The Comprehensive Perinatal Services Program
Learn how the AI-generated research projects were createdOverall Conclusion
The State has provided limited oversight of the Comprehensive Perinatal Services Program and has not meaningfully improved the program. Data limitations and insufficient oversight hinder the ability to determine whether Medi-Cal members receive CPSP services as intended or whether the program is effectively reducing low birthweight or improving maternal-infant outcomes. Without strengthened data collection, comprehensive provider oversight (across fee-for-service and managed care), and proactive outreach, CPSP is unlikely to achieve its goals.
Source Document
Audit Scope
The audit examines the Comprehensive Perinatal Services Program (CPSP) oversight by the California Department of Health Care Services and the California Department of Public Health, including their management of fee-for-service and Medi-Cal managed care; it evaluates the adequacy of program data collection and reporting, provider oversight (including chart reviews and provider education), and outreach to Medi-Cal members and providers. The scope covers the program’s governance and operation during the period surrounding the CPSP and CalAIM transition, with a focus on data and oversight activities for the period 2018–2022, and it notes development through 2023–2024, including the planned replacement of local oversight with a provider‑verified annual survey and the anticipated expansion of managed care enrollment under CalAIM. The analysis includes the roles of Health Care Services and Public Health, the interaction with managed care plans, and the implications for utilization and outcomes of perinatal services.
Key Findings Summary
The State provided limited oversight of the CPSP by Health Care Services and Public Health and did not exercise full authority to drive program improvements.
There are significant data limitations that prevent meaningful measurement of CPSP usage, including non-exclusive billing codes used by managed care plans and lack of systematic data collection for fee-for-service providers.
Utilization data for the CPSP is incomplete: in 2022, it could be assessed for only about 14% of Medi‑Cal members, with fee-for-service members showing some utilization (more than half pregnant members in fee-for-service plans received CPSP services during pregnancy; less than 16% received CPSP services within 60 days after birth).
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AI-Assisted
AI Scope Summary
This audit examines whether California's Comprehensive Perinatal Services Program is adequately overseen and utilized, focusing on data adequacy, provider oversight, and outreach, across fee-for-service and managed care delivery, and identifies barriers and opportunities for program improvement.
AI-Generated Insight
The audit uncovers systemwide gaps in data, oversight, and communications that are hindering the CPSP’s ability to improve maternal and infant health outcomes in California. The reliance on non-specific billing codes, fragmented oversight (by both Health Care Services and Public Health), and the anticipated shift to survey-based oversight under CalAIM pose risks to the reliability of CPSP usage data and the program’s effectiveness. The report underscores the need for robust, independent verification, standardized data collection, and proactive outreach to ensure CPSP services are delivered to Medi‑Cal members who need them.
Audit Objectives
Assess the adequacy of oversight by Health Care Services (California Department of Health Care Services) and Public Health over the Comprehensive Perinatal Services Program (CPSP) and determine whether program governance aligns with state laws and contract provisions.
Evaluate the availability, quality, and use of data to measure CPSP usage, delivery of services, and provider performance across fee-for-service and managed care delivery models.
Evaluate whether managed care plans and fee-for-service providers deliver CPSP services to Medi‑Cal members as intended and whether utilization data can support program improvement.
Assess the effectiveness of outreach and communication to Medi-Cal members and providers about CPSP availability and scope, including provider education and member handbooks.
Identify barriers to CPSP utilization and oversight, including data limitations, incomplete local oversight, and policy gaps, and recommend actions to address them.
Examine evolving program governance in the context of CalAIM and the intended transition of oversight mechanisms (e.g., provider surveys, new data systems) and their implications for CPSP oversight.
Audit Findings (8)
The State provided limited oversight of the CPSP by Health Care Services and Public Health and did not exercise full authority to drive program improvements.
There are significant data limitations that prevent meaningful measurement of CPSP usage, including non-exclusive billing codes used by managed care plans and lack of systematic data collection for fee-for-service providers.
Utilization data for the CPSP is incomplete: in 2022, it could be assessed for only about 14% of Medi‑Cal members, with fee-for-service members showing some utilization (more than half pregnant members in fee-for-service plans received CPSP services during pregnancy; less than 16% received CPSP services within 60 days after birth).
Only a small fraction of provider reviews included CPSP services in 2022 (about 1.7% of 2,600 reviews, i.e., 45 reviews across 18 counties); OB-GYNs and other perinatal service providers who are not designated primary care providers are often excluded from reviews.
Local oversight of fee-for-service providers by Public Health was limited; 22 of 61 local jurisdictions reported no chart reviews from 2018–2022; many reviews declined during the pandemic; Public Health planned to shift to a provider‑verified annual survey rather than robust local chart reviews, reducing independent verification.
Public Health intends to shift oversight away from local coordinators to a provider survey, but without independent verification this could reduce the reliability of oversight results.
Health Care Services’ provider reviews are not consistently focused on perinatal services (CPSP section not always used) and do not systematically feed into broader program improvements; 18 reviews per year were performed in some years, far below expectations given the number of plans and counties.
Overall, the lack of data and oversight limits the ability to confirm that Medi‑Cal members are receiving CPSP services as required and to evaluate the program’s effectiveness in reducing low birthweight and improving maternal-infant outcomes.
Recommendations (9)
Mandate comprehensive CPSP data collection and analysis by Public Health, including maintaining a complete active provider list, collecting local chart review results, and producing regular statewide usage and outcomes reports.
Expand and strengthen provider reviews to include all perinatal service providers (e.g., OB-GYNs) regardless of whether they are designated primary care providers; ensure the CPSP section is consistently applied in reviews and that results feed into program improvements.
Require managed care plans to report CPSP-related data and outcomes, and enable Health Care Services to analyze trends across counties and plans through the new data system (Managed Care Site Review Portal).
Reinforce independent verification for any provider survey-based oversight adopted by Public Health to ensure data reliability and reduce reliance on self‑certification.
Enhance member and provider outreach by updating handbooks to describe the full range of CPSP services, and clarify how to access and utilize CPSP benefits; coordinate with local health jurisdictions to promote CPSP participation.
Utilize enforcement tools as needed (e.g., corrective action plans, sanctions) to drive compliance with CPSP requirements, and tie improvements to measurable CPSP outcomes.
Monitor and report on CPSP outcomes such as low birthweight rates and postpartum care uptake to evaluate program effectiveness and guide continuous improvement.
Establish or require exclusive CPSP-specific billing codes for managed care plans to enable accurate tracking of perinatal services, and ensure consistent reporting of CPSP services across fee-for-service and managed care.
Align CPSP oversight and data activities with the CalAIM initiative to ensure integrated, coordinated, and equity-focused perinatal care delivery.