Downloadable PDF
Uncovering Systemic Contract Breaches & Data Governance Failures
This exhibit documents a detailed summary of repeated vendor non-compliance across multiple contract domains for the HFS HealthChoice Illinois ADT Program. Despite being entrusted with sensitive Medicaid data to support real-time care coordination for over 3 million lives, the vendor has consistently failed to meet critical performance, security, transparency, and communication standards as outlined in the original Request for Proposal (RFP) and signed contract.
Highlighted violations include:
Unauthorized use of PHI/PII without proper approval
Failure to submit required training materials, system performance reports, or help desk metrics
Nonexistent reporting on key items such as roster reconciliation, HL7 message delivery, and user engagement
Ongoing ambiguity around subscription file enforcement, test environment access, and EHR interoperability
This report also reveals unresolved gaps in security monitoring, lack of role-based test access, and a failure to support outcome metrics aligned with the Illinois Medicaid Quality Strategy.
This documentation serves as evidence of breach and calls for:
Formal contract audit
Remediation timeline and corrective action plan
Potential legal review for enforcement of contract terms
Download the full PDF and Excel documentation below for the complete breakdown of non-compliance categories, corresponding contract clauses, and unresolved action items.
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