI#44, October 8, 2019
BAI#27, October 23, 2018
BAI #36, May 8, 2018
BAI #8.1, April 3, 2018
BAI #26, February 7, 2017
BAI #36.1, December 6, 2016
ATTACHMENTS INCLUDED AND/OR ON FILE:
On file with Clerk-Addendum to Participation Agreement with DHCS
On file with Clerk- DHCS PPL No. 21-017
On file with Clerk- DHCS PPL No. 21.017R
On file with Clerk-MCIP Participation Agreement FY 20-23#A-20-262
County of Fresno page 2 File Number.22-0018
File Number:22-0018
CAO ANALYST:
Ronald Alexander
County of Fresno Page 3 File Number:22-0018
Agreement No.22-101
COUNTY-BASED MEDI-CAL ADMINISTRATIVE ACTIVITIES
ADDENDUM TO
PARTICIPATION AGREEMENT
County: Fresno 20-MCIPFRESNO-10
The Department of Health Care Services (DHCS) and County of Fresno agree that
effective January 1, 2022; the addendum is incorporated into and hereby amends the
Participation Agreement 20-MCIPFRESNO-10:
ARTICLE XVI —ALTERNATIVE FORMATTING
A. The County of Fresno assures the state that it complies with the ADA, which
prohibits discrimination on the basis of disability, as well as all applicable
regulations and guidelines issued pursuant to the ADA.
B. County of Fresno will ensure that deliverables developed and produced pursuant
to this Agreement comply with federal and state laws, regulations or
requirements regarding accessibility and effective communication, including the
Americans with Disabilities Act (42 U.S.C. § 12101, et. seq.), which prohibits
discrimination on the basis of disability, and section 508 of the Rehabilitation Act
of 1973 as amended (29 U.S.C. § 794 (d)). Specifically, electronic and printed
documents intended as public communications must be produced to ensure the
visual-impaired, hearing-impaired, and other special needs audiences are
provided material information in the formats needed to provide the most
assistance in making informed choices. These formats include but are not limited
to braille, large font, and audio.
Except as amended herein, all other terms and conditions of the PA 20-MCIPFRESNO-
10 shall remain in full force and effect.
DocuSign Envelope ID:3C2DDE9B-OF5A-40AC-BA28-FAB9CE5OB563
J�) ATTEST:L BERNICE E.SEIDEL
Contract's Authorized Person's Signature Clerk of the Board of Supervisors
County of Fresno.State of California
Brian Pacheco Byy
Print Name Deoutv
Chairman of the Board of Supervisors of the County of Fresno
Title
2281 Tulare Street, 3rd Floor, Fresno, CA 93721
Address
3p,a �
- '9ooZ.
b'cuSigned by:
Fif".jYa
all rnla apartment of Health Care Services
Authorized Contact Person's Signature
Brian Fitzgerald
Print Name
Chief, Local Governmental Financing Division
Title
Department of Health Care Services
Name of Department
1501 Capitol Avenue, MS 2628, Sacramento, CA 95899-7413
Address
May 17, 2022
Date
California Department of Health Care Services
Name/No.: County-Based Medi-Cal Administrative Activities Addendum to
Participation Agreement
DHCS Agreement (No. 20-MCIPFRESNO-10)
Fresno County Agreement (No. A-20-262)
Fund/Subclass: 0001/10000
Organization #: 56201683
Revenue Account#: 7295
Est. $800,000 Annually
State of California—Health and Human Services Agency
DHCS
Department of Health Care Services
WILL LIGHTBOURNE GAVIN NEWSOM
DIRECTOR GOVERNOR
DATE: August 10, 2021 PPL No. 21-017
TO: Local Educational Agencies (LEAS), Local Educational Consortiums
(LECs), and the Local Governmental Agencies (LGAs), participating in the
Local Educational Agency Medi-Cal Billing Options Program (LEA BOP),
School-Based Medi-Cal Administrative Activities (SMAA) Program,
County-Based and Tribal Medi-Cal Administrative Activities
(CMAA/TMAA) Programs, Inmate Medi-Cal Claiming Unit (IMCU), and
Targeted Case Management (TCM) Program
SUBJECT: Alternative Format Request Requirements
This Policy and Procedure Letter (PPL) clarifies LEAS, LECs, LGAs, and their
subcontractors' responsibilities to provide qualified persons who have speech, hearing,
or vision disabilities with auxiliary aids and services, including materials in alternative
formats, to ensure that they can effectively communicate and participate in public
programs, services, or activities.
Overview
Under federal and state law, including the Americans with Disabilities Act (42 U.S.C. §
12101, et. seq.) and section 508 of the Rehabilitation Act of 1973, as amended (29
U.S.C. § 794 (d)), discrimination against qualified members of the public participating in
public programs based on disability is prohibited. A person is a qualified member of the
public if they are an appropriate person with whom a public agency should or would
communicate. The rights of persons with disabilities must be protected to ensure
meaningful and equal access to public services, including but not limited to Medi-Cal
and other programs that the Department of Health Care Services (DHCS) oversees in
whole or in part through partnerships with other entities, such as providers, facilities,
managed care plans, vendors, contractors, counties, or other state agencies. As such,
all LEAS, LECs, LGAs, and their subcontractors that provide services to Medi-Cal
beneficiaries must comply and adhere to these laws. Accordingly, LEAS, LECs, LGAs,
and their subcontractors must provide auxiliary aids and services to ensure that all
qualified members of the public with disabilities, including Medi-Cal beneficiaries, can
effectively communicate and participate in public programs, services and/or activities,
which includes making program documents available in alternative formats (e.g., braille,
large font, audio recording).
Local Governmental Financing Division
1501 Capitol Avenue, MS 2628, P.O. Box 997436
Sacramento, CA 95899-7436
https://www.dhcs.ca.gov
PPL 21-017
LEAs, LECs, and LGAs
Page 2
Auxiliary Aids and Services
All public agencies are required to provide auxiliary aids and services, free of charge, to
ensure all qualified persons with speech, hearing and/or vision disabilities can
effectively communicate and participate in public programs, services, and/or activities.
Public agencies must also provide auxiliary aids and services to a family member,
friend, or associate of the program participant if said individual is identified as the
beneficiary's authorized representative, or it is someone with whom it is appropriate to
communicate (e.g., a disabled parent of a beneficiary).
