DPH compliance office reports $1.2 million in disallowed claims, highlights privacy incidents and training gains

Maggie Rakowski, chief integrity officer for the San Francisco Department of Public Health, reported to the Health Commission that the department returned $1.2 million in disallowed claims after external audits and has strengthened compliance and privacy procedures across its hospitals and clinics.

"Disallowances for that fiscal year...DPH returned $1,200,000 in disallowed claims as a result of external audits," Rakowski said, noting the amount reflected catch-up activity after regulators suspended audits during the COVID-19 emergency.

Rakowski described the OCPA's work in auditing billing and documentation, citing risk areas such as cataract coding, observation services and documentation for mental-health and substance-use services. She said 27 clinics had error rates above 5% in FY22-23 and that providers are required to complete corrective action plans when errors exceed thresholds.

On privacy, Rakowski provided counts of incidents and reportable breaches across DPH units: San Francisco General Hospital (ZSFG) logged 74 incidents, 11 reportable breaches; Laguna Honda had 45 incidents, 5 reportable breaches; behavioral health services had 31 incidents with 6 reportable; clinics showed 17 incidents with 7 reportable; community-based organization partners recorded 12 incidents with 4 reportable. She said no privacy-related fines were imposed in the fiscal year.

Rakowski also emphasized training and system controls. After requiring staff to complete an annual two-part privacy and compliance module and sign confidentiality and data-sharing documents, OCPA achieved roughly a 98% compliance rate for required training and has suspended system access for untrained accounts when necessary.

She described the department's whistleblower process: the controller's office referred 73 complaints to DPH during the period and OCPA investigated 10 complaints filed directly with the office, pursuing corrective action where substantiated.

Commissioners asked about the nature of errors in clinic audits (primarily documentation not supporting billing codes) and about the expansion of compliance audits into ambulatory and population-health clinics; Rakowski said those audits are underway and will appear in future reports.