What is the deadline for a corrective action plan?

Whatever the notice or contract allows, which is often less than three weeks. Mercy Care in Arizona wants a plan within 15 business days of a noncompliance notice and expects the approved plan to start right away. In its Tennessee network, Verida sends a 10-day written cure notice that calls for a plan. If a notice gives no date, ask for one in writing and send the plan before it.

Can I dispute the finding instead of writing a plan?

Plan on answering it either way. Mercy Care's manual says corrective actions and notices to cure are not open to dispute, but it still asks providers to tell it when they believe a deficiency is wrong, with the facts and the contract terms behind that view. Send any dispute along with the plan rather than in place of it, so the deadline is still met.

Who should sign the plan?

The owner or the person who runs compliance, and that same person should own the follow-up. OIG's compliance guidance for small health care entities says to name someone, such as the compliance contact or a company leader, to judge whether a violation occurred and how it should be corrected. Choose someone with authority over schedules and staff, since most fixes change one or the other.

What if the finding means some trips should not have been paid?

Then repaying the money is part of the plan. OIG's guidance lists refunding overpayments among the corrective actions, and federal law requires returning a Medicare or Medicaid overpayment within 60 days after it is identified. MTM's Virginia handbook ties expired driver documents to losing payment for the trips those drivers ran, so list the affected trips in Part B before you total anything.

What happens when the plan does not fix the problem?

Expect fewer trips first, then suspension or removal. Verida may take a Tennessee provider out of its network when a plan is not accepted, is not carried out, or leaves performance poor after coaching. Georgia goes further: its Medicaid manual requires the state's broker to end its agreement with any provider that fails to take satisfactory corrective action in the required time. MART lowers a provider's trip capacity in steps while its plan runs.

Corrective Action Plan Template for NEMT Findings

Before you fill it in

Start from the notice. Copy the finding into Part A exactly as the payer wrote it, along with the standard or contract section it cites, the records the reviewer used, and the due date. Then answer that finding and no other. What triggers these plans and the parts payers expect are covered in our glossary entry on the corrective action plan; this page is the form itself, with a worked example.

Payers want the cause fixed, not just explained, and the federal rule behind their own compliance programs says the same. A Medicaid health plan, and any subcontractor it hands claims payment to, must correct compliance problems “promptly and thoroughly” to reduce the chance they recur (42 CFR 438.608(a)(1)(vii)). A plan that only explains the trips named in the notice leaves the payer with nothing to show for that.

Give the plan one owner. OIG’s General Compliance Program Guidance (November 2023) tells small health care entities to designate someone, whether the compliance contact or a company leader, to decide whether a violation exists and what it will take to correct it. That person signs Part F and sends every update.

The template

Part A: The finding

Field	Entry
Broker, health plan, or agency
Notice date and reference number
Finding, copied word for word
Standard or contract section cited
Period and records the reviewer used
Plan due date and how to submit it
Effect on riders (missed or late appointments, complaints)
Plan owner (name, role)

Part B: Root cause

Question	Answer
What happened, with numbers
Where it clusters (drivers, vans, times of day, facilities)
Why it happened (keep asking why until the answer is something you control)
Why your own checks did not catch it
Other trips, drivers, vans, or brokers with the same exposure
Trips billed that may need to be repaid

Part C: Actions

#	Action	Owner	Start	Due	Proof of completion
1
2
3
4
5

Part D: Monitoring

Measure	Baseline	Target	Where the number comes from	How often	Through (date)

Part E: Status updates

Date sent	Sent to	Actions finished	Actions behind, with new date	Measure this period

Part F: Closure

Item	Entry
All actions finished (date)
Target met for the period (dates and result)
Overpayments refunded, if any (amount, date)
Policy, schedule, or training changes on file (where)
Closure letter from the payer received (date)
Signed by the plan owner and date

A filled example: late morning pickups

This example is made up. The company, numbers, and dates show how a finished plan reads; they do not describe a real provider.

Part A. The broker’s quarterly report says the provider’s on-time pickup rate for July through September was 86 percent, 354 of 412 pickups, against a 95 percent standard. Three dialysis riders reached their chairs over 15 minutes late on seven of those mornings. The plan is due 15 business days after the notice.

Part B. The answers, asking why until the cause is something the company controls:

58 pickups were late, and 41 of them fell between 6:00 and 8:30 a.m. on vans 2 and 4.
Drivers reached the second and third morning stops 10 to 25 minutes after the scheduled time.
The standing orders on those vans were spaced 15 minutes apart, while the trip records show the drive between the first two stops averaged 22 minutes.
The times were set when both vans covered a smaller area, and nobody rechecked them when two new dialysis riders joined in August.
On-time numbers were read only when the broker’s quarterly report arrived, so the slide went unnoticed for three months.