The type of auxiliary aid or service necessary requires consideration of, among other
things:
• The method of communication used by the person with a disability
• The nature, length, and difficulty of the communication taking place
• The complexity of what is being communicated
When providing aids or services, primary consideration should be given to the
requester's choice, unless the LEA, LEC, LGA, or subcontractor can demonstrate that
another equally effective means of communication is available or that use of the
requester's choice would result in a fundamental alteration of the information or an
undue burden for the agency. These auxiliary aids and services include providing
communications in alternative formats.
Alternative Format Requests
Policies regarding alternative formats were created to assist persons with disabilities to
communicate their needs effectively with necessary parties such as staff within an LEA,
LEC, LGA, or their subcontractor's agency. Opportunities for effective communication
must be provided to all qualified members of the public with disabilities, including those
who simply make contact seeking information about programs, services, or activities.
Alternative formats include, but are not limited to:
• Braille
• Large print (20-point Arial Font)
• Audio format
• Accessible electronic format (such as a data CD)
• Closed Captioning
• Text-to-Speech
• Voice-to-Text
PPL 21-017
LEAs, LECs, and LGAs
Page 3
Reporting and Ongoing Requirements
Medi-Cal beneficiaries and their representatives may only request one alternative
format each. Alternative format requests are recorded in DHCS' online Alternative
Format Selection Application (AFSA) system at the following link:
https://afs.dhcs.ca.gov/.
The following methods can be used to record requests:
1. Medi-Cal beneficiaries can input their request directly into the online system.
2. Medi-Cal beneficiaries can report their request to staff within an LEA, LEC, LGA,
or their subcontractor's agency who must input the beneficiaries' request into the
system.
3. A program participant within an LEA, LEC, LGA or their subcontractor's agency,
or the beneficiary can call 1-833-284-0040 and go through the prompt to input
the format request.
Additionally, if an LEA, LEC, LGA, or their subcontractor receives a request for an
alternative format from a qualified member of the public, the applicable document must
be provided within two months of the request. In cases where a beneficiary requests an
electronic format (such as an Audio CD), and the information requested contains
protected health information, the LEA, LEC, LGA, or their subcontractor must ask
whether the beneficiary elects to have documents encrypted. Furthermore, all
subsequent documentation provided to that individual must be in the requested format
and encrypted, as needed. As such, the requested alternative format should be stored
to guarantee that this requirement is met with every communication. LEAs, LECs,
LGAs, or their subcontractor's agencies may contact the applicable county's Health and
Human Services Agency for translation assistance with the following formats:
• Braille
• Large print (20-point Aria[ Font)
• Audio CD
• Accessible electronic format (data CD)
Ensuring Alternative Format Requirements are Met
LEAs, LECs, and LGAs must develop a plan to meet these alternative format
requirements within 180 days from the release of this PPL, and must continuously
monitor its effectiveness within their applicable LEAs and LGAs. LEAs, LECs, and LGAs
must store and maintain the plan within their audit file for oversight. DHCS reserves the
right to request a copy of the plan at any time 180 days after the release of this PPL.
PPL 21-017
LEAs, LECs, and LGAs
Page 4
If you have any questions, please use the information below to contact a specific
program:
LEA BOP: lea @-dhcs.ca.gov
SMAA: smaa(cbdhcs.ca.gov
CMAA/TMAA: cmaa(a),dhcs.ca.gov
IMCU: dhcsimcu(a)dhcs.ca.gov
TCM: tcm-dhcs(a.dhcs.ca.gov
Sincerely,
ORIGINAL SIGNED BY
Jillian Mongetta, Chief
Medi-Cal Claiming and Services Branch
Local Governmental Financing Division
DHCS State of California—Health and Human Services Agency
Department of Health Care Services i ' :
` _ I
MICHELLEBAASS GAVIN NEWSOM
DIRECTOR GOVERNOR
DATE: December 15, 2021 PPL No. 21-017R
TO: Local Educational Agencies (LEAS), Local Educational Consortiums
(LECs), and the Local Governmental Agencies (LGAs), participating in the
Local Educational Agency Medi-Cal Billing Options Program (LEA BOP),
School-Based Medi-Cal Administrative Activities (SMAA) Program,
County-Based and Tribal Medi-Cal Administrative Activities
(CMAA/TMAA) Programs, Inmate Medi-Cal Claiming Unit (IMCU), and
Targeted Case Management (TCM) Program
SUBJECT: Alternative Format Request Requirements
This Policy and Procedure Letter (PPL) clarifies LEAS, LECs, LGAs, and their
subcontractors responsibilities to provide qualified persons who have speech, hearing,
or vision disabilities with auxiliary aids and services, including materials in alternative
formats, to ensure that they can effectively communicate and participate in public
programs, services, or activities.
Overview
Under federal and state law, including the Americans with Disabilities Act (42 U.S.C. §
12101, et. seq.) and section 508 of the Rehabilitation Act of 1973, as amended (29
U.S.C. § 794 (d)), discrimination against qualified members of the public participating in
public programs based on disability is prohibited. A person is a qualified member of the
public if they are an appropriate person with whom a public agency should or would
communicate. The rights of persons with disabilities must be protected to ensure
meaningful and equal access to public services, including but not limited to Medi-Cal
and other programs that the Department of Health Care Services (DHCS) oversees in
whole or in part through partnerships with other entities, such as providers, facilities,
managed care plans, vendors, contractors, counties, or other state agencies.
Accordingly, LEAS, LECs, WAS, and their subcontractors must provide auxiliary aids
and services to ensure that all qualified members of the public with disabilities, including
Medi-Cal beneficiaries, can effectively communicate and participate in public programs,
services and/or activities, which includes making program documents available in
alternative formats (e.g., braille, large font, audio recording).
Local Governmental Financing Division
1501 Capitol Avenue, MS 2628, P.O. Box 997436
Sacramento, CA 95899-7436
https://w ww.dhcs.ca.gov
PPL 21-017R
LEAs, LECs, and LGAs
Page 2
Auxiliary Aids and Services
All public agencies are required to provide auxiliary aids and services, free of charge, to
ensure all qualified persons with speech, hearing, and/or vision disabilities can
effectively communicate and participate in public programs, services, and/or activities.
Public agencies must also provide auxiliary aids and services to a family member,
friend, or associate of the program participant if said individual is identified as the
beneficiary's authorized representative, or it is someone with whom it is appropriate to
communicate (e.g., a disabled parent of a beneficiary).
The type of auxiliary aid or service necessary requires the consideration of numerous
factors, including:
• The method of communication used by the person with a disability
• The nature, length, and difficulty of the communication taking place
• The complexity of what is being communicated
When providing aids or services, primary consideration should be given to the
requester's choice, unless the LEA, LEC, LGA, or subcontractor can demonstrate that
another equally effective means of communication is available or that use of the
requester's choice would result in a fundamental alteration of the information or an
undue burden for the agency. These auxiliary aids and services include providing
communications in alternative formats.
