Corrective action plans: what brokers and states expect after a finding

What sets one off

A CAP starts with a finding: something a broker, plan, or state saw that falls short of your contract or its service standards. The common sources:

• Audits and inspections. MTM’s Pennsylvania agreement commits providers to quality and compliance programs, including building and following corrective action plans, and to unannounced audits and inspections. Missing a document deadline alone can cost a provider its place in the network. See how to pass a broker audit.
• Complaint patterns. CareOregon’s brokerages track the cause of each grievance and incident, and a trend tied to the provider as a whole can lead to a CAP. WellTrans takes a driver or attendant off Indiana trips after two complaints within five business days until a plan it approves is in place. The broker complaints guide walks through a response.
• Performance numbers. In February 2020, Connecticut’s broker at the time began placing every provider below 95 percent on-time on a CAP, a change the state auditors reported in 2021. Late pickups and missed trips are the usual measures, as covered in NEMT on-time performance.
• Point systems. MTM’s 2026 Virginia handbook scores safety, compliance, and service violations. Points last one year, and piling them up leads to corrective action, suspensions of 5 or 10 days, loss of recurring trips, or termination.

What the plan has to contain

CareOregon spells out the minimum parts of a corrective action or performance improvement plan. The list works as a checklist even when your own broker says less:

1. What caused the problem.
2. The person or people responsible for carrying out the fix.
3. The specific actions the provider will take.
4. A timeline with dated steps and a final deadline.
5. Any effect the problem had on riders getting to care.
6. How the broker will monitor performance and keep the problem from coming back.

Written status updates follow until the plan is complete. Here is a short example for a driver file finding:

Deadlines and follow-up

Timelines come from the contract. In Arkansas’s 2026 invitation for bid covering Region G, the broker must notify a subcontractor within 24 business hours of learning of unacceptable performance, impose a CAP within three business days, and confirm it is carried out within 30 days of the notice. The broker may extend past 30 days only when the subcontractor is making adequate progress. If the deadline passes without satisfactory action, the broker must end the agreement. The state hears about the poor performance from the broker and can join in setting the plan.

Brokers also watch the results. WellTrans’s 2025 agreement has providers help develop CAPs and cooperate with any data collection that measures them, and it keeps suspension, reduced trip volume, and termination available.

States are writing limits into law. Colorado’s HB26-1328, signed June 4, 2026, lets the state cap a provider’s trips or market share as part of a CAP. The restriction must rest on documented, measurable performance problems, fit the individual case, end after a set period, and follow written notice with a meaningful chance to cure.

Writing a plan that closes

• Answer the exact finding, in the broker’s words, before anything else.
• Fix the cause. A reminder email does not help if nobody owns the renewal dates, and more training does not help a schedule that leaves one van for five returns.
• Set targets someone can check, such as an on-time rate or a date.
• Attach proof: rosters, revised policies, trip reports. Keep copies in your policies and procedures file.
• Send every update on the date promised, even when the news is mixed.

Measuring the fix

A CAP about lateness closes when the numbers move. HealthRide’s trip log report lists every leg’s scheduled and actual times with on-time totals, and it exports as a print-ready PDF you can attach to the plan. For driver file findings, credential expiration reminders keep the next renewal from slipping.