Medical Services at the Lake County Jail

R1

That the Board of Supervisors direct the Health Services Director to establish a formal protocol for emergency access to critical medications through local pharmacies when Omnicare delivery is unavailable. (F1, F2, F8)

R2

That the Board of Supervisors direct the Health Services Director to amend the Wellpath contract to include telehealth for medication approvals when in- person staff are unavailable. (F1, F2)

R1

That the Board of Supervisors direct the Health Services Director to establish a formal protocol for emergency access to critical medications through local pharmacies when Omnicare delivery is unavailable. (F1, F2, F8)

R2

That the Board of Supervisors direct the Health Services Director to amend the Wellpath contract to include telehealth for medication approvals when in- person staff are unavailable. (F1, F2)

R3

That the Board of Supervisors direct the Health Services Director to negotiate the next Wellpath contract to add the psychiatric technician classification, or offer psychiatric technician training to existing LVN staff. (F3)

R4

That the Board of Supervisors compel the Health Services Director to report yearly the dollar value of unstaffed RN hours and associated reimbursements as required by contract. (F4, F5, F6, F7)

R5

That the Board of Supervisors establish penalties in future Wellpath contracts when the auditing of RN hours has not been completed on time. (F4, F5, F6, F7)

R6

The Board of Supervisors invoke a penalty for the current delay in processing audit of the RN hours. (F4, F5, F6, F7) Page | 275 2024-2025 Lake County Civil Grand Jury Final Report RESPONSES Under California Penal Code section 933.03 (a-c), the following responses are required: Lake County Board of Supervisors R-1, R-2, R-3, R-4, R-5, R-6 90 days The following response is requested: Director, Department of Health Services R-1, R-2, R-3, R-4 60 days Exhibits A and B and C Page | 276 2024-2025 Lake County Civil Grand Jury Final Report A. Letter from Regional Director of Wellpath, April 23, 2025 Lake County Grand Jury P.O. Box 1076 Lakeport, CA 95453 [sic] Subject: Response to Grand Jury Inquiry Regarding Reimbursement of RN Shift Differential Dear Members of the Lake County Grand Jury, I am writing on behalf of Wellpath, LLC in response to your inquiry regarding the reimbursement of funds owed to the County of Lake in relation to the staffing of the night shift Registered Nurse (RN) position at the Lake County Jail Medical Clinic. As background, Wellpath entered into a five-year agreement with the County of Lake effective January 1, 2023, to operate the jail’s medical clinic. In preparation for the January 1, 2024 contract renewal, Wellpath submitted a written proposal to amend the staffing language for the night shift RN position. Due to persistent recruitment challenges in filling RN roles, the proposal allowed Wellpath to staff this shift with a Licensed Vocational Nurse (LVN) if an RN was unavailable. As part of this agreement, Wellpath committed to reimburse the County the wage differential for each shift worked by an LVN in place of an RN. Additionally, the renewal proposal included a provision for an annual Consumer Price Index (CPI) increase to the total contract cost, to be effective January 1, 2024. On December 14, 2023, Wellpath received the County’s signed acceptance of the proposal from the County Administrative Officer. While the County viewed this letter as sufficient to proceed, Wellpath’s internal compliance and legal teams determined that a formal contract amendment was required for both the staffing adjustment and CPI increase to take effect. Accordingly, a draft amendment was submitted to the County. On April 10, 2024, the County Administrative Officer advised Wellpath that she would need to redraft the amendment into a format suitable for County Counsel review and eventual presentation to the Board of Supervisors. Wellpath has not received a finalized version since that date, and as a result, implementation of both the CPI increase and the LVN shift reimbursement calculations was delayed pending formal approval. Page | 277 2024-2025 Lake County Civil Grand Jury Final Report Despite this, in October 2024, Wellpath made the decision to proceed with invoicing for the CPI adjustment retroactive to January 1, 2024, and began reconciling the LVN shift data for the same period. That reconciliation is now underway, and Wellpath is committed to refunding or crediting the County for all applicable amounts where LVNs filled RN designated shifts, in alignment with our original proposal and the County’s accepted terms. We regret the delay in processing these refunds and acknowledge the importance of transparency and timely fiscal responsibility. The delay was rooted in a genuine effort to ensure proper legal and contractual compliance, and not in any intent to avoid reimbursement obligations. Wellpath is committed to maintaining a strong, accountable partnership with Lake County and will ensure that all reconciliations and refunds are completed promptly. A detailed accounting and credit summary will be provided to the County upon finalization. Thank you for the opportunity to clarify the matter. Please do not hesitate to reach out if further information is required. Respectfully, Regional Director of Operations Wellpath, LLC Page | 278 2024-2025 Lake County Civil Grand Jury Final Report B. Senator Elizabeth Warren's Oversight Letter https://www.warren.senate.gov/imo/media/doc/wellpath_bankruptcy_letter.pdf