Alternative Format Requests
Policies regarding alternative formats were created by DHCS to assist persons with
disabilities to communicate their needs effectively with necessary parties such as LEA,
LEC, LGA, or their subcontractor's staff. Opportunities for effective communication must
be provided to all qualified members of the public with disabilities, including those who
are simply seeking information about programs, services, or activities.
Alternative formats include, but are not limited to:
• Braille
• Large print (20-point Arial Font)
• Audio format
• Accessible electronic format (such as a data CD)
• Closed Captioning
• Text-to-Speech
• Voice-to-Text
Please note: By choosing Audio or Data CD as an alternative format, beneficiaries will
receive their Medi-Cal notices and information in an electronic format that is not
PPL 21-017R
LEAs, LECs, and LGAs
Page 3
encrypted (password protected). Beneficiaries who wish to receive Medi-Cal notices
and information in a password protected electronic format should call 1-833-284-0040.
Reporting and Ongoing Requirements
Medi-Cal beneficiaries and their representatives may only request one alternative
format each. A provider can search for a Medi-Cal beneficiary's alternative format
selection in DHCS' online Alternative Format Selection Application (AFSA) system by
providing the beneficiary's name, Benefits Identification Card number, and date of birth.
Alternative format requests are recorded in the AFSA system at the following link:
https:Hafs.dhcs.ca.gov/.
The following methods can be used to record requests:
1. Medi-Cal beneficiaries can input their request directly into the online system.
2. Medi-Cal beneficiaries can report their request to LEA, LEC, LGA, or their
subcontractor's staff who must input the beneficiaries' requests into the system.
3. LEA, LEC, LGA, subcontractor staff or the beneficiary can call 1-833-284-0040
and go through the prompt to input the format request.
If an LEA, LEC, LGA, or their subcontractor receives a request for an alternative format
from a qualified member of the public, all documents provided to the beneficiary must
be provided within two months of the request. Furthermore, all subsequent
documentation provided to that individual must be in the requested alternative format
and encrypted, as needed. The requested alternative format should be stored to
guarantee that these requirements were met with every communication. LEAs, LECs,
LGAs, or their subcontractors may contact the applicable county's Health and Human
Services Agency for translation assistance with the following formats:
• Braille
• Large print (20-point Arial Font)
• Audio CD
• Accessible electronic format (data CD)
Additionally, the written communication needs to consider both alternative format and
written language preference (except braille). For example, if a beneficiary's alternative
format preference is large print and written language preference is Spanish, then written
communication to that beneficiary must be in Spanish and in large print.
The selection of braille is inherently the final language in its written preferred format.
The common form of braille for reproducing publications is contracted braille in the
United States.
Ensuring Alternative Format Requirements are Met
PPL 21-017R
LEAs, LECs, and LGAs
Page 4
LEAs, LECs, and LGAs must develop a plan to meet these alternative format
requirements within 180 days from the original release of this PPL, and must
continuously monitor its effectiveness within their applicable LEAs and LGAs. LEAs,
LECs, and LGAs must store and maintain the plan within their audit file for oversight.
DHCS reserves the right to request a copy of the plan at any time 180 days after the
release of the original PPL.
If you have any questions, please use the information below to contact a specific
program:
LEA BOP: lea(aD_dhcs.ca.gov
SMAA: smaa(a)_dhcs.ca.gov
CMANTMAA: cmaa(a)_dhcs.ca.gov
IMCU: dhcsimcu(a-).dhcs.ca.gov
TCM: tcm-dhcs(aD_dhcs.ca.gov
Sincerely,
Original signed by Jillian Mongetta
Jillian Mongetta, Chief
Medi-Cal Claims and Services Branch
Local Governmental Financing Division
Department of Health Care Services
State of California—Health and Human Services Agency
Department of Health Care Services
Medi-Cal County Inmate Program (MCIP)
Participation Agreement 20-MCIPFRESNO-10
County Name: County of Fresno
ARTICLE I — STATEMENT OF INTENT
The purpose of this Participation Agreement (PA) between the Department of Health Care Services
(DHCS) and the County of Fresno (County) is to permit the County to voluntarily participate in the
Medi-Cal County Inmate Program (MCIP).
ARTICLE 11 - AUTHORITY
This PA is authorized by Welfare and Institutions Code sections 14053.7, 14053.8, and Penal Code
section 5072.
ARTICLE III — TERM AND TERMINATION OF THE AGREEMENT
1. This PA is effective on July 1, 2020 (date).
2. This PA will rernain in effect until terminated by either party pursuant to and in accordance with
the requirements and conditions set forth in this PA.
3. Termination Without Cause:
Either party may terminate this PA without cause, and terminate the participation of the County
in MCIP by issuing at least a 30 day prior written notification to the other party of the intent to
terminate. Notice of termination shall result in the County's immediate withdrawal from MCIP
on the termination date and exclusion from further participation in MCIP unless and until such
time as the County's participation is reinstated by DHCS in MCIP. The County shall remain
obligated to pay for the non-federal share of all MCIP services provided to the County.
4. Termination With Cause:
If the County fails to comply with any of the terms of this PA, DHCS may terminate this PA for
cause effective immediately by providing written notice to the County's representative listed
below. Furthermore, DHCS may terminate this PA for cause if DHCS determines that the
County does not meet the requirements for participation in MCIP, the County has not
submitted a valid reimbursement claim, or that the County is unable to certify that the claims
are eligible for federal funds. Termination for cause will result in the County's immediate
withdrawal and exclusion from further participation in the MCIP.
[Page 1 of 9] DHCS 07/01/2020
Medi-Cal County Inmate Program Participation Agreement 20-MCIP FRESNO-10
County: Fresno
The conviction of an employee, subcontractor, or authorized agent of the County, or of an
employee or authorized agent of a subcontractor, of any felony or of a misdemeanor involving
fraud, abuse of any Medi-Cal applicant or beneficiary, or abuse of the Medi-Cal Program, shall
result in the exclusion of that employee, agent, or subcontractor, or employee or agent of a
subcontractor, from participation in MCIP. Failure of the County to exclude a convicted
individual from participation in MCIP shall constitute a breach of this agreement for which
DHCS may terminate this PA.
DHCS may terminate this PA in the event that DHCS determines that the County, or any
employee or contractor working with the County has violated the laws, regulations or rules
governing MCIP.
