Corrective Action Plans: A Checklist for Success

Health care organizations are increasingly turning to corrective action plans (CAPs) to address suboptimal audit findings and correct any internal processes and/or billing practices that contributed to identified issues quickly and efficiently. 

More than simply road maps to mitigate or remediate the circumstances or conditions that contributed to problematic audit findings, CAPs also help health care organizations reduce future billing compliance risks—and significantly enhance their ability to achieve revenue integrity.

CAP Checklists

While CAPs can be essential for helping health system leaders quickly and appropriately respond to problematic audit findings, not all are the same. A quality CAP will encompass several key elements, including:

1. Identification–the originating incident, or the reason for the audit
2. Evaluation–reviewing the incident to determine what triggered the audit (the who, what, when, how, and why)
3. Root Cause Analysis–determining the specific cause of the negative findings 
4. Action Plan–devising the specific response strategy
5. Implementation–enacting the response strategy and any remediation actions
6. Follow-up or Post-Mortem–evaluating the effectiveness of the response, identifying lessons learned, and determining any targeted education opportunities to ensure improvements are permanent

The most effective CAPs start with identifying and evaluating the various components that contributed to the audit, its impacts, and consequences. These actions are typically followed by a root cause analysis to dig deeper into the issues to reveal the underlying cause(s) so a path towards resolution can be set. 

Next is the action plan, which sets out the process for correcting the root cause, followed by the implementation phase spelling out how the plan is communicated and enacted internally, including training employees (e.g., providers) on the corrective actions. The final step is to follow up on the CAP, measuring its effectiveness in permanently resolving the issue. 

Other CAP Considerations

Along with the standard elements of a CAP, there are some additional information points that can help make navigating and following the plan easier. These include: 

• Date of the original incident
• CAP implementation date
• List of tasks required to complete each element of the CAP
• List of individuals responsible for completing and approving each task
• Description of necessary training and timeline for completion

It is also a good idea to spell out any recommended changes to policies, procedures, and forms to prevent any issues that contributed to the problematic audit findings from happening again in the future.

Finally, once the CAP has been completed, make sure the corrected claims are resubmitted and any overpayments returned, and that the appropriate organizational changes have been made to ensure the highest level of coding quality and integrity.

While the specifics of your CAP may change based on the audit findings, its structure can be put in place even before there is an incident. That way, when findings necessitate action, the CAP can quickly be implemented. 

Automating the Process

Even with a CAP to guide the process, conducting educational sessions, crafting reports, and putting corrective plans in place can be painstaking. These activities are often manual and require careful management to avoid jeopardizing the payer relationship or exacerbating any penalties. To address this, a growing number of health care organizations are automating many of the core tasks of CAPs, such as communication, deadline management, task assignment and completion, and reporting. 

Technology solutions that support CAP automation can alleviate the burden of manual task management, ensuring tasks are assigned to responsible parties and that the work is completed within the defined timeframes. Some solutions also provide document management and reporting functionality to keep key stakeholders informed of progress and to provide visual tracking of CAP outcomes, map workflows, and initiate post-CAP improvements. 

Closing Thoughts

As the pressure from both internal and external audits continues to intensify, health care organizations will find that well-designed CAPs can mitigate some of the pain by guiding incident management and response. They can also serve as comprehensive roadmaps for compliance teams to follow in response to problematic audit findings—a process that can quickly become unwieldy when undertaken manually.  

CAPs can be valuable tools not just for audit response, but also as guideposts for operational improvements to achieve revenue integrity and protect the health care organization’s bottom line.