C. Text of article from Open Mind, May 14, 2025 Correctional Health Care Organization Wellpath Emerges From Chapter 11 Reorganization Wellpath, which provides correctional health care services, emerged from Chapter 11 bankruptcy and completed its financial restructuring. The bankruptcy filing was announced on November 11, 2024. The company sought to reduce about $550 million in debt. As part of the reorganization, Wellpath transitioned ownership to a group of its current and former lenders, referred to as the Ad Hoc Lender Group. On January 30, 2025, former Wellpath business line Recovery Solutions, which provides behavioral health services on behalf of public entities, completed a sale transaction that created an independent organization focused on behavioral health. A group of Wellpath’s creditors now owns Recovery Solutions. Financial terms were not disclosed. During the bankruptcy proceedings, Wellpath continued delivering services under its contracts. The company has a network of clinical professionals in 37 states who provide medical and mental health care services to over 200,000 people daily in more than 350 locations. The facilities include prisons, jails, state hospitals, forensic treatment facilities, civil commitment centers, and community-based services centers. Wellpath was advised in this matter by McDermott Will & Emery as legal counsel, Lazard and MTS Health Partners as investment bankers, and FTI Consulting as restructuring advisor. The Ad Hoc Lender Group was advised by Akin Gump Strauss Hauer & Feld LLP as legal counsel, Ankura Consulting Group, LLC, as financial advisor, and Houlihan Lokey Capital, Inc., as investment banker. This was reported by Wellpath on May 12, 2025. More information about Wellpath’s Chapter 11 cases, including the terms of the transactions consummated in connection with the Company’s emergence, is posted at https://dm.epiq11.com/case/wellpath/info (accessed May 14, 2025). Page | 279 2024-2025 Lake County Civil Grand Jury Final Report Bibliography 1. Welllpath website https://wellpathcare.com/about/ 2. HIG CAPITAL’S AND WELLPATH’S CORRECTIONAL HEALTHCARE INVESTMENT RISKS https://tinyurl.com/4psmpuh3 3. Lake County Sheriff's Office Custody Manual (pp. 368-469) - https:// tinyurl.com/55cyjhec 4. Contract including Exhibit B https://tinyurl.com/y5h9c69c 5. 1st Amendment to the CFMG contract https://tinyurl.com/3t8uf3hv 6. Compensation Agreement https://tinyurl.com/3rey9a94 7. Lake County Grand Jury Reports - 2012-2013 and 2021-2022 https:// www.lakecountyca.gov/ArchiveCenter 8. Sonoma county Grand Jury Final Report 2007-2008 (death of inmate) https:// sonoma.courts.ca.gov/system/files?file=2.pdf 9. COUNTY OF LAKE Community Corrections Partnership Plan 2020-2021 https://tinyurl.com/y2xyeh5c 10. Wellpath spins off behavioral health unit in bankruptcy sale https://tinyurl.com/465yphem 11. Prison health company Wellpath reaches $15.5 mln creditor settlement https://tinyurl.com/yvmd6ftv 12. A health care provider that faced dozens of prisoner lawsuits is filing for bankruptcy https://tinyurl.com/yymv7jp5 13. With Wellpath’s contract set to expire, County opens bids for jail health care providers. (Monterey) https://tinyurl.com/3nbam2dw 14. Alameda County supervisor says he doesn't want Wellpath to continue serving Santa Rita Jail https://tinyurl.com/bd5t6xhk 15. How Texas’s bankruptcy courts are used to shield a prison healthcare provider https://tinyurl.com/ar6e33ru 16. National Commission on Correctional Healthcare nhhch.org 17. Fresno County Jail Receives Prestigious Honor for Health Care Standards https://tinyurl.com/fbfk24rm 18. Santa Barbara County Jail Awarded Accreditation from National Commission on Correctional Health Care https://tinyurl.com/yecs4khu 19. San Luis Obispo County Jail, Supported by Wellpath, Receives Accreditation from the National Commission on Correctional Health Care Accreditation https://tinyurl.com/38wvwnyp 20. Ventura County Sheriff’s Office Receives Accreditation from the National Commission on Correctional Health Care. https://tinyurl.com/yehm8r3u 21. Diamond Pharmacy https://www.diamondpharmacy.com/ 22. Omnivore Pharmacy https://www.omnicare.com/ 23. PE-Backed Prison Health Firm Wellpath Declares Bankruptcy https://tinyurl.com/4rx55ajf 24. COCHS Legal Reports on Inmate Healthcare Lawsuits and Deficiencies - https://cochs.org/articles- wellpath-2024/ Page | 280 2024-2025 Lake County Civil Grand Jury Final Report 25. Warren Urges Wellpath to Commit to Fair Payouts and Fair Notice for Incarcerated Patients During Bankruptcy Process https://tinyurl.com/43ch52rf 26. Three Things to Know About Implementing Telehealth in Correctional Facilities https://tinyurl.com/yk5383nj 27. Persistent Noncompliance Found with Santa Barbara County Jail Health Care (staffing and credits) https://tinyurl.com/3j48cd6b 28. County Jail Ends Contract With Medical Provider Wellpath https://tinyurl.com/ 3z8k5bt5 29. Contract holes: Santa Barbara County aims to adjust its contract with jail health care provider, Wellpath, to improve service levels https://tinyurl.com/ mrfj98h4 30. Psychiatric Technician https://tinyurl.com/mr95jyyn 31. Santa Barbara County Jail Health Care Provider Declares Bankruptcy in Name Only https://tinyurl.com/28hpmuzv 32. Wellpath Emerges from Chapter 11 to Lead a New Era in Correctional Healthcare https://tinyurl.com/23d42u9h 33. 33. Psych Tech Jobs https://tinyurl.com/5d2hxtu8 Page | 281 2024-2025 Lake County Civil Grand Jury Final Report Page | 282