In cases where DHCS determines in its sole discretion that the health and welfare of Medi-Cal
beneficiaries or the public is jeopardized by continuation of this PA, this PA shall be terminated
effective the date that DHCS made such determination. After termination of the PA, any
overpayment must be returned to DHCS pursuant to Welfare and Institutions Code sections
14176 and 14177.
Finally, this PA will terminate automatically upon the termination of the County's MCIP
Administrative Service Agreement.
ARTICLE IV — PROJECT REPRESENTATIVES
David Pomaville
Director, Department of Public Health
P.O. Box 11867
Fresno, CA 93775
Telephone: (559) 600-6439
E-Mail: dpomaville@fresnocounty.ca.gov
Captain Stephen McComas
Jail Programs and Services Bureau
1125 M. Street
Fresno, CA 93721
Shelly Taunk, Chief
County-Based Claiming and Inmate Services Section
Telephone: (916) 345-7934
Fax: (916) 324-0738
E-Mail: Shelly.Taunk@dhcs.ca.gov
Direct all inquiries and notices to:
Inmates Medi-Cal Claiming Unit
Local Governmental Financing Division
1501 Capitol Ave., MS 4603
P.O. Box 997436
[Page 2 of 9] DHCS 07/01/2020
Medi-Cal County Inmate Program Participation Agreement 20-MCIP FRESNO-10
County: Fresno
Sacramento, CA 95899-7436
Telephone: (916) 345-7895
E-Mail- DHCSIMCURdhcs.ca.gov
Any notice, request, demand or other communication required or permitted hereunder, shall be
deemed to be properly given when delivered to the project representatives identified above.
ARTICLE V — PAYMENT TERMS AND INVOICING
1. The County shall compensate DHCS for the County's apportioned share of the nonfederal
share of MCIP services listed in Article VII, as required by Welfare and Institutions Code
sections 14053.7 and 14053.8, Government Code sections 26605.6, 26605.7, and
26605.8, and Penal Code 5072 within 60 days of receipt of an invoice from DHCS, which
specifies both the total federally claimable cost and the nonfederal share of the total cost,
for payments DHCS has made to providers. The DHCS invoice shall not contain and the
County shall not compensate DHCS for MCIP services provided by Medi-Cal providers
where the County incurs the cost of providing MCIP services and claims them through the
CPE process as outlined specifically for Designated Public Hospitals (DPHs). The County
shall not reimburse DHCS for the nonfederal share of services as Certified Public
Expenditures (CPEs) of DPHs.
2. DHCS shall submit to the County a quarterly invoice for MCIP services that identifies the
nonfederal share amount, and a report that contains information regarding paid claims data
for the quarter, including information identifying the provider of services and the beneficiary,
the recipient aid code, and arnount of reimbursement, and other information that may be
agreed to between the parties.
If after comparing its owed nonfederal share to payments actually made, the County has
overpaid DHCS, and the amount is undisputed DHCS shall refund the overpayment to the
County within 180 days of receipt of an invoice containing the same information from the
County. This refund may be made by offsetting the amount against the County's next
quarterly payment due to DHCS.
3. DPHs, in MCIP participating counties may submit claims and follow the CPE process which
includes a pricing methodology established on an annual basis. These DPHs are paid
using Federal Financial Participation (FFP) only.
ARTICLE VI — COUNTY RESPONSIBILITIES
1. Except as provided in subdivision (f.) of this section, the County is responsible for
reimbursing DHCS for the nonfederal share of MCIP services paid by DHCS.
a. The County may pay a Medi-Cal provider to the extent required by or otherwise
permitted by state and federal law to arrange for services for Medi-Cal beneficiaries.
Such additional amounts shall be paid entirely with county funds, and shall not be
eligible for Social Security Act Title XIX FFP.
[Page 3 of 9] DHCS 07/01/2020
Medi-Cal County Inmate Program Participation Agreement 20-MCIP FRESNO-10
County: Fresno
b. If DHCS pays the Medi-Cal provider more than what the County would have paid for
services rendered, the County cannot request and receive the difference from the Medi-
Cal provider.
c. If the County would have paid the Medi-Cal provider less than what DHCS paid the
Medi-Cal provider, the County is still obligated to reimburse DHCS for the nonfederal
share of DHCS' payment for the MCIP services.
d. In the event that FFP is not available for any MCIP service clairned pursuant to this PA,
the County shall be solely responsible for arranging and paying for the MCIP service.
e. If the Centers for Medicare & Medicaid Services (CMS) determines an overpayment has
occurred including the application of any federal payment limit that reduces the amount
of FFP available then DHCS shall seek the overpayment amount from the provider,
return the collected FFP to CMS, and return the collected nonfederal share to the
County. In the event that DHCS cannot recover the overpayment from the Medi-Cal
provider, the County shall pay DHCS an amount equal to the FFP portion of the
unrecovered amount to the extent that Section 1903(d)(2)(D) of the Social Security Act
is found not to apply.
f. The County is not responsible for reimbursing DHCS for the nonfederal share of
expenditures for MCIP services provided by DPHs when those services are reimbursed
under the CPE process because DHCS is not responsible for the nonfederal share of
expenditures for MCIP services reimbursed in the CPE process.
2. If CMS determines DHCS claimed a higher Federal Medical Assistance Percentage
(FMAP) rate than is allowed and FFP is reduced by CMS then the County shall hold DHCS
harmless for the return of the FFP to CMS.
3. Upon the County's compliance with all applicable provisions in this PA and applicable laws,
the County may send its MCIP-eligible beneficiaries to Medi-Cal providers to receive MCIP
services.
4. The County understands and agrees that the overall nature of the medical facilities in which
an inmate receives medical services must be one of community interaction such that
members of the general public may be admitted to receive services and admission into the
medical facility or into specific beds within the facility is not limited to individuals under the
responsibility of a correctional facility, and that inmates are admitted to specific medical
units based not on their statutes as inmates of a correctional institution, but rather on their
treatment needs and plan of care.
5. Ensure that an appropriate audit trail exists within records and accounting system and
maintain expenditure data as indicated in this PA.
6. The County agrees to provide to DHCS or any federal or state department with monitoring
or reviewing authority, access and the right to examine its applicable records and
[Page 4 of 9] DFICS 07/01/2020
Medi-Cal County Inmate Program Participation Agreement 20-MCIP FRESN®-10
County: Fresno
documents for compliance with relevant federal and state statutes, rules and regulations,
and this PA.
7. In the event of any federal deferral or disallowance applicable to MCIP expenditures, the
County shall provide all documents requested by DHCS within 14 days.
