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Compliance Program Presentation to the MHBE Board of Trustees Presented by Caterina Pagilinan May 18, 2020 Q3 FY2020 Privacy, Audit And Compliance Activities Independent Financial and Programmatic Audit Annual Privacy, IT Security


  1. Compliance Program Presentation to the MHBE Board of Trustees Presented by Caterina Pañgilinan May 18, 2020

  2. Q3 FY2020 Privacy, Audit And Compliance Activities  Independent Financial and Programmatic Audit  Annual Privacy, IT Security and Fraud, Waste and Abuse Training  Privacy Impact Assessment (PIA) - Access to Personally Identifiable Information  Secure Faxing Protocol  Transition to HIPAA IT Security Requirements for Carriers  Office of Legislation Audit (OLA) Finance, Network and General Services Triennial Audits  SOC 2 Type 2 Audit Requirement Changes  Contract Management Process  Policy and Procedure Improvement Project  Fully Implement List of Excluded Individuals and Entities Process  Revamp Privacy Notice  508 Compliance 2

  3. Internal Control Reviews  Improve IRS 1075 Safeguards – Federal Tax Information Background Check Processes  Improve traceability of verification of consultant timesheets to invoicing to payment process  Proper Invoice Payments to Connector Entities  Expand Override Process Verifications  Inventory and Reconciliation Processes  Request For Resume Conflict of Interest  Payment Error Rate Measurement (PERM) Audit Initial Findings  Procurement Bid Security Process 3

  4. Postponed  Incorporate Unemployment Compensation Data into Income Verification Process  Full Implementation of Failure to Reconcile Taxes Process  Employer-Sponsored Coverage Verification Process  Internal Revenue Service Safeguards Triennial Review  Payment Error Rate Measurement (PERM) Audit  Eligibility Improper Payment Measurement (EIPM) Pilot  State-based Marketplace Annual Reporting Tool (SMART), Minimum Acceptable Risk Standards for Exchanges (MARSE) and Privacy Impact Assessments (PIA) 4

  5. FY 2020 Compliance Hotline 3 rd Quarter FY20 Compliance Hotline Calls Department 3rd QTR Calls FY20 YTD Calls 2% 1% Constituent Services 102 263 Compliance Hotline 0 3 Civil Rights Officer 2 6 Constituent Services TOTAL 104 272 Compliance Hotline Civil Rights Officer 97% 3 rd Quarter YTD FY20 Fraud, Waste & Abuse Allegations 14 - Allegations  7 - Not Founded  1 - Partially Founded  5 - Referred  1 - Pending Investigation 5

  6. Q3 FY20 YTD PRIVACY INCIDENTS (Non- Producer) 9% Increase in Rate of Misloads 15% Increase in Rate of Privacy Incidents - 1.31 from 1.14 30 2.00 FY19 FY20 1.80 3.00 25 1.60 1.40 2.52 2.79 20 1.20 2.49 2.29 15 1.00 2.00 1.92 0.80 10 0.60 0.40 5 1.00 0.20 0 0.00 Jul Aug Sep Oct Nov Dec Jan Feb Mar FY19 Raw No. FY20 Raw No. FY19 Rate FY20 Rate 0.00 Rate Per 10,000 Enrollments Per 10,000 Uploads

  7. Misloaded Documents Per 100,000 Calls 4 3 2 1 0 Jul Aug Sep Oct Nov Dec Jan Feb Mar FY 19 FY 20 7

  8. Privacy Incident Mitigation Rate of Misloads requiring Notice to Consumer (per 10 Misloads) Average Days to Delete Misload Average Days to Send Breach Letter Rate of Parties Affected (per 10,000 Enrollments) 0.00 2.00 4.00 6.00 8.00 10.00 12.00 FY20 FY19 8

  9. Questions? Thank you for your leadership. 9

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