R4

That the Board of Supervisors compel the Health Services Director to report yearly the dollar value of unstaffed RN hours and associated reimbursements as required by contract. (F4, F5, F6, F7)

R5

That the Board of Supervisors establish penalties in future Wellpath contracts when the auditing of RN hours has not been completed on time. (F4, F5, F6, F7)

R6

The Board of Supervisors invoke a penalty for the current delay in processing audit of the RN hours. (F4, F5, F6, F7) Page | 275 2024-2025 Lake County Civil Grand Jury Final Report RESPONSES Under California Penal Code section 933.03 (a-c), the following responses are required: Lake County Board of Supervisors R-1, R-2, R-3, R-4, R-5, R-6 90 days The following response is requested: Director, Department of Health Services R-1, R-2, R-3, R-4 60 days Exhibits A and B and C Page | 276 2024-2025 Lake County Civil Grand Jury Final Report A. Letter from Regional Director of Wellpath, April 23, 2025 Lake County Grand Jury P.O. Box 1076 Lakeport, CA 95453 [sic] Subject: Response to Grand Jury Inquiry Regarding Reimbursement of RN Shift Differential Dear Members of the Lake County Grand Jury, I am writing on behalf of Wellpath, LLC in response to your inquiry regarding the reimbursement of funds owed to the County of Lake in relation to the staffing of the night shift Registered Nurse (RN) position at the Lake County Jail Medical Clinic. As background, Wellpath entered into a five-year agreement with the County of Lake effective January 1, 2023, to operate the jail’s medical clinic. In preparation for the January 1, 2024 contract renewal, Wellpath submitted a written proposal to amend the staffing language for the night shift RN position. Due to persistent recruitment challenges in filling RN roles, the proposal allowed Wellpath to staff this shift with a Licensed Vocational Nurse (LVN) if an RN was unavailable. As part of this agreement, Wellpath committed to reimburse the County the wage differential for each shift worked by an LVN in place of an RN. Additionally, the renewal proposal included a provision for an annual Consumer Price Index (CPI) increase to the total contract cost, to be effective January 1, 2024. On December 14, 2023, Wellpath received the County’s signed acceptance of the proposal from the County Administrative Officer. While the County viewed this letter as sufficient to proceed, Wellpath’s internal compliance and legal teams determined that a formal contract amendment was required for both the staffing adjustment and CPI increase to take effect. Accordingly, a draft amendment was submitted to the County. On April 10, 2024, the County Administrative Officer advised Wellpath that she would need to redraft the amendment into a format suitable for County Counsel review and eventual presentation to the Board of Supervisors. Wellpath has not received a finalized version since that date, and as a result, implementation of both the CPI increase and the LVN shift reimbursement calculations was delayed pending formal approval. Page | 277 2024-2025 Lake County Civil Grand Jury Final Report Despite this, in October 2024, Wellpath made the decision to proceed with invoicing for the CPI adjustment retroactive to January 1, 2024, and began reconciling the LVN shift data for the same period. That reconciliation is now underway, and Wellpath is committed to refunding or crediting the County for all applicable amounts where LVNs filled RN designated shifts, in alignment with our original proposal and the County’s accepted terms. We regret the delay in processing these refunds and acknowledge the importance of transparency and timely fiscal responsibility. The delay was rooted in a genuine effort to ensure proper legal and contractual compliance, and not in any intent to avoid reimbursement obligations. Wellpath is committed to maintaining a strong, accountable partnership with Lake County and will ensure that all reconciliations and refunds are completed promptly. A detailed accounting and credit summary will be provided to the County upon finalization. Thank you for the opportunity to clarify the matter. Please do not hesitate to reach out if further information is required. Respectfully, Regional Director of Operations Wellpath, LLC Page | 278 2024-2025 Lake County Civil Grand Jury Final Report B. Senator Elizabeth Warren's Oversight Letter https://www.warren.senate.gov/imo/media/doc/wellpath_bankruptcy_letter.pdf C. Text of article from Open Mind, May 14, 2025 Correctional Health Care Organization Wellpath Emerges From Chapter 11 Reorganization Wellpath, which provides correctional health care services, emerged from Chapter 11 bankruptcy and completed its financial restructuring. The bankruptcy filing was announced on November 11, 2024. The company sought to reduce about $550 million in debt. As part of the reorganization, Wellpath transitioned ownership to a group of its current and former lenders, referred to as the Ad Hoc Lender