8. The County shall assist with the completion and delivery of completed Medi-Cal
applications to the County Welfare Department within 90 days after the date of admission
of the beneficiary to a Medi-Cal provider off of the grounds of the County correctional
facility resulting in an expected stay of more than 24 hours.
9. As a condition of participation in MCIP, and in recognition of revenue generated by MCIP,
the County shall pay quarterly administrative costs directly to DHCS.
a. The quarterly administrative costs payment shall be used to cover DHCS' administrative
costs associated with MCIP, including, but not limited to, claims processing, technical
assistance, and monitoring. DHCS shall determine and report staffing requirements
upon which projected costs will be based.
b. The amount of the administrative costs shall be based upon the anticipated state
salaries, benefits, operating expenses, and equipment necessary to administer MCIP
and other costs related to that process.
c. The County shall enter in to a separate agreement with DHCS to reimburse DHCS for
the administrative costs of administering MCIP.
ARTICLE VII — DHCS RESPONSIBILITIES
1. DHCS shall pay the appropriate Medi-Cal fee-for-service rate to Medi-Cal providers that
directly bill DHCS for MCIP services rendered to the County's MCIP eligible beneficiaries
and seek FFP for these service claims. DHCS shall be responsible to pay such Medi-Cal
providers only to the extent the County commits to reimburse DHCS for the nonfederal
share of all federally reimbursable MCIP claims and for which FFP is available and
obtained by DHCS for the MCIP service claims.
2. DHCS shall maintain accounting records to a level of detail which identifies the actual
expenditures incurred for MCIP services, -the services provided, the county responsible, the
specific MCIP-eligible beneficiary treated, the MCIP-eligible beneficiaries aid code, and the
specific provider billing.
3. DHCS shall submit claims in a timely manner to CMS to draw down FFP and shall
distribute FFP for all eligible claims.
4. DHCS shall:
a. Ensure that an appropriate audit trail exists within records and accounting system and
maintain expenditure data as indicated in this PA.
[Page 5 of 91 DHCS 07/01/2020
Medi-Cal County Inmate Program Participation Agmen-tent nt 20-MCIP FRESNO-10
County: F Fresno
b. Designate a person to act as liaison with the County concerning issues arising under
this PA. This person shall be identified to the County's contact person for this PA.
c. Provide a written response by email or mail to the County's contact person within 30
days of receiving a written request for information related to MCIP.
d. With each quarterly administrative cost invoice, provide a paid claim analysis report to
the County regarding MCIP claims submitted by providers for the County's MCIP-
eligible beneficiaries. This analysis shall be used to determine the arnount of the non-
federal share that the County is obligated to pay under this PA.
5. Should the services to be performed under this PA conflict with DHCS' responsibilities under
federal Medicaid law, those responsibilities shall take precedence.
6. DHCS' cessation of any activities due to federal Medicaid responsibilities does not
relinquish the obligation of the County to reimburse DHCS for MCIP services incurred by
DHCS in connection with this PA for periods in which the County participated in MCIP.
7. DHCS agrees to provide to the County, or any federal or state department with monitoring
or reviewing authority, access and the right to examine its applicable records and
documents for compliance with relevant federal and state statutes, rules and regulations,
and this PA.
ARTICLE Vill — FISCAL PROVISIONS
1. DHCS will invoice the County quarterly at the address above. Each invoice shall include the
agreement number and supporting documentation for the previous quarter's paid claims.
2. Counties are required to sign and submit the MCIP Certification and Hold Harmless by an
authorized county representative to DHCS annually to ensure the County is providing
efficient oversight of federal expenditures.
ARTICLE IX — BUDGET CONTIGENCY CLAUSE
1. It is mutually agreed that if the State Budget Act of the current State Fiscal Year (SFY) and
any subsequent SFYs covered under this PA does not provide sufficient funds for MCIP,
this PA shall be of no further force and effect. In this event, the DHCS shall have no liability
to pay any funds whatsoever to the County or to furnish any other considerations under the
PA and the County shall not be obligated to perform any provisions of this PA.
2. If funding for any SFY is reduced or deleted by the State Budget Act for purposes of MCIP,
DHCS shall have the option to either cancel this PA, with no liability occurring to DHCS, or
offer an agreement amendment to the County to reflect the reduced arnount.
ARTICLE X — LIMITATION OF STATE LIABILITY
[Page 6 of 91 DHCS 07/01/2020
kge,di-Cal County Inmate Program Participation Agreement 20-MCIP FRE—SNO-10
County: Fresno
1. In the event of a federal audit disallowance, the County shall cooperate with DHCS in
replying to and complying with any federal audit exception related to MCIP. The County
shall assume sole financial responsibility for any and all federal audit disallowances related
to the rendering of services under this PA. The County shall assume sole financial
responsibility for any and all penalties and interest charged as a result of a federal audit
disallowance related to the rendering of services under this PA. The amount of the federal
audit disallowance, plus interest and penalties shall be payable on demand from DHCS.
2. To the extent that a federal audit disallowance and interest results from a claim or claims
for which the Medi-Cal provider has received reimbursement for MCIP services under this
PA, DHCS shall recoup from the Medi-Cal provider, upon written notice of 60 days after the
completion of an audit or other examination that results in the discovery of an overpayment
per Welfare and Institutions Code section14-172.5), amounts equal to the amount of the
disallowance and interest in that state fiscal year for the disallowed claim, less the amounts
already remitted to or recovered by DHCS.
ARTICLE XI —AMENDMENT
1. This PA and any exhibits attached hereto, along with the MCIP Administrative Agreement
shall constitute the entire agreement among the parties regarding MCIP and supersedes
any prior or contemporaneous understanding or agreement with respect to MCIP and may
be amended only by a written amendment to this PA.
2. Changes to the project representatives may be made via written communication including
email by either party and shall not constitute a formal amendment to the PA.
ARTICLE XII — GENERAL PROVISIONS
1. None of the provisions of this PA are or shall be construed as for the benefit of, or
enforceable by any person not a party to this PA.
2. The interpretation and performance of this PA shall be governed by the State of California.
The venue shall lie only in counties in which the California Attorney General maintains an
office.
DHCS and the County shall maintain and preserve all records relating to this PA for a
period of three years from DHCS' receipt of the last payment of UP or until three years
after all audit findings are resolved, whichever is later. This does not limit any
responsibilities held by DHCS or the County provided for elsewhere in this PA, or in state or
federal law.
