9/9/25, 7:18 Pm MailGate Sc MailGate Sc

The Department of Health Care Services’ (DHCS’) Enhanced Care Management (ECM) benefit specifies the criteria plans must use to identify high-cost, high-need members eligible for ECM services. The Alliance generates lists of members using this criterion and provides lists of eligible members to contracted providers for outreach. While the Behavioral Health Department does not participate in ECM, SCC Health Services Agency clinic is an Alliance-contracted ECM provider and routinely receives lists of members meeting criteria for ECM.

DHCS’ No Wrong Door (NWD) approach to behavioral health services requires plans and counties to use common clinical criterion and a shared assessment tool, referred to as the Screening and Transition of Care Tools for Medi-Cal Mental Health Services, to determine whether members should be served by the specialty or non-specialty mental health system. The Alliance refers members needing Specialty Mental Health Services (SMHS) or substance use disorder (SUD) services to SCC and maintains a shared tracking list to ensure all referred members obtain services. The Alliance partners with SCC, and the four other county mental health plans in its service area, align on the assessment tool, and manage the process to connect members to the correct delivery system.

Clinical: Santa Cruz County does not have a Level of Care Tool to track and manage High-Cost Beneficiaries. The Central California Alliance for Health does have a Level of Care Tool to track and manage High-Cost Beneficiaries. The parties are partners in the delivery of services and their resources could be leveraged to create a unified Level of Care tool. __ AGREE X PARTIALLY DISAGREE __ DISAGREE Response explanation (required for a response other than Agree): The Alliance utilizes available data to identify and track high-cost beneficiaries (HCBs) that would benefit from care management and other wraparound services to help them manage their conditions and navigate the healthcare system. The Alliance shares member-level data that identifies HCBs with Santa Cruz County (SCC), as follows. 1. The Department of Health Care Services’ (DHCS’) Enhanced Care Management (ECM) benefit specifies the criteria plans must use to identify high-cost, high-need members eligible for ECM services. The Alliance generates lists of members using this criterion and provides lists of eligible members to contracted providers for outreach. While the Behavioral Health Department does not participate in ECM, SCC Health Services Agency clinic is an Alliance-contracted ECM provider and routinely receives lists of members meeting criteria for ECM. 2. DHCS’ No Wrong Door (NWD) approach to behavioral health services requires plans and counties to use common clinical criterion and a shared assessment tool, referred to as the Screening and Transition of Care Tools for Medi-Cal Mental Health Services, to determine whether members should be served by the specialty or non-specialty mental health system. The Alliance refers members needing Specialty Mental Health Services (SMHS) or substance use disorder (SUD) services to SCC and maintains a shared tracking list to ensure all referred members obtain services. The Alliance partners with SCC, and the four other county mental health plans in its service area, align on the assessment tool, and manage the process to connect members to the correct delivery system. 3. Admit, discharge and transfer (ADT) data from local hospitals is shared with SCHIO and then with SCC to enable timely provider follow up with members, including follow up after hospitalization for substance use challenge (FUA) and follow up after hospitalization for mental health challenge (FUM). Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025 4. Lists of linked members with a high volume of ED visits are shared with contracted Primary Care Providers (PCPs), including SCC, to support PCP follow-up with members to ensure post-discharge care is received and coordinated. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025

Lists of linked members with a high volume of ED visits are shared with contracted Primary Care Providers (PCPs), including SCC, to support PCP follow-up with members to ensure post-discharge care is received and coordinated. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025 F5 . Data, Clinical & Administrative: The Central California Alliance for Health (Alliance) has substantial financial reserves, and Santa Cruz County has seats on the governing board of the Alliance. Clinical, financial and operational collaboration between these agencies, who are both insurers and providers, needs to be better coordinated and integrated at all levels to improve treatment and outcomes for all clients. __ AGREE __ PARTIALLY DISAGREE X DISAGREE Response explanation (required for a response other than Agree): The Alliance and SCC work collaboratively to meet the needs of our mutual members and meet routinely to coordinate care for individual members and to improve systems and processes that allow for collaboration and data sharing with the goal of improving health outcomes. There are legal and regulatory factors that limit the extent to which the Alliance and SCC can “integrate at all levels”. California law (§WIC 5600 and 14684) provides counties exclusive responsibility for providing specialty mental health services (SMHS). Additionally, California’s 1915(b) waiver “carves out” SMHS to county mental health plans. Integration would require statutory and regulatory changes as well as clarification of oversight authority and accountability. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025 Therefore, integration would require statutory and regulatory changes as well as clarification of oversight authority and accountability. In July 2025, DHCS released a Concept Paper titled, “DHCS Continuing The Transformation of Medi-Cal.” The purpose of this concept paper is to outline DHCS’ vision and goals for the next five years, including plans for advancing the renewal of the CalAIM waivers and other initiatives. The concept paper states, DHCS is committed to increasing efficiency in the managed care program and reducing fragmentation across delivery systems. Under CalAIM, DHCS considered a full integration proposal that would have allowed an MCP, in partnership with one or more BHPs (County Behavioral Health Plans), to apply to bring together physical, behavioral, and oral health benefits under a single entity contracted with DHCS. Due to operational complexities, DHCS did not launch any full integration pilots during the CalAIM waiver period and is considering streamlining the member experience and improving outcomes through more limited integration, such as piloting the integration of oral health benefits into managed care. Additionally, the Alliance is a regional agency with a five-county governing board. The Alliance is required by statute and regulation to have financial reserves to ensure the long-term financial viability of the organization, including providing uninterrupted services to its members, timely and adequate reimbursement to its providers, compliance with regulatory requirements, and ensuring organizational capacity to respond to short and long-term capital needs and opportunities consistent with the Alliance’s strategic plans. To that end, the board has set a reserve target and has allocated remaining reserves to support ongoing operational and strategic requirements including provider payments, implementing a Medicare Advantage (MA) Dual Eligible Special Needs Program (D-SNP) product as required by DHCS, and enhancing provider payments across the five-county service area. With recent federal budget cuts and policy changes affecting Medicaid funding, and a worsening state budget, the Alliance is experiencing a decline in financial reserves, and projects this decline will continue over the next four years. The Alliance is obligated to meet members’ needs and fulfill its contracts and obligations to its community, which covers five different counties. Additionally, Alliance reserves are to address obligations across all five counties, under the authority of the Alliance five- county governing Board. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025 F7 . Compassion: Throughout the Grand Jury investigation, the Jury found that the staff and leadership of the Health Services Agency, Santa Cruz County Sheriff’s Office, and the Central California Alliance for Health are compassionate in the treatment of people experiencing behavioral health or substance use disorder. Patients are treated with dignity and respect, despite sometimes difficult conditions. X AGREE __ PARTIALLY DISAGREE __ DISAGREE Response explanation (required for a response other than Agree): The Alliance agrees with this finding and appreciates the acknowledgement. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025