Group. On January 30, 2025, former Wellpath business line Recovery Solutions, which provides behavioral health services on behalf of public entities, completed a sale transaction that created an independent organization focused on behavioral health. A group of Wellpath’s creditors now owns Recovery Solutions. Financial terms were not disclosed. During the bankruptcy proceedings, Wellpath continued delivering services under its contracts. The company has a network of clinical professionals in 37 states who provide medical and mental health care services to over 200,000 people daily in more than 350 locations. The facilities include prisons, jails, state hospitals, forensic treatment facilities, civil commitment centers, and community-based services centers. Wellpath was advised in this matter by McDermott Will & Emery as legal counsel, Lazard and MTS Health Partners as investment bankers, and FTI Consulting as restructuring advisor. The Ad Hoc Lender Group was advised by Akin Gump Strauss Hauer & Feld LLP as legal counsel, Ankura Consulting Group, LLC, as financial advisor, and Houlihan Lokey Capital, Inc., as investment banker. This was reported by Wellpath on May 12, 2025. More information about Wellpath’s Chapter 11 cases, including the terms of the transactions consummated in connection with the Company’s emergence, is posted at https://dm.epiq11.com/case/wellpath/info (accessed May 14, 2025). Page | 279 2024-2025 Lake County Civil Grand Jury Final Report Bibliography 1. Welllpath website https://wellpathcare.com/about/ 2. HIG CAPITAL’S AND WELLPATH’S CORRECTIONAL HEALTHCARE INVESTMENT RISKS https://tinyurl.com/4psmpuh3 3. Lake County Sheriff's Office Custody Manual (pp. 368-469) - https:// tinyurl.com/55cyjhec 4. Contract including Exhibit B https://tinyurl.com/y5h9c69c 5. 1st Amendment to the CFMG contract https://tinyurl.com/3t8uf3hv 6. Compensation Agreement https://tinyurl.com/3rey9a94 7. Lake County Grand Jury Reports - 2012-2013 and 2021-2022 https:// www.lakecountyca.gov/ArchiveCenter 8. Sonoma county Grand Jury Final Report 2007-2008 (death of inmate) https:// sonoma.courts.ca.gov/system/files?file=2.pdf 9. COUNTY OF LAKE Community Corrections Partnership Plan 2020-2021 https://tinyurl.com/y2xyeh5c 10. Wellpath spins off behavioral health unit in bankruptcy sale https://tinyurl.com/465yphem 11. Prison health company Wellpath reaches $15.5 mln creditor settlement https://tinyurl.com/yvmd6ftv 12. A health care provider that faced dozens of prisoner lawsuits is filing for bankruptcy https://tinyurl.com/yymv7jp5 13. With Wellpath’s contract set to expire, County opens bids for jail health care providers. (Monterey) https://tinyurl.com/3nbam2dw 14. Alameda County supervisor says he doesn't want Wellpath to continue serving Santa Rita Jail https://tinyurl.com/bd5t6xhk 15. How Texas’s bankruptcy courts are used to shield a prison healthcare provider https://tinyurl.com/ar6e33ru 16. National Commission on Correctional Healthcare nhhch.org 17. Fresno County Jail Receives Prestigious Honor for Health Care Standards https://tinyurl.com/fbfk24rm 18. Santa Barbara County Jail Awarded Accreditation from National Commission on Correctional Health Care https://tinyurl.com/yecs4khu 19. San Luis Obispo County Jail, Supported by Wellpath, Receives Accreditation from the National Commission on Correctional Health Care Accreditation https://tinyurl.com/38wvwnyp 20. Ventura County Sheriff’s Office Receives Accreditation from the National Commission on Correctional Health Care. https://tinyurl.com/yehm8r3u 21. Diamond Pharmacy https://www.diamondpharmacy.com/ 22. Omnivore Pharmacy https://www.omnicare.com/ 23. PE-Backed Prison Health Firm Wellpath Declares Bankruptcy https://tinyurl.com/4rx55ajf 24. COCHS Legal Reports on Inmate Healthcare Lawsuits and Deficiencies - https://cochs.org/articles- wellpath-2024/ Page | 280 2024-2025 Lake County Civil Grand Jury Final Report 25. Warren Urges Wellpath to Commit to Fair Payouts and Fair Notice for Incarcerated Patients During Bankruptcy Process https://tinyurl.com/43ch52rf 26. Three Things to Know About Implementing Telehealth in Correctional Facilities https://tinyurl.com/yk5383nj 27. Persistent Noncompliance Found with Santa Barbara County Jail Health Care (staffing and credits) https://tinyurl.com/3j48cd6b 28. County Jail Ends Contract With Medical Provider Wellpath https://tinyurl.com/ 3z8k5bt5 29. Contract holes: Santa Barbara County aims to adjust its contract with jail health care provider, Wellpath, to improve service levels https://tinyurl.com/ mrfj98h4 30. Psychiatric Technician https://tinyurl.com/mr95jyyn 31. Santa Barbara County Jail Health Care Provider Declares Bankruptcy in Name Only https://tinyurl.com/28hpmuzv 32. Wellpath Emerges from Chapter 11 to Lead a New Era in Correctional Healthcare https://tinyurl.com/23d42u9h 33. 33. Psych Tech Jobs https://tinyurl.com/5d2hxtu8 Page | 281 2024-2025 Lake County Civil Grand Jury Final Report Page | 282