ARTICLE XIII — INDEMNIFICATION
It is agreed that the County shall defend, hold harmless, and indemnify DHCS, its officers,
employees, and agents from any and all claims liability, loss or expense (including reasonable
attorney fees) for injuries or damage to any person or property which arise out of the terms and
[Page 7 of 91 DHCS 07/01/2020
Medi-Cal County Inmate Pvofjcarm Participation Agreement 20-MCIP FRESNO-10
County: Fresno
conditions of this PA and the negligent and intentional acts or omissions of the County, its officers,
employees, or agents.
ARTICLE XIV — AVOIDANCE OF CONFLICTS OF INTEREST
The County is subject to compliance with the Medi-Cal Conflict of Interest Law, as applicable and set
forth in Welfare and Institutions Code section 14022, and Article 1.1 (commencing with Welfare and
Institutions Code section 14047), and implemented pursuant to 22 California Code of Regulations,
section 51466.
ARTICLE XV — CONFIDENTIALITY
The County shall comply with the applicable confidentiality requirements as specified in Section
1902(a)(7) of the Social Security Act; 42 Code of Federal Regulations, part 431.300; Welfare and
Institutions Code section 14100.2; and 22 California Code of Regulations, section 51009; and, the
Business Associates Agreement hereby incorporated by reference.
THIS SPACE INTENTIONALLY LEFT BLANK
[Page 8 of 91 DFICS 07/01/2020
Medi-Cal County Inmate Program Participation Agreement 20-MCIP FRESNO-10
County: Fresno
The signatories to this PA warrant that they have full and binding authority to the cornrnitrnents
contained herein on behalf of their respective entities.
County Name: County of Fresno
Ernest Buddy Mendes
Name of Authorized Representative
(Person legally authorized to bind contracts for the County)
Chairman of the Board of Supervisors of the Countjr of Fresno
Title of Authorized Representative
Signature of Authorized
Representative ATTEST:
BERNICE E.SEIDEL
Clerk of the Board of Supervisors
Owl
r7 _ �O `1 o County of Fresno,State of California
Date I By �,Z , Deputy
STATE OF CALIFORNIA — DEPARTMENT OF HEALTH CARE SERVICES
Signature of the DHCS Authorized Representative
Typed or Printed NamOof the DHCS Authorized Representative
A V-1-J to V—
Typed or Printed Title of the DHCS Authorized Representative
Date
[Page 9 of 9] DHCS 07!01/2020
County of Fresno
20-MCIPFRESNO-10
Page 1 of 6
Exhibit X
Business Associate Addendum
1. This Agreement has been determined to constitute a business associate relationship under the Health
Insurance Portability and Accountability Act (HIPAA) and its implementing privacy and security regulations
at 45 Code of Federal Regulations, Parts 160 and 164 (collectively, and as used in this Agreement)
2. The term "Agreement" as used in this document refers to and includes both this Business Associate
Addendum and the contract to which this Business Associate Agreement is attached as an exhibit, if any.
3. For purposes of this Agreement, the term "Business Associate" shall have the same meaning as set forth in
45 CFR section 160.103.
4. The Department of Health Care Services (DHCS) intends that Business Associate may create, receive,
maintain, transmit or aggregate certain information pursuant to the terms of this Agreement, some of which
information may constitute Protected Health Information (PHI) and/or confidential information protected by
Federal and/or state laws.
4.1 As used in this Agreement and unless otherwise stated, the term "PHI" refers to and includes both "PHI"
as defined at 45 CFR section 160.103 and Personal Information (PI) as defined in the Information
Practices Act at California Civil Code section 1798.3(a). PHI includes information in any form, including
paper, oral, and electronic.
4.2 As used in this Agreement, the term "confidential information" refers to information not otherwise defined
as PHI in Section 4.1 of this Agreement, but to which state and/or federal privacy and/or security
protections apply.
5. Contractor (however named elsewhere in this Agreement) is the Business Associate of DHCS acting on
DHCS's behalf and provides services or arranges, performs or assists in the performance of functions or
activities on behalf of DHCS, and may create, receive, maintain, transmit, aggregate, use or disclose PHI
(collectively, "use or disclose PHI") in order to fulfill Business Associate's obligations under this Agreement.
DHCS and Business Associate are each a party to this Agreement and are collectively referred to as the
"parties."
6. The terms used in this Agreement, but not otherwise defined, shall have the same meanings as those terms
in HIPAA. Any reference to statutory or regulatory language shall be to such language as in effect or as
amended.
7. Permitted Uses and Disclosures of PHI by Business Associate. Except as otherwise indicated in this
Agreement, Business Associate may use or disclose PHI only to perform functions, activities or services
specified in this Agreement on behalf of DHCS, provided that such use or disclosure would not violate HIPAA
if done by DHCS.
7.1 Specific Use and Disclosure Provisions. Except as otherwise indicated in this Agreement, Business
Associate may use and disclose PHI if necessary for the proper management and administration of the
Business Associate or to carry out the legal responsibilities of the Business Associate. Business
Associate may disclose PHI for this purpose if the disclosure is required by law, or the Business
Associate obtains reasonable assurances from the person to whom the information is disclosed that it
will be held confidentially and used or further disclosed only as required by law or for the purposes for
which it was disclosed to the person, and the person notifies the Business Associate of any instances
of which it is aware that the confidentiality of the information has been breached.
8. Compliance with Other Applicable Law
DHCS HIPAA BAA 11/19/19
County of Fresno
20-MCIPFRESNO-10
Page 2 of 6
8.1 To the extent that other state and/or federal laws provide additional, stricter and/or more protective
(collectively, more protective) privacy and/or security protections to PI-II or other confidential information
covered under this Agreement beyond those provided through HIPAA, Business Associate agrees:
8.1.1 To comply with the more protective of the privacy and security standards set forth in applicable state
or federal laws to the extent such standards provide a greater degree of protection and security than
HIPAA or are otherwise more favorable to the individuals whose information is concerned; and
8.1.2 To treat any violation of such additional and/or more protective standards as a breach or security
incident, as appropriate, pursuant to Section 18. of this Agreement.
8.2 Examples of laws that provide additional and/or stricter privacy protections to certain types of PHI
and/or confidential information, as defined in Section 4. of this Agreement, include, but are not limited
to the Information Practices Act, California Civil Code sections 1798-1798.78, Confidentiality of
Alcohol and Drug Abuse Patient Records, 42 CFR Part 2, Welfare and Institutions Code section 5328,
and California Health and Safety Code section 11845.5.
8.3 If Business Associate is a Qualified Service Organization (QSO) as defined in 42 CFR section 2.11,
Business Associate agrees to be bound by and comply with subdivisions (2)(i) and (2)(ii) under the
definition of QSO in 42 CFR section 2.11.
