What is the DHCS TRACS System?

In the context of California health and legal services, "DHCS TRACS" typically refers to the Treatment Records and Compliance System (or similar internal tracking databases) used by the California Department of Health Care Services (DHCS).

This is a national system so it applies equally to Contra Costa County where we have our office or to the most remote regions of the United States, Guam (anywhere that US based healthcare insurance or programs exist.)  It is designed to reduce waste and abuse of the federal or state systems by providing a single repository for raw data.  It is not a place for police reports, FBI reports etc..  Much of the data is technical or data and to use it for your benefit you will end up hiring an expert witness (Expensive!)

Fraud referrals received by DHCS from all sources are tracked in the DHCS case tracking system known as the Tracking, Reporting, Administrative Actions & Case Development System (TRACS). TRACS is used to document these referrals, the resulting investigations, and the disposition of the investigation. The TRACS system does not contain details on overpayment recoveries as that information is contained in the CMIPS system.fraud referrals received by DHCS from all sources are tracked in the DHCS case tracking system known as the Tracking, Reporting, Administrative Actions & Case Development System (TRACS). TRACS is used to document these referrals, the resulting investigations, and the disposition of the investigation. The TRACS system does not contain details on overpayment recoveries as that information is contained in the CMIPS system.

When viewing TRACS reports there is a "Notes" section that has a short narrative which is sort of a summary progress note of an investigation.  With a good AI program, you  can download all the TRACS data and have AI pull out the notes and organize it in a table by Date / Note contents.  

DHCS Internal Tracking (Healthcare & Medi-Cal)

For an attorney or professional working with the Department of Health Care Services, TRACS generally refers to an internal department system used to track audits, investigations, and compliance related to Medi-Cal providers and beneficiaries.

• Purpose: It helps DHCS monitor the flow of data, transition of care, and compliance with state and federal regulations.

• Legal Context: If you are dealing with a subpoena for records or a Medical Board matter, you might see references to TRACS in the metadata or as the "system of record" for tracking correspondence and investigative milestones.

There is a HUD based TRACS system but that is different.   An example of how the TRACS system could be used is the recent hospice fraud investigation and arrests.  Recently, Attorney General Rob Bonta .made the claim that:  “Over the life of this fraud scheme, not a single legitimate hospice service was ever provided, yet millions were billed in a brazen, calculated scheme that exploited the Medi-Cal system. This wasn’t a mistake or a loophole; it was deliberate fraud. This kind of abuse undermines trust, drains critical resources, and threatens care for those who truly depend on it. This is a perfect example that we have taken a firm stand to investigate, prosecute, and shut down hospice fraud wherever it exists.”   This is exactly the type of investigation that would use (as a small but important part of the investigation) TRACS to coordinate and track the massive amount of data relating to the investigation.  Lawyers defending people arrested will be looking at the TRACS data as part of their defense preparation.

How Can You Use TRACS?

TRACS at present provides 24 specific screens to track and update beneficiary records.  In any medical fraud case or billing investigation the lawyer should request full TRACS records and the supporting data.  This will be viewed as internal to the investigators and they will fight to withhold the materials.  If they do provide it the spreadsheets may be hard to decipher.  Unfortunately - expensively - you may have to hire a TRACS expert to decipher what is going on.  This is true with any government data used against a defendant in a civil or criminal case.  The summaries and data are only as good as the sources. We have had many cases where summaries or data collections were offered as evidence.  We objected on HEARSAY grounds.   The federal hearsay rule is similar to the rule in most states.  Basically it says that out-of-court statements when they are offered to prove the truth of the matter asserted are improper because the declarant cannot be cross-examined.   In terms of TRACS records or more broadly any database information, the sources cannot be questioned so how do you know if the data is reliable.  There are many exceptions and many rules governing this type of attack but unless you demand the raw data you (as an attorney) will be limited in how you challenge conclusions of witnesses drawn from the questionable data.