R4

That the Board of Supervisors compel the Health Services Director to report yearly the dollar value of unstaffed RN hours and associated reimbursements as required by contract. (F4, F5, F6, F7)

R5

That the Board of Supervisors establish penalties in future Wellpath contracts when the auditing of RN hours has not been completed on time. (F4, F5, F6, F7)

R6

The Board of Supervisors invoke a penalty for the current delay in processing audit of the RN hours. (F4, F5, F6, F7) Page | 275 2024-2025 Lake County Civil Grand Jury Final Report RESPONSES Under California Penal Code section 933.03 (a-c), the following responses are required: Lake County Board of Supervisors R-1, R-2, R-3, R-4, R-5, R-6 90 days The following response is requested: Director, Department of Health Services R-1, R-2, R-3, R-4 60 days Exhibits A and B and C Page | 276 2024-2025 Lake County Civil Grand Jury Final Report A. Letter from Regional Director of Wellpath, April 23, 2025 Lake County Grand Jury P.O. Box 1076 Lakeport, CA 95453 [sic] Subject: Response to Grand Jury Inquiry Regarding Reimbursement of RN Shift Differential Dear Members of the Lake County Grand Jury, I am writing on behalf of Wellpath, LLC in response to your inquiry regarding the reimbursement of funds owed to the County of Lake in relation to the staffing of the night shift Registered Nurse (RN) position at the Lake County Jail Medical Clinic. As background, Wellpath entered into a five-year agreement with the County of Lake effective January 1, 2023, to operate the jail’s medical clinic. In preparation for the January 1, 2024 contract renewal, Wellpath submitted a written proposal to amend the staffing language for the night shift RN position. Due to persistent recruitment challenges in filling RN roles, the proposal allowed Wellpath to staff this shift with a Licensed Vocational Nurse (LVN) if an RN was unavailable. As part of this agreement, Wellpath committed to reimburse the County the wage differential for each shift worked by an LVN in place of an RN. Additionally, the renewal proposal included a provision for an annual Consumer Price Index (CPI) increase to the total contract cost, to be effective January 1, 2024. On December 14, 2023, Wellpath received the County’s signed acceptance of the proposal from the County Administrative Officer. While the County viewed this letter as sufficient to proceed, Wellpath’s internal compliance and legal teams determined that a formal contract amendment was required for both the staffing adjustment and CPI increase to take effect. Accordingly, a draft amendment was submitted to the County. On April 10, 2024, the County Administrative Officer advised Wellpath that she would need to redraft the amendment into a format suitable for County Counsel review and eventual presentation to the Board of Supervisors. Wellpath has not received a finalized version since that date, and as a result, implementation of both the CPI increase and the LVN shift reimbursement calculations was delayed pending formal approval. Page | 277 2024-2025 Lake County Civil Grand Jury Final Report Despite this, in October 2024, Wellpath made the decision to proceed with invoicing for the CPI adjustment retroactive to January 1, 2024, and began reconciling the LVN shift data for the same period. That reconciliation is now underway, and Wellpath is committed to refunding or crediting the County for all applicable amounts where LVNs filled RN designated shifts, in alignment with our original proposal and the County’s accepted terms. We regret the delay in processing these refunds and acknowledge the importance of transparency and timely fiscal responsibility. The delay was rooted in a genuine effort to ensure proper legal and contractual compliance, and not in any intent to avoid reimbursement obligations. Wellpath is committed to maintaining a strong, accountable partnership with Lake County and will ensure that all reconciliations and refunds are completed promptly. A detailed accounting and credit summary will be provided to the County upon finalization. Thank you for the opportunity to clarify the matter. Please do not hesitate to reach out if further information is required. Respectfully, Regional Director of Operations Wellpath, LLC Page | 278 2024-2025 Lake County Civil Grand Jury Final Report B. Senator Elizabeth Warren's Oversight Letter https://www.warren.senate.gov/imo/media/doc/wellpath_bankruptcy_letter.pdf C. Text of article from Open Mind, May 14, 2025 Correctional Health Care Organization Wellpath Emerges From Chapter 11 Reorganization Wellpath, which provides correctional health care services, emerged from Chapter 11 bankruptcy and completed its financial restructuring. The bankruptcy filing was announced on November 11, 2024. The company sought to reduce about $550 million in debt. As part of the reorganization, Wellpath transitioned ownership to a group of its current and former lenders, referred to as the Ad Hoc Lender