9. Additional Responsibilities of Business Associate
9.1 Nondisclosure. Business Associate shall not use or disclose PHI or other confidential information other
than as permitted or required by this Agreement or as required by law.
9.2 Safeguards and Security.
9.2.1 Business Associate shall use safeguards that reasonably and appropriately protect the
confidentiality, integrity, and availability of PHI and other confidential data and comply, where
applicable, with subpart C of 45 CFR Part 164 with respect to electronic protected health
information, to prevent use or disclosure of the information other than as provided for by this
Agreement. Such safeguards shall be, at a minimum, at Federal Information Processing
Standards (FIPS) Publication 199 protection levels.
9.2.2 Business Associate shall, at a minimum, utilize an industry-recognized security framework when
selecting and implementing its security controls, and shall maintain continuous compliance with
its selected framework as it may be updated from time to time. Examples of industry-recognized
security frameworks include but are not limited to
9.2.2.1 NISI SP 800-53 — National Institute of Standards and Technology Special Publication
800-53
9.2.2.2 FedRAMP — Federal Risk and Authorization Management Program
9.2.2.3 PCI — PCI Security Standards Council
9.2.2.4 ISO/ESC 27002 — International Organization for Standardization / International
Electrotechnical Commission standard 27002
9.2.2.5 IRS PUB 1075 — Internal Revenue Service Publication 1075
9.2.2.6 HITRUST CSF — HITRUST Common Security Framework
9.2.3 Business Associate shall maintain, at a minimum, industry standards for transmission and storage
of PHI and other confidential information.
DHCS HIPAA BAA 11/19/19
County of Fresno
20-MCIPFRESNO-10
Page 3 of 6
9.2.4 Business Associate shall apply security patches and upgrades, and keep virus software up-to-
date, on all systems on which PHI and other confidential information may be used.
9.2.5 Business Associate shall ensure that all members of its workforce with access to PHI and/or
other confidential information sign a confidentiality statement prior to access to such data. The
statement must be renewed annually.
9.2.6 Business Associate shall identify the security official who is responsible for the development and
implementation of the policies and procedures required by 45 CFR Part 164, Subpart C.
9.3 Business Associate's Agent. Business Associate shall ensure that any agents, subcontractors,
subawardees, vendors or others (collectively, "agents") that use or disclose PHI and/or confidential
information on behalf of Business Associate agree to the same restrictions and conditions that apply to
Business Associate with respect to such PHI and/or confidential information.
10. Mitigation of Harmful Effects. Business Associate shall mitigate, to the extent practicable, any harmful
effect that is known to Business Associate of a use or disclosure of PHI and other confidential information in
violation of the requirements of this Agreement.
11. Access to PHI. Business Associate shall make PHI available in accordance with 45 CFR section 164.524.
12. Amendment of PHI. Business Associate shall make PHI available for amendment and incorporate any
amendments to protected health information in accordance with 45 CFR section 164.526.
13. Accounting for Disclosures. Business Associate shall make available the information required to provide
an accounting of disclosures in accordance with 45 CFR section 164.528.
14. Compliance with DHCS Obligations. To the extent Business Associate is to carry out an obligation of
DHCS under 45 CFR Part 164, Subpart E, comply with the requirements of the subpart that apply to DHCS
in the performance of such obligation.
15. Access to Practices, Books and Records. Business Associate shall make its internal practices, books,
and records relating to the use and disclosure of PHI on behalf of DHCS available to DHCS upon reasonable
request, and to the federal Secretary of Health and Human Services for purposes of determining DHCS'
compliance with 45 CFR Part 164, Subpart E.
16. Return or Destroy PHI on Termination; Survival. At termination of this Agreement, if feasible, Business
Associate shall return or destroy all PHI and other confidential information received from, or created or
received by Business Associate on behalf of, DHCS that Business Associate still maintains in any form and
retain no copies of such information. If return or destruction is not feasible, Business Associate shall notify
DHCS of the conditions that make the return or destruction infeasible, and DHCS and Business Associate
shall determine the terms and conditions under which Business Associate may retain the PHI. If such return
or destruction is not feasible, Business Associate shall extend the protections of this Agreement to the
information and limit further uses and disclosures to those purposes that make the return or destruction of
the information infeasible.
17. Special Provision for SSA Data. If Business Associate receives data from or on behalf of DHCS that was
verified by or provided by the Social Security Administration (SSA data) and is subject to an agreement
between DHCS and SSA, Business Associate shall provide, upon request by DHCS, a list of all employees
and agents and employees who have access to such data, including employees and agents of its agents, to
DHCS.
18. Breaches and Security Incidents. Business Associate shall implement reasonable systems for the
discovery and prompt reporting of any breach or security incident, and take the following steps:
18.1 Notice to DHCS.
DHCS HIPAA BAA 11/19/19
County of Fresno
20-MCIPFRESNO-10
Page 4 of 6
18.1.1 Business Associate shall notify DHCS immediately upon the discovery of a suspected breach
or security incident that involves SSA data. This notification will be provided by email upon
discovery of the breach. If Business Associate is unable to provide notification by email, then
Business Associate shall provide notice by telephone to DHCS.
18.1.2 Business Associate shall notify DHCS within 24 hours by email (or by telephone if Business
Associate is unable to email DHCS) of the discovery of:
18.1.2.1 Unsecured PHI if the PHI is reasonably believed to have been accessed or acquired
by an unauthorized person;
18.1.2.2 Any suspected security incident which risks unauthorized access to PHI and/or other
confidential information;
18.1.2.3 Any intrusion or unauthorized access, use or disclosure of PHI in violation of this
Agreement; or
18.1.2.4 Potential loss of confidential data affecting this Agreement.
18.1.3 Notice shall be provided to the DHCS Program Contract Manager (as applicable), the DHCS
Privacy Office, and the DHCS Information Security Office (collectively, "DHCS Contacts")
using the DHCS Contact Information at Section 18.6. below.
Notice shall be made using the current DHCS "Privacy Incident Reporting Form" ("PIR Form";
the initial notice of a security incident or breach that is submitted is referred to as an "Initial
PIR Form") and shall include all information known at the time the incident is reported. The
form is available online at
http://www.dhcs.ca.gov/formsandpubs/laws/priv/Pages/DHCSBusinessAssociatesOnIV.aspx.
Upon discovery of a breach or suspected security incident, intrusion or unauthorized access,
use or disclosure of PHI, Business Associate shall take:
18.1.3.1 Prompt action to mitigate any risks or damages involved with the security incident or
breach; and
18.1.3.2 Any action pertaining to such unauthorized disclosure required by applicable Federal
and State law.
