DPH compliance office reports fewer overpayments and ongoing audit work; privacy incidents steady
October 19, 2021 | San Francisco City, San Francisco County, California
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Margaret Rakowski, chief integrity/compliance officer for the Department of Public Health, presented the OCPA annual report to the Health Commission on Oct. 19.
Rakowski reviewed the compliance program's seven fundamental elements: leadership and governance, policies and procedures, open reporting channels, ongoing auditing and monitoring, training, internal investigations and corrective action. She described DPH's confidential toll-free hotline and email for reporting suspected violations and said all reported incidents receive investigation; substantiated issues trigger corrective-action plans and follow-up.
For fiscal year 202021, OCPA conducted 51 provider audits for behavioral health services; 36 providers had an error rate above 5%, with the principal error types tied to assessments, client plans and progress-note coding. Rakowski showed a trend of reduced overpayments and paybacks since fiscal-year 2017218 and described work to reduce repayments through auditing and corrective actions. She noted one financial penalty paid related to noncompliance with the California Department of Public Health state operations manual for long-term care (Laguna Honda) but said the office has reduced the number of disallowed claims overall.
On privacy and data sharing, Rakowski said FY2021 had no federal financial penalties related to privacy breaches; OCPA tracks incidents, reportable breaches and manages data-sharing agreements with vendors and city partners (including COVID-related data requests). The office reported 622 hotline calls across matters in FY2021 and 80 complaints investigated via the whistleblower process.
Rakowski described ongoing priorities: staffing to support audits and privacy work, operationalizing a privacy work plan and continuing staff training. Commissioners thanked the office for progress and asked no substantive follow-up during the meeting.
What's next: OCPA will continue audits, corrective-action oversight, privacy risk mitigation and report to the commission as necessary.
Rakowski reviewed the compliance program's seven fundamental elements: leadership and governance, policies and procedures, open reporting channels, ongoing auditing and monitoring, training, internal investigations and corrective action. She described DPH's confidential toll-free hotline and email for reporting suspected violations and said all reported incidents receive investigation; substantiated issues trigger corrective-action plans and follow-up.
For fiscal year 202021, OCPA conducted 51 provider audits for behavioral health services; 36 providers had an error rate above 5%, with the principal error types tied to assessments, client plans and progress-note coding. Rakowski showed a trend of reduced overpayments and paybacks since fiscal-year 2017218 and described work to reduce repayments through auditing and corrective actions. She noted one financial penalty paid related to noncompliance with the California Department of Public Health state operations manual for long-term care (Laguna Honda) but said the office has reduced the number of disallowed claims overall.
On privacy and data sharing, Rakowski said FY2021 had no federal financial penalties related to privacy breaches; OCPA tracks incidents, reportable breaches and manages data-sharing agreements with vendors and city partners (including COVID-related data requests). The office reported 622 hotline calls across matters in FY2021 and 80 complaints investigated via the whistleblower process.
Rakowski described ongoing priorities: staffing to support audits and privacy work, operationalizing a privacy work plan and continuing staff training. Commissioners thanked the office for progress and asked no substantive follow-up during the meeting.
What's next: OCPA will continue audits, corrective-action oversight, privacy risk mitigation and report to the commission as necessary.
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