Group. On January 30, 2025, former Wellpath business line Recovery Solutions, which provides behavioral health services on behalf of public entities, completed a sale transaction that created an independent organization focused on behavioral health. A group of Wellpath’s creditors now owns Recovery Solutions. Financial terms were not disclosed. During the bankruptcy proceedings, Wellpath continued delivering services under its contracts. The company has a network of clinical professionals in 37 states who provide medical and mental health care services to over 200,000 people daily in more than 350 locations. The facilities include prisons, jails, state hospitals, forensic treatment facilities, civil commitment centers, and community-based services centers. Wellpath was advised in this matter by McDermott Will & Emery as legal counsel, Lazard and MTS Health Partners as investment bankers, and FTI Consulting as restructuring advisor. The Ad Hoc Lender Group was advised by Akin Gump Strauss Hauer & Feld LLP as legal counsel, Ankura Consulting Group, LLC, as financial advisor, and Houlihan Lokey Capital, Inc., as investment banker. This was reported by Wellpath on May 12, 2025. More information about Wellpath’s Chapter 11 cases, including the terms of the transactions consummated in connection with the Company’s emergence, is posted at https://dm.epiq11.com/case/wellpath/info (accessed May 14, 2025). Page | 279 2024-2025 Lake County Civil Grand Jury Final Report Bibliography 1. Welllpath website https://wellpathcare.com/about/ 2. HIG CAPITAL’S AND WELLPATH’S CORRECTIONAL HEALTHCARE INVESTMENT RISKS https://tinyurl.com/4psmpuh3 3. Lake County Sheriff's Office Custody Manual (pp. 368-469) - https:// tinyurl.com/55cyjhec 4. Contract including Exhibit B https://tinyurl.com/y5h9c69c 5. 1st Amendment to the CFMG contract https://tinyurl.com/3t8uf3hv 6. Compensation Agreement https://tinyurl.com/3rey9a94 7. Lake County Grand Jury Reports - 2012-2013 and 2021-2022 https:// www.lakecountyca.gov/ArchiveCenter 8. Sonoma county Grand Jury Final Report 2007-2008 (death of inmate) https:// sonoma.courts.ca.gov/system/files?file=2.pdf 9. COUNTY OF LAKE Community Corrections Partnership Plan 2020-2021 https://tinyurl.com/y2xyeh5c 10. Wellpath spins off behavioral health unit in bankruptcy sale https://tinyurl.com/465yphem 11. Prison health company Wellpath reaches $15.5 mln creditor settlement https://tinyurl.com/yvmd6ftv 12. A health care provider that faced dozens of prisoner lawsuits is filing for bankruptcy https://tinyurl.com/yymv7jp5 13. With Wellpath’s contract set to expire, County opens bids for jail health care providers. (Monterey) https://tinyurl.com/3nbam2dw 14. Alameda County supervisor says he doesn't want Wellpath to continue serving Santa Rita Jail https://tinyurl.com/bd5t6xhk 15. How Texas’s bankruptcy courts are used to shield a prison healthcare provider https://tinyurl.com/ar6e33ru 16. National Commission on Correctional Healthcare nhhch.org 17. Fresno County Jail Receives Prestigious Honor for Health Care Standards https://tinyurl.com/fbfk24rm 18. Santa Barbara County Jail Awarded Accreditation from National Commission on Correctional Health Care https://tinyurl.com/yecs4khu 19. San Luis Obispo County Jail, Supported by Wellpath, Receives Accreditation from the National Commission on Correctional Health Care Accreditation https://tinyurl.com/38wvwnyp 20. Ventura County Sheriff’s Office Receives Accreditation from the National Commission on Correctional Health Care. https://tinyurl.com/yehm8r3u 21. Diamond Pharmacy https://www.diamondpharmacy.com/ 22. Omnivore Pharmacy https://www.omnicare.com/ 23. PE-Backed Prison Health Firm Wellpath Declares Bankruptcy https://tinyurl.com/4rx55ajf 24. COCHS Legal Reports on Inmate Healthcare Lawsuits and Deficiencies - https://cochs.org/articles- wellpath-2024/ Page | 280 2024-2025 Lake County Civil Grand Jury Final Report 25. Warren Urges Wellpath to Commit to Fair Payouts and Fair Notice for Incarcerated Patients During Bankruptcy Process https://tinyurl.com/43ch52rf 26. Three Things to Know About Implementing Telehealth in Correctional Facilities https://tinyurl.com/yk5383nj 27. Persistent Noncompliance Found with Santa Barbara County Jail Health Care (staffing and credits) https://tinyurl.com/3j48cd6b 28. County Jail Ends Contract With Medical Provider Wellpath https://tinyurl.com/ 3z8k5bt5 29. Contract holes: Santa Barbara County aims to adjust its contract with jail health care provider, Wellpath, to improve service levels https://tinyurl.com/ mrfj98h4 30. Psychiatric Technician https://tinyurl.com/mr95jyyn 31. Santa Barbara County Jail Health Care Provider Declares Bankruptcy in Name Only https://tinyurl.com/28hpmuzv 32. Wellpath Emerges from Chapter 11 to Lead a New Era in Correctional Healthcare https://tinyurl.com/23d42u9h 33. 33. Psych Tech Jobs https://tinyurl.com/5d2hxtu8 Page | 281 2024-2025 Lake County Civil Grand Jury Final Report Page | 282

