Management Oversight and Monitoring. The Contractor agrees to:
A. Establish and maintain ongoing management oversight and quality assurance for monitoring workforce compliance with the privacy and security safeguards in this Agreement when using or disclosing Medi-Cal PII and ensure that ongoing management oversight includes periodic self-assessments.
Management Oversight and Monitoring. To ensure compliance with the privacy and security safeguards in this Agreement the County shall perform the following:
a. Conduct periodic privacy and security reviews of work activity by Contractor Staff, including random sampling of work product. Examples include, but are not limited to, access to case files or other activities related to the handling of PII.
b. The periodic privacy and security reviews must be performed or overseen by management level personnel who are knowledgeable and experienced in the areas of privacy and information security in the administration of their program, and the use or disclosure of PII.
Management Oversight and Monitoring. To ensure compliance with the privacy and security safeguards in this Agreement the county shall perform the following:
Management Oversight and Monitoring. To ensure compliance with the privacy and security safeguards in this Agreement Contractor shall perform the following:
A. Conduct periodic privacy and security review of work activity by Contractor workers to ensure compliance with this agreement.
B. The periodic privacy and security reviews must be performed or overseen by Contractor management level personnel who are knowledgeable and experienced in the areas of privacy and information security.
Management Oversight and Monitoring. The County Department agrees to:
Management Oversight and Monitoring. To ensure compliance with the privacy and security safeguards in this Agreement the County shall perform the following:
A. Conduct periodic privacy and security review of work activity by County Workers, including random sampling of work product. Examples include, but are not limited to, access to case files or other activities related to the handling of Medi-Cal PII. The periodic privacy and security reviews shall be performed or overseen by management level personnel who are knowledgeable and experienced in the areas of privacy and information security in the administration of the Medi-Cal program and the use or disclosure of Medi-Cal PII.
B. Utilize Medi-Cal Eligibility Data System (MEDS) audit reports provided by DHCS and other system auditing tools available to County Department/Agency to perform quality assurance and management oversight reviews of their County Workers’ access to Medi-Cal and SSA PII within data systems utilized, including MEDS. For additional information see Medi-Cal Eligibility Division Information Letter | 21-34. Any instances of suspected security incidents or breaches are to be reported to DHCS immediately following the instructions within Section X of this Agreement. To ensure a separation of duties, these system audit reviews shall be performed by privacy and security staff who do not have access to Medi-Cal PII within the systems. SSA requires DHCS to enforce a separation of duties, excluding any individual who uses MEDS to make benefit or entitlement determinations from participating in oversight, monitoring, or quality assurance functions. DHCS acknowledges that in smaller counties the separation of duties requirement might create a hardship based on there being a small number of people available to perform various tasks. Requests for hardship exemptions will be approved on a case-by-case basis.
Management Oversight and Monitoring. County Department agrees to:
A. Establish and maintain ongoing management oversight and quality assurance for monitoring workforce compliance with the privacy and security safeguards in this Agreement when using or disclosing Medi-Cal PII.
B. Ensure ongoing management oversight including periodic self-assessments and random sampling of work activity by County Workers, who assist in the administration of Medi-Cal and use or disclose Medi-Cal PII. DHCS shall provide the County Department with information on the Medi-Cal Eligibility Data System (MEDS) usage anomalies for investigation and follow-up.
C. Ensure these management oversight and monitoring activities are performed by County Workers, whose job functions are separate from those, who use or disclose Medi-Cal PII as part of their routine duties.
Management Oversight and Monitoring. The LCSA agrees to:
Management Oversight and Monitoring. To ensure compliance with the privacy and security safeguards in this Agreement the CalSAWS Consortium shall perform the following:
Management Oversight and Monitoring. To ensure compliance with the privacy and security safeguards in this Agreement the county County Department shall perform the following:
A. Conduct periodic privacy and security reviewreviews of work activity by County Workerscounty staff, including random sampling of work product. Examples include, but are not limited to, access to case files or other activities related to the handling of Medi- Cal PII.
B. The periodic privacy and security reviews must be performed or overseen by management level personnel who are knowledgeable and experienced in the areas of privacy and information security in the administration of the Medi-Caltheir program, and the use or disclosure of Medi-Cal PII.
