What is a Corrective Action Plan?

A Corrective Action Plan (CAP) is a plan that outlines steps, a timeline, and personnel involved in addressing and correcting individual provider issues; it is written and initiated by the provider and shared with their Medicare contractor. The CAP is measurable and specific to the provider’s identified errors. Several factors determine whether or not a contractor may request a CAP from a provider:

• The length of involvement in a Progressive Corrective Action (PCA) case
• The provider's Payment Error Rate (PER) and/or Claim Error Rate (CER)
• The severity or dollar amount involved in the errors found, and/or
• Other PCA case involvement and education the supplier may have received

CAP Process

Providers will know if they must submit a CAP by reading their PCA results letters closely. If a CAP is required, the request is made by the Medical Review Department in the most recent results letter. Suggestions for creating, implementing, and evaluating the CAP are outlined in the letter, along with the contact person in Medical Review to submit the plan. Providers usually have 30 days to respond to the CAP request. If a CAP is not returned, and no communications with Medical Review are occurring regarding an extension, the percentage of claims under review may increase.

Here are some suggestions about what to include in a CAP:

• A timeline; with start and completion dates and periodic evaluation dates
• List of staff involved and how they contribute to the plan
• Goals and measurements of success; along with alternatives if original goals falter
• Outline for staff to follow
• Points of Contact (including name, title and telephone number) for contractor follow up
• Specific, concrete interventions to address issues identified

A good approach is to begin with each denial reason and work backwards; create a plan to resolve each of the reasons for the denials.

We will notify you after we receive and review of the CAP—whether or not the CAP is acceptable, and if unacceptable, we will make recommendations to improve your proposed CAP.