R4

That the Board of Supervisors compel the Health Services Director to report yearly the dollar value of unstaffed RN hours and associated reimbursements as required by contract. (F4, F5, F6, F7)

R5

That the Board of Supervisors establish penalties in future Wellpath contracts when the auditing of RN hours has not been completed on time. (F4, F5, F6, F7)

R6

The Board of Supervisors invoke a penalty for the current delay in processing audit of the RN hours. (F4, F5, F6, F7) Page | 275 2024-2025 Lake County Civil Grand Jury Final Report RESPONSES Under California Penal Code section 933.03 (a-c), the following responses are required: Lake County Board of Supervisors R-1, R-2, R-3, R-4, R-5, R-6 90 days The following response is requested: Director, Department of Health Services R-1, R-2, R-3, R-4 60 days Exhibits A and B and C Page | 276 2024-2025 Lake County Civil Grand Jury Final Report A. Letter from Regional Director of Wellpath, April 23, 2025 Lake County Grand Jury P.O. Box 1076 Lakeport, CA 95453 [sic] Subject: Response to Grand Jury Inquiry Regarding Reimbursement of RN Shift Differential Dear Members of the Lake County Grand Jury, I am writing on behalf of Wellpath, LLC in response to your inquiry regarding the reimbursement of funds owed to the County of Lake in relation to the staffing of the night shift Registered Nurse (RN) position at the Lake County Jail Medical Clinic. As background, Wellpath entered into a five-year agreement with the County of Lake effective January 1, 2023, to operate the jail’s medical clinic. In preparation for the January 1, 2024 contract renewal, Wellpath submitted a written proposal to amend the staffing language for the night shift RN position. Due to persistent recruitment challenges in filling RN roles, the proposal allowed Wellpath to staff this shift with a Licensed Vocational Nurse (LVN) if an RN was unavailable. As part of this agreement, Wellpath committed to reimburse the County the wage differential for each shift worked by an LVN in place of an RN. Additionally, the renewal proposal included a provision for an annual Consumer Price Index (CPI) increase to the total contract cost, to be effective January 1, 2024. On December 14, 2023, Wellpath received the County’s signed acceptance of the proposal from the County Administrative Officer. While the County viewed this letter as sufficient to proceed, Wellpath’s internal compliance and legal teams determined that a formal contract amendment was required for both the staffing adjustment and CPI increase to take effect. Accordingly, a draft amendment was submitted to the County. On April 10, 2024, the County Administrative Officer advised Wellpath that she would need to redraft the amendment into a format suitable for County Counsel review and eventual presentation to the Board of Supervisors. Wellpath has not received a finalized version since that date, and as a result, implementation of both the CPI increase and the LVN shift reimbursement calculations was delayed pending formal approval. Page | 277 2024-2025 Lake County Civil Grand Jury Final Report Despite this, in October 2024, Wellpath made the decision to proceed with invoicing for the CPI adjustment retroactive to January 1, 2024, and began reconciling the LVN shift data for the same period. That reconciliation is now underway, and Wellpath is committed to refunding or crediting the County for all applicable amounts where LVNs filled RN designated shifts, in alignment with our original proposal and the County’s accepted terms. We regret the delay in processing these refunds and acknowledge the importance of transparency and timely fiscal responsibility. The delay was rooted in a genuine effort to ensure proper legal and contractual compliance, and not in any intent to avoid reimbursement obligations. Wellpath is committed to maintaining a strong, accountable partnership with Lake County and will ensure that all reconciliations and refunds are completed promptly. A detailed accounting and credit summary will be provided to the County upon finalization. Thank you for the opportunity to clarify the matter. Please do not hesitate to reach out if further information is required. Respectfully, Regional Director of Operations Wellpath, LLC Page | 278 2024-2025 Lake County Civil Grand Jury Final Report B. Senator Elizabeth Warren's Oversight Letter https://www.warren.senate.gov/imo/media/doc/wellpath_bankruptcy_letter.pdf C. Text of article from Open Mind, May 14, 2025 Correctional Health Care Organization Wellpath Emerges From Chapter 11 Reorganization Wellpath, which provides correctional health care services, emerged from Chapter 11 bankruptcy and completed its financial restructuring. The bankruptcy filing was announced on November 11, 2024. The company sought to reduce about $550 million in debt. As part of the reorganization, Wellpath transitioned ownership to a group of its current and former lenders, referred to as the Ad Hoc Lender Group. On January 30, 2025, former Wellpath business line Recovery Solutions, which provides behavioral health