Data, Clinical & Administrative: The Central California Alliance for Health (Alliance) has substantial financial reserves, and Santa Cruz County has seats on the governing board of the Alliance. Clinical, financial and operational collaboration between these agencies, who are both insurers and providers, needs to be better coordinated and integrated at all levels to improve treatment and outcomes for all clients. __ AGREE __ PARTIALLY DISAGREE X DISAGREE Response explanation (required for a response other than Agree): The Alliance and SCC work collaboratively to meet the needs of our mutual members and meet routinely to coordinate care for individual members and to improve systems and processes that allow for collaboration and data sharing with the goal of improving health outcomes. There are legal and regulatory factors that limit the extent to which the Alliance and SCC can “integrate at all levels”. California law (§WIC 5600 and 14684) provides counties exclusive responsibility for providing specialty mental health services (SMHS). Additionally, California’s 1915(b) waiver “carves out” SMHS to county mental health plans. Integration would require statutory and regulatory changes as well as clarification of oversight authority and accountability. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025 Therefore, integration would require statutory and regulatory changes as well as clarification of oversight authority and accountability. In July 2025, DHCS released a Concept Paper titled, “DHCS Continuing The Transformation of Medi-Cal.” The purpose of this concept paper is to outline DHCS’ vision and goals for the next five years, including plans for advancing the renewal of the CalAIM waivers and other initiatives. The concept paper states, DHCS is committed to increasing efficiency in the managed care program and reducing fragmentation across delivery systems. Under CalAIM, DHCS considered a full integration proposal that would have allowed an MCP, in partnership with one or more BHPs (County Behavioral Health Plans), to apply to bring together physical, behavioral, and oral health benefits under a single entity contracted with DHCS. Due to operational complexities, DHCS did not launch any full integration pilots during the CalAIM waiver period and is considering streamlining the member experience and improving outcomes through more limited integration, such as piloting the integration of oral health benefits into managed care. Additionally, the Alliance is a regional agency with a five-county governing board. The Alliance is required by statute and regulation to have financial reserves to ensure the long-term financial viability of the organization, including providing uninterrupted services to its members, timely and adequate reimbursement to its providers, compliance with regulatory requirements, and ensuring organizational capacity to respond to short and long-term capital needs and opportunities consistent with the Alliance’s strategic plans. To that end, the board has set a reserve target and has allocated remaining reserves to support ongoing operational and strategic requirements including provider payments, implementing a Medicare Advantage (MA) Dual Eligible Special Needs Program (D-SNP) product as required by DHCS, and enhancing provider payments across the five-county service area. With recent federal budget cuts and policy changes affecting Medicaid funding, and a worsening state budget, the Alliance is experiencing a decline in financial reserves, and projects this decline will continue over the next four years. The Alliance is obligated to meet members’ needs and fulfill its contracts and obligations to its community, which covers five different counties. Additionally, Alliance reserves are to address obligations across all five counties, under the authority of the Alliance five- county governing Board. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025

Compassion: Throughout the Grand Jury investigation, the Jury found that the staff and leadership of the Health Services Agency, Santa Cruz County Sheriff’s Office, and the Central California Alliance for Health are compassionate in the treatment of people experiencing behavioral health or substance use disorder. Patients are treated with dignity and respect, despite sometimes difficult conditions. X AGREE __ PARTIALLY DISAGREE __ DISAGREE Response explanation (required for a response other than Agree): The Alliance agrees with this finding and appreciates the acknowledgement. Required Response from the Governing Board, Central California Alliance for Health High-Cost Beneficiaries Due by September 24, 2025