From a trial standpoint here's an important set of questions.  First, how do you prepare a foundation to have the document recognized as authentic so it can be admitted in evidence?  Next, once admitted is it admissible in its entirety or are parts still hearsay?  Is it a business record or official record (and if so, how does that affect what contents are admissible or not).  If it contains a summary of an investigation can you find out who wrote the summary and what the sources were that the summary was based on?    We have answered some (not all) of these questions in another blog.   Blog on Admitting Documentary Evidence.  One last thought - if you an get the TRACS data with the embedded metadata that can give you some insight as to who last held or edited the document.

How "They" Use TRACS

In the context of California health law and Medi-Cal oversight, TRACS (Treatment Records and Compliance System) serves as the "digital nervous system" for the Department of Health Care Services (DHCS).

While SIRIS is a shared intelligence platform across many insurers, TRACS is a specialized internal system used by DHCS to track the lifecycle of audits, provider compliance, and investigative milestones. When a "routine audit" in TRACS flags an anomaly, it can quickly escalate into a criminal referral to the Department of Justice (DOJ).

Here are specific ways TRACS is involved in criminal investigations, including recent real-world examples:

1. Tracking "Outlier" Billing Patterns

TRACS is used to aggregate and monitor billing data to find providers who deviate from the statistical norm.

• The Mechanism: If a physician is billing for 26 hours of face-to-face patient time in a single 24-hour day, TRACS flags this as a compliance failure.

• Criminal Application: This data is often the "Exhibit A" used to obtain search warrants. It provides the Probable Cause needed to show that the billing isn't just a clerical error, but a systematic attempt to defraud the state.

2. Managing "Credible Allegation of Fraud" (CAF) Referrals

By law (Welfare and Institutions Code §14107.11), DHCS must suspend payments to a provider if there is a "Credible Allegation of Fraud."

• The Role of TRACS: TRACS acts as the formal system of record for these suspensions. It tracks when the allegation was made, who the witnesses are, and the status of the referral to the Division of Medi-Cal Fraud and Elder Abuse (DMFEA).

• Criminal Application: Prosecutors use the audit trail in TRACS to prove that a provider was officially notified of compliance issues but continued the fraudulent activity, helping establish criminal intent (scienter).

3. Real-Life Case Example: Operation Skip Trace (April 2026)

In a major case involving a $267 million hospice fraud ring in Los Angeles, DHCS systems like TRACS played a critical role in dismantling a transnational criminal network.

• The Investigation: Criminals used stolen identities to enroll people in Medi-Cal and bill for hospice services that were never provided.

• How Systems like TRACS were involved:

  • Detection: DHCS used data analytics to flag 14 "hospice companies" that had zero legitimate patient contact but millions in billing.

  • Coordination: TRACS allowed DHCS sworn peace officers to coordinate with the California DOJ to execute search warrants at 12 locations simultaneously.

  • Outcome: The system helped identify that over 7,000 fraudulent enrollments were linked to these "straw owners." This led to the arrest of 21 suspects and the seizure of over $757,000 in cash and firearms.

4. Evidentiary Use in "Medical Board" Matters

For attorneys defending medical professionals, TRACS is often the source of the metadata and correspondence logs produced during discovery.

• The Role: If the Medical Board of California moves to revoke a license based on Medi-Cal fraud, the TRACS file contains the internal "investigative milestones."

• Investigation Insight: Defense teams often look at TRACS entries to see if DHCS followed proper protocols or if there were "gaps" in the investigation that suggest the provider was targeted unfairly or that the data was misinterpreted.

Comparison: SIRIS vs. TRACS in a Criminal Case    See our Blog on SIRIS

So in summary, we published the general TRACS definition to clarify what it is but to answer the core question "Why do you need to know this definition?"   Bottom line is that doctors or lawyers representing doctors look up this term because their clients are being investigated!   If you are a doctor who is not presently represented consider calling the Horowitz law firm.  Our firm defends medical professionals facing fraud investigations.  Call us at (925) 283-1863.