By Jessica Ellison

On July 21, 2025, the Department of Managed Health Care (“DMHC” or “the Department”) countersigned a Letter of Agreement against Blue Cross of California Partnership Plan, Inc. (Plan), which covers more than 960,000 enrollees in California, for failure to correct several deficiencies identified in a prior audit.

The initial audit was a routine survey conducted by the Department’s Division of Plan Surveys in November 2017. The Department issued a Preliminary Report on April 19, 2019, to provide the Plan an opportunity to correct the identified deficiencies through a Corrective Action Plan (CAP) and provide the Department with proof of implementation of these CAPs. On August 14, 2019, DMHC issued the Final Report of the 2017 Routine Survey, which found that sixteen of the seventeen identified deficiencies remained uncorrected. On March 28, 2023, the Department issued a Routine Survey Follow-up Report on March 28, 2023 and found eleven of the seventeen deficiencies remained uncorrected and notified the Plan that the issue would be referred to the Department’s Office of Enforcement (OE) for further action.

The various deficiencies implicated violations of the plan requirements for grievance and appeals processes, quality assurance, licensing standards, language assistance, and medical surveys. These included violations of both the Health and Safety Code and the California Code of Regulations, including failure to establish procedures allowing enrollees to participate in establishing the public policy of the Plan, failure to properly consider enrollee grievances and provide reasons for denial of claims, failure to have a well-monitored grievance system, failure to include required statutory language on their website, failure to follow statutory procedures in addressing enrollee grievances, among many others. Collectively, these deficiencies reflected systemic barriers to members’ access to information, fair grievance handling, and quality oversight.

Because many of these statutory and regulatory deficiencies remained uncorrected after repeated surveys, DMHC imposed a $500,000 penalty and issued a detailed CAP to bring the Plan into compliance. The CAP requires the Plan to take action to correct the remaining deficiencies and provide narratives outlining the actions taken to OE. The deliverable actions were due to the Department by July 30, 2025.