18.2 Investigation. Business Associate shall immediately investigate such security incident or confidential
breach.
18.3 Complete Deport. To provide a complete report of the investigation to the DHCS contacts within ten
(10) working days of the discovery of the security incident or breach. This "Final PIR" must include
any applicable additional information not included in the Initial Form. The Final PIR Form shall include
an assessment of all known factors relevant to a determination of whether a breach occurred under
HIPAA and other applicable federal and state laws. The report shall also include a full, detailed
corrective action plan, including its implementation date and information on mitigation measures
taken to halt and/or contain the improper use or disclosure. If DHCS requests information in addition
to that requested through the PIR form, Business Associate shall make reasonable efforts to provide
DHCS with such information. A "Supplemental PIR" may be used to submit revised or additional
information after the Final PIR is submitted. DHCS will review and approve or disapprove Business
Associate's determination of whether a breach occurred, whether the security incident or breach is
reportable to the appropriate entities, if individual notifications are required, and Business Associate's
corrective action plan.
DHCS HIPAA BAA 11/19/19
County of Fresno
20-MCIPFRESNO-10
Page 5 of 6
18.3.1 If Business Associate does not complete a Final PIR within the ten (10) working day
timeframe, Business Associate shall request approval frorn DHCS within the ten (10) working
day timeframe of a new submission timeframe for the Final PIR.
18.4 Notification of Individuals. If the cause of a breach is attributable to Business Associate or its
agents, Business Associate shall notify individuals accordingly and shall pay all costs of such
notifications, as well as all costs associated with the breach. The notifications shall comply with
applicable federal and state law. DHCS shall approve the time, manner and content of any such
notifications and their review and approval must be obtained before the notifications are made.
18.5 Responsibility for Reporting of Breaches to Entities Other than DHCS. If the cause of a breach
of PHI is attributable to Business Associate or its subcontractors, Business Associate is responsible
for all required reporting of the breach as required by applicable federal and state law.
18.6 DHCS Contact Information. To direct communications to the above referenced DHCS staff, the
Contractor shall initiate contact as indicated here. DHCS reserves the right to make changes to the
contact information below by giving written notice to Business Associate. These changes shall not
require an amendment to this Agreement.
DHCS Program DHCS Privacy Office DHCS Information Security Office
Contract Manager
See the Scope of Work Privacy Office Information Security Office
exhibit for Program c/o: Office of HIPAA Compliance DHCS Information Security Office
Contract Manager Department of Health Care Services P.O. Box 997413, MS 6400
information. If this P.O. Box 997413, MS 4722 Sacramento, CA 95899-7413
Business Associate Sacramento, CA 95899-7413
Agreement is not Email: incidents@dhcs.ca.Qov
attached as an exhibit to Email: incidents(d,dhcs.ca.gov
a contract, contact the
DHCS signatory to this Telephone: (916)445-4646
Agreement.
19. Responsibility of DHCS. DHCS agrees to not request the Business Associate to use or disclose PHI in
any manner that would not be permissible under HIPAA and/or other applicable federal and/or state law.
20.Audits, Inspection and Enforcement
20.1 From time to time, DHCS may inspect the facilities, systems, books and records of Business Associate
to monitor compliance with this Agreement. Business Associate shall promptly remedy any violation
of this Agreement and shall certify the same to the DHCS Privacy Officer in writing. Whether or how
DHCS exercises this provision shall not in any respect relieve Business Associate of its responsibility
to comply with this Agreement.
20.2 If Business Associate is the subject of an audit, compliance review, investigation or any proceeding
that is related to the performance of its obligations pursuant to this Agreement, or is the subject of any
judicial or administrative proceeding alleging a violation of HIPAA, Business Associate shall promptly
notify DHCS unless it is legally prohibited from doing so.
21. Termination
21.1 Termination for Cause. Upon DHCS' knowledge of a violation of this Agreement by Business
Associate, DHCS may in its discretion:
21.1.1 Provide an opportunity for Business Associate to cure the violation and terminate this
Agreement if Business Associate does not do so within the tirne specified by DHCS; or
DHCS HIPAA BAA 11/19/19
County of Fresno
20-MCIPFRESNO-'10
Page 6 of 6
21.1.2 Terminate this Agreement if Business Associate has violated a material term of this
Agreement.
21.2 Judicial or Administrative Proceedings. DHCS may terminate this Agreement if Business
Associate is found to have violated HIPAA, or stipulates or consents to any such conclusion, in any
judicial or administrative proceeding.
22. Miscellaneous Provisions
22.1 Disclaimer. DHCS makes no warranty or representation that compliance by Business Associate with
this Agreement will satisfy Business Associate's business needs or compliance obligations. Business
Associate is solely responsible for all decisions made by Business Associate regarding -the
safeguarding of PHI and other confidential information.
22.2. Amendment.
22.2.1 Any provision of this Agreement which is in conflict with current or future applicable Federal or
State laws is hereby amended to conform to the provisions of those laws. Such amendment of
this Agreement shall be effective on the effective date of the laws necessitating it, and shall be
binding on the parties even though such amendment may not have been reduced to writing and
formally agreed upon and executed by the parties.
22.2.2 Failure by Business Associate to take necessary actions required by amendments to this
Agreement under Section 22.2.1 shall constitute a material violation of this Agreement.
22.3 Assistance in Litigation or Administrative Proceedings. Business Associate shall make itself and
its employees and agents available to DHCS at no cost to DHCS to testify as witnesses, or otherwise,
in the event of litigation or administrative proceedings being commenced against DHCS, its directors,
officers and/or employees based upon claimed violation of HIPAA, which involve inactions or actions
by the Business Associate.
22.4 No Third-Party Beneficiaries. Nothing in this Agreement is intended to or shall confer, upon any
third person any rights or remedies whatsoever.
22.5 Interpretation. The terms and conditions in this Agreement shall be interpreted as broadly as
necessary to implement and comply with HIPAA and other applicable laws.
22.6 No Waiver of Obligations. No change, waiver or discharge of any liability or obligation hereunder
on any one or more occasions shall be deemed a waiver of performance of any continuing or other
obligation, or shall prohibit enforcement of any obligation, on any other occasion.
DHCS HIPAA BAA 11/19/19
California Department of Health Care Services
Name/No.: Medi-Cal County Inmate Program (MCIP) Participation
Agreement (No. 20-MCIPFRESNO-10)
Fund/Subclass: 0001/10000
Organization #: 56201683
Revenue Account #: 7295
Est. $800,000 Annually