services on behalf of public entities, completed a sale transaction that created an independent organization focused on behavioral health. A group of Wellpath’s creditors now owns Recovery Solutions. Financial terms were not disclosed. During the bankruptcy proceedings, Wellpath continued delivering services under its contracts. The company has a network of clinical professionals in 37 states who provide medical and mental health care services to over 200,000 people daily in more than 350 locations. The facilities include prisons, jails, state hospitals, forensic treatment facilities, civil commitment centers, and community-based services centers. Wellpath was advised in this matter by McDermott Will & Emery as legal counsel, Lazard and MTS Health Partners as investment bankers, and FTI Consulting as restructuring advisor. The Ad Hoc Lender Group was advised by Akin Gump Strauss Hauer & Feld LLP as legal counsel, Ankura Consulting Group, LLC, as financial advisor, and Houlihan Lokey Capital, Inc., as investment banker. This was reported by Wellpath on May 12, 2025. More information about Wellpath’s Chapter 11 cases, including the terms of the transactions consummated in connection with the Company’s emergence, is posted at https://dm.epiq11.com/case/wellpath/info (accessed May 14, 2025). Page | 279 2024-2025 Lake County Civil Grand Jury Final Report Bibliography 1. Welllpath website https://wellpathcare.com/about/ 2. HIG CAPITAL’S AND WELLPATH’S CORRECTIONAL HEALTHCARE INVESTMENT RISKS https://tinyurl.com/4psmpuh3 3. Lake County Sheriff's Office Custody Manual (pp. 368-469) - https:// tinyurl.com/55cyjhec 4. Contract including Exhibit B https://tinyurl.com/y5h9c69c 5. 1st Amendment to the CFMG contract https://tinyurl.com/3t8uf3hv 6. Compensation Agreement https://tinyurl.com/3rey9a94 7. Lake County Grand Jury Reports - 2012-2013 and 2021-2022 https:// www.lakecountyca.gov/ArchiveCenter 8. Sonoma county Grand Jury Final Report 2007-2008 (death of inmate) https:// sonoma.courts.ca.gov/system/files?file=2.pdf 9. COUNTY OF LAKE Community Corrections Partnership Plan 2020-2021 https://tinyurl.com/y2xyeh5c 10. Wellpath spins off behavioral health unit in bankruptcy sale https://tinyurl.com/465yphem 11. Prison health company Wellpath reaches $15.5 mln creditor settlement https://tinyurl.com/yvmd6ftv 12. A health care provider that faced dozens of prisoner lawsuits is filing for bankruptcy https://tinyurl.com/yymv7jp5 13. With Wellpath’s contract set to expire, County opens bids for jail health care providers. (Monterey) https://tinyurl.com/3nbam2dw 14. Alameda County supervisor says he doesn't want Wellpath to continue serving Santa Rita Jail https://tinyurl.com/bd5t6xhk 15. How Texas’s bankruptcy courts are used to shield a prison healthcare provider https://tinyurl.com/ar6e33ru 16. National Commission on Correctional Healthcare nhhch.org 17. Fresno County Jail Receives Prestigious Honor for Health Care Standards https://tinyurl.com/fbfk24rm 18. Santa Barbara County Jail Awarded Accreditation from National Commission on Correctional Health Care https://tinyurl.com/yecs4khu 19. San Luis Obispo County Jail, Supported by Wellpath, Receives Accreditation from the National Commission on Correctional Health Care Accreditation https://tinyurl.com/38wvwnyp 20. Ventura County Sheriff’s Office Receives Accreditation from the National Commission on Correctional Health Care. https://tinyurl.com/yehm8r3u 21. Diamond Pharmacy https://www.diamondpharmacy.com/ 22. Omnivore Pharmacy https://www.omnicare.com/ 23. PE-Backed Prison Health Firm Wellpath Declares Bankruptcy https://tinyurl.com/4rx55ajf 24. COCHS Legal Reports on Inmate Healthcare Lawsuits and Deficiencies - https://cochs.org/articles- wellpath-2024/ Page | 280 2024-2025 Lake County Civil Grand Jury Final Report 25. Warren Urges Wellpath to Commit to Fair Payouts and Fair Notice for Incarcerated Patients During Bankruptcy Process https://tinyurl.com/43ch52rf 26. Three Things to Know About Implementing Telehealth in Correctional Facilities https://tinyurl.com/yk5383nj 27. Persistent Noncompliance Found with Santa Barbara County Jail Health Care (staffing and credits) https://tinyurl.com/3j48cd6b 28. County Jail Ends Contract With Medical Provider Wellpath https://tinyurl.com/ 3z8k5bt5 29. Contract holes: Santa Barbara County aims to adjust its contract with jail health care provider, Wellpath, to improve service levels https://tinyurl.com/ mrfj98h4 30. Psychiatric Technician https://tinyurl.com/mr95jyyn 31. Santa Barbara County Jail Health Care Provider Declares Bankruptcy in Name Only https://tinyurl.com/28hpmuzv 32. Wellpath Emerges from Chapter 11 to Lead a New Era in Correctional Healthcare https://tinyurl.com/23d42u9h 33. 33. Psych Tech Jobs https://tinyurl.com/5d2hxtu8 Page | 281 2024-2025 Lake County Civil Grand Jury Final Report Page | 282

R1

That the Board of Supervisors direct the Health Services Director to establish a formal protocol for emergency access to critical medications through local pharmacies when Omnicare delivery is unavailable. (F1, F2, F8)