Same exposure: van 5’s afternoon dialysis returns use the same 15-minute spacing.

Part C. Actions:

#	Action	Owner	Due	Proof
1	Re-time every standing order on vans 2, 4, and 5 from last month’s actual drive times	Lead dispatcher	Day 5	Old and new schedules side by side
2	Move two 6:30 a.m. pickups to a third van running 6:00 to 9:00 a.m.	Owner	Day 10	Revised standing orders and driver shifts
3	Check the drive from the previous stop before accepting any new standing order	Lead dispatcher	Day 10	Written dispatch procedure, signed by each dispatcher
4	Drivers call dispatch as soon as they expect to be late; dispatch then warns the rider and facility, and the broker where the contract requires	Operations manager	Day 10	Training sign-in sheet
5	Owner reviews on-time pickups every Monday	Owner	Weekly from day 7	Initialed weekly report

Part D. Monitoring:

Measure	Baseline	Target	Source	How often	Through
On-time pickups	86% (354 of 412)	95% or better	Trip log, scheduled against actual pickup time	Weekly	End of next quarter
Late pickups, 6:00 to 8:30 a.m.	41 in the quarter	Fewer than 5 a month	Same	Weekly	End of next quarter

The usual causes of late pickups, and how on-time rates are counted, are covered in NEMT on-time performance.

Deadlines payers and brokers set

No single deadline applies. Each payer writes its own, and some start with a warning before any plan is due. These come from current manuals and contracts:

Payer or broker	What triggers a plan	Deadline and what follows
Mercy Care, Arizona health plan (July 2026 manual)	Any contract breach; timely trips under 95 percent in a quarter	Plan due 15 business days after notice; the approved plan starts at once
Verida, BlueCare Tennessee network (October 2026 manual)	Excessive grievances, or a failed grievance inspection or driver check	10-day written cure notice requiring a plan; the driver or van stays out of service until fixed
MART, Massachusetts human service transportation (July 2025)	Complaints above 1 percent of scheduled trips	Warning after month 1; a 60-day plan with capacity cut to 80 percent from month 3
Modivcare, out-of-network providers (August 2023)	Failing a quarterly credentialing audit	Plan with extra training; the audit is run again the following quarter
MTM, Virginia Medicaid (handbook approved August 2026)	Missing a performance metric, such as the 95 percent on-time standard	Liquidated damages, an improvement plan, or network termination

Grievances in Verida’s Tennessee network run on an even shorter clock: the provider has 24 hours to answer one in writing. WellTrans’s agreement gives 10 days to cure a material breach after written notice before a 30-day termination can follow. How the capacity cuts and fines in these contracts add up is laid out in broker penalties and sanctions. When a rider complaint set off the finding, the first written reply is its own step, explained in handling complaints a broker sends you. The written warning that starts a cure period is a cure notice.

When the finding involves money or lapsed credentials

Two kinds of findings need more than an operational fix.

Trips paid that should not have been. OIG’s guidance lists refunding overpayments as part of corrective action, and federal law gives 60 days from finding a Medicare or Medicaid overpayment to pay it back. Work out the amount in Part B and record the refund in Part F. The 60-day overpayment rule explains when that clock starts.
Drivers or vans with expired documents. MTM’s Virginia handbook warns that allowing documents to lapse can lead to an improvement plan and to nonpayment for any trip a driver ran on expired paperwork. List every trip that driver or van ran during the gap, then fix how renewal dates are tracked. The driver file checklist has a renewal tracker for each driver.

OIG also expects discipline to reach supervisors whose neglect let a problem run unchecked, not only the driver or dispatcher closest to it. Write any such step into Part C so the payer sees it was handled.

Sending updates and closing the plan

Send every update on the date in Part E, including the ones where an action is behind; give the new date and the reason. A plan closes when the measure holds, not when the last action is ticked off. MART, for example, gives back full trip capacity only after a provider meets its standard for 60 days, and keeps watching after that.

Ask the payer for closure in writing. File the plan, the proof for each action, every update, and the closure letter together, and keep the set as long as your record retention schedule requires. A monthly self-check of the kind described in our quality assurance guide is the surest way to see the next problem before a payer’s report does.

Pulling the numbers for the plan in HealthRide

Part D needs the same numbers every week, taken the same way. HealthRide’s on-time report and trip log show each leg’s scheduled and actual times, so the baseline and each weekly check come from one record. The trip log exports as a print-ready PDF to attach to each update, and expiration reminders for driver and vehicle credentials help keep a lapsed-document finding from returning. See reports.

Corrective action plan template for broker and Medicaid findings