What Is a Corrective Action Plan in NEMT? When Brokers Require One and How to Close It Out

What a corrective action plan is

A corrective action plan (CAP) is a written, dated plan to fix a problem a broker, health plan, or state found in your service. It names what went wrong, why, who will fix it, what they will do, and by when. The broker then watches your results until the plan is closed.

Brokers write it into their agreements. MTM Health’s standard provider agreement, in the January 1, 2023 version Pennsylvania posts, says you agree to take part in quality and compliance programs, including developing and cooperating with corrective action plans (section 2.T). The same section lets MTM audit you unannounced and says missing a document request deadline could get you removed from the network. The agreement also ties its performance improvement plan process to liquidated damages (section 7.A). WellTrans’s agreement, revised October 16, 2025, says you will help develop corrective action plans and cooperate with the data collection used to monitor them.

A plan is one step on a ladder, and each broker uses its own. CareOregon’s manual (February 2024) puts the plan before suspension or termination, but lets brokerages skip it when an infraction is severe enough. MTM Health’s Virginia handbook (May 2026) says infraction points lead to corrective action, suspension, or termination. Points last 1 year:

• 3 points: no access to MTM’s trip marketplace until points come off.
• 5 points: a 5-day business suspension.
• 8 points: a 10-day suspension and the loss of your recurring trips.
• 10 points: removal from MTM’s network.

When brokers and states require a corrective action plan

Program	What triggers a plan	What the rule says
Arkansas Region G NET broker, covering Pulaski, Faulkner, and Lonoke counties (DHS bid 710-26-069, issued June 19, 2026)	Any service requirement a subcontractor does not meet	The broker notifies you within 24 business hours, imposes a plan within 3 business days, and sets a deadline no more than 30 days from the notice. It may extend the deadline if you took adequate action but could not finish. It must end your agreement if you do not correct the problem, and it tells DHS.
CareOregon brokerages (manual version 1.3, February 2024)	Not following contract or service standards, such as a repeated pattern of provider no-shows, too many last-minute trip returns, or taking only the best-paying trips	The brokerage builds the plan with you. It may cut the rides offered or change your hours or service area while you work on it. Providers who will not or cannot follow it move to suspension, up to termination.
WellTrans, Indiana (manual, February 17, 2023)	A driver or attendant with 2 or more rider complaints within 5 business days	That person may not be used until a plan WellTrans approves is in place
Modivcare (credentialing reminder for out-of-network providers, posted August 2023)	Failing one of its quarterly credentialing audits	A plan with more education, and a repeat audit the next quarter. Missing credentialing rules can also cut trip volume or end the contract. Driver records must be kept 10 years and may have to be produced within 3 business days of a request.
MTM Health, Virginia (handbook, May 2026)	Falling short of a performance standard, such as on-time performance above 95 percent, provider no-shows under 0.25 percent, GPS tracking on more than 90.01 percent of trips, or returned trips under 0.5 percent, or letting driver and vehicle documents lapse	A performance improvement plan, liquidated damages, or termination from the network. Lapsed documents can also cut your trip volume, cost you payment for trips by unapproved drivers, or end in non-renewal.
Colorado (HB26-1328, in effect July 1, 2026)	Documented, material performance problems	The state may cap a provider’s trips or market share only as part of a plan, based on objective measurable criteria, individual to you, proportional, and time-limited, after written notice and a meaningful chance to fix the problem (section 25.5-1-802(10) and (11)). Once members may request a provider, which starts after all service regions are running, the broker may not steer them away from their choice unless that provider is under such caps (section 25.5-1-804(10)).

The pattern repeats across contracts: late pickups, missed trips, rider complaints, vehicle or driver documents that lapse, failed audits, and billing errors. For how brokers measure each one, see NEMT broker scorecards. For the dollar side, see NEMT broker penalties.

What a corrective action plan must contain

CareOregon’s manual lists the basic parts of any corrective action or performance improvement plan. They make a good outline for any broker’s plan:

Part	What to write	Example: late dialysis pickups
Causes	The factors behind the problem, backed by your own data	Two drivers covered three centers with chair times 15 minutes apart
Responsible person	One named person, not “management”	The dispatch manager
Specific actions	Each fix, in plain terms	Stagger the routes, add a third driver on Mondays, Wednesdays, and Fridays, and set pickups 20 minutes earlier
Timeline	A date for each action and a final deadline	New routes by the 5th, new driver by the 15th, target met by the 30th
Effect on riders	Any effect on members’ access to care and how you prevent it	Trips you cannot cover go back to the broker the day before, not the morning of
Monitoring	How the broker will check your results so it does not happen again	Weekly on-time report from GPS data, sent every Friday

CareOregon also requires written status updates on your progress and a written notice when the plan is done. Arkansas’s Region G bid adds an outside limit: 30 days from the notice unless the broker extends it.

How to answer a corrective action request

1. Read the notice closely. Write down the standard you missed, the data the broker used, and every due date.
2. Check the finding against your records. Pull trip logs, GPS, signatures, and complaint files. If the data is wrong, answer in writing with your evidence by the response date. See how broker audits work.
3. Find the real cause. Ask why until you reach something you can change, such as routing, staffing, training, or a missing document.
4. Name one owner who has the authority to make the changes.
5. Write specific, dated actions. “Retrain drivers” is weak. “Every driver completes securement training by March 10, logged in the training file” is strong.
6. Protect riders while you fix it. Say what you will do so no member misses care, such as returning trips early.
7. Pick the measure that proves it worked, the target, and how often you will report it.
8. Submit on time and keep proof of what you sent and when.

If a rider complaint started it, answer the complaint through the broker’s grievance process too. See Medicaid grievance and log each one in the free NEMT complaint log.

How to close out a corrective action plan

A plan is not closed because the deadline passed. Close it on the record:

• Send the updates the plan requires, in writing, on the dates it sets.
• Build an evidence file for every action: new route sheets, training logs, updated policies, renewed documents, and the performance reports that show the target was met.
• Send a completion notice that lists each action, the date it was done, and the proof attached.
• Ask for written confirmation that the plan is closed, and ask when any trip limits end.
• Pass the follow-up check. Modivcare, for example, repeats a failed audit the next quarter.
• Keep the whole file. MTM Health’s standard agreement requires you to keep full records of your operations under it for 10 years (section 2.S). See NEMT record retention.

If you are running out of time but have made real progress, ask for an extension in writing before the deadline, with proof of what is done. Arkansas’s Region G bid allows one when the provider has taken adequate corrective action but could not finish in 30 days.

Corrective action plans you write for yourself

You do not have to wait for a broker. OIG’s General Compliance Program Guidance (November 2023) tells small entities to name someone, such as a compliance contact or the owner, to decide whether a violation happened and what to do. The options it lists are a corrective action plan, returning overpayments, a report to the government agency, or a disclosure to OIG. It says a plan may include policy and process changes, staff education, a revised training plan, and consequences for the people responsible.

A self-imposed plan that finds an overpayment still has to repay it on time; see the 60-day overpayment rule. For the rest of a small company’s compliance program, see NEMT compliance program.