The Arkansas Medicaid Provider Manual requires the submission and approval of a Corrective Action Plan (CAP) when requested by the Office of the Medicaid Inspector General (OMIG) in conjunction with a Program Integrity Audit Report or Review.

Arkansas Medicaid Provider Manual Section I 151.000 allows for sanctions to be imposed against a Medicaid provider in certain instances, including if a provider fails to submit an acceptable corrective action plan when requested.

What is a Corrective Action Plan?

A corrective action plan is a plan of action developed to address findings and observations that have been identified by the OMIG Program Integrity division during a field audit or a desk audit. The CAP gives a Medicaid provider the opportunity to analyze your program and identify the root causes of the identified findings and observations, and to develop a corrective action to address the findings and observations to ensure future compliance with the Arkansas Medicaid Provider Manual.

Preparing Your CAP

Should the Arkansas Office of the Medicaid Inspector General audit your program, OMIG will issue an Audit Report or Review.  If OMIG determines the provider has deficiencies, these deficiencies may be noted in the Audit Report’s Findings or Observations.

The first step in preparing your CAP is to review the specific findings/observations noted in the audit report and determine the root cause of the deficiency and the applicable Medicaid Manual sections. Your CAP should always include the following information:

• Copy and identify the specific Audit Finding/Observation that is being addressed;
• Explain the specific plan of correction for each finding/observation identified in OMIG audit report;
• Identification of the person(s) responsible for implementing and/or completing specific plan of correction for each finding/observation identified; and
• Identify a target date for implementation and completion of the specific plan of correction for each finding/observation identified.

Examples of specific plans for corrective action include:

• Developing/implementing policy and enforcement through monthly internal audits;
• Developing training manuals and conducting staff training sessions;
• Establishing scheduled monitoring.

Your CAP should not contain arguments or dispute the specific audit findings.   Please consult the Arkansas Medicaid Manual regarding your rights to appeal and reconsideration if you do not accept the Findings/Observations.   If you have a dispute with the Findings or Observations but do not wish to appeal or request reconsideration of the Audit Report or Review, please contact OMIG to discuss your concerns before submitting a CAP.

Submitting Your CAP

Once you have completed a specific plan of correction, identified the responsible person(s), and identified your target dates for each finding/observation designated in the OMIG audit report, you should submit your corrective action plan to the Arkansas Office of the Medicaid Inspector General either by mail or fax at:

900 West Capitol Ave, Suite 310
Little Rock, AR 72201

(501) 682-8350

You should consult the Arkansas Medicaid Provider Manual for your deadline in submitting a completed CAP for your specific provider type.

Expectations

Upon receipt of the corrective action plan, the Office of the Medicaid Inspector General will review the submitted CAP and determine whether the specific plan for corrective action for each audit finding/observation meets the requirements for approval. OMIG will provide a letter of acceptance or denial to the provider based upon the submitted CAP.

OMIG may deny a submitted CAP if it:

• Fails to address the specific findings/observations.
• Fails to provide a specific plan for corrective action for each deficiency;
• Contains argument or refutation of findings/observations;
• Fails to identify the person(s) responsible for implementation; or
• Fails to identify target dates, including implementation and completion dates.

A follow up site review may be conducted after the CAP is accepted to ensure compliance and implementation of the CAP. Any follow up site reviews must show adequate corrections of the deficiencies or monetary recoupment and/or referral to the appropriate oversight agencies could occur.

For more information on Corrective Action Plans, please contact the Arkansas Office of the Medicaid Inspector General at (501) 682-8349