Rethink Corrective Action Plans
PAAS National® analysts continue to see PBMs demand pharmacies complete formal Corrective Action Plans (CAPs) in response to negative audit outcomes; particularly from MedImpact, OptumRx, and Caremark.
The demand for CAPs can be daunting, and excessive; however, CAPs may also help uncover the root causes for audit errors, allowing the pharmacy to potentially fix a systemic problem(s) that caused the negative audit outcome and prevent future non-compliance (and subsequent audit exposure).
Here is a suggested stepwise process to consider if you are faced with a demand for a CAP:
Step 1 Identify and investigate each possible unique problem to find the root cause(s)
- All possible errors should be considered until you can rule them out by process of elimination
- Obtain an external point of view (e.g., PAAS) to eliminate confirmation bias
Step 2 Develop and implement a corrective action plan for each unique root cause identified in step 1
- May include new/revised policy and procedure, new technology implementation or re-training on existing procedures
- System solutions that remove the potential for human error, and prevent mistakes from recurring, are ideal
- Designate a staff member to be the lead and develop a timeline for implementation
- There may be one or more solutions for a given root cause – identify what works for your pharmacy based on available resources
Step 3 Train staff and implement a corrective action plan
- May include a staff memo, email, or meeting
- May need formal training if new technology is implemented
- All training should be documented and include when it occurred, who was involved and what was covered
Step 4 Perform internal scheduled audits to ensure that corrective actions are working
- Document these audits both for your records and to prove to a PBM (if required) that you are following through on any promises made
- The PAAS Vault is a great place to store these internal audits for record keeping and get scheduled alerts when they’re due for completion
See the January 2023 Newsline article, Essential Elements of Corrective Action Plans for an example related to invoice audit shortages.
PAAS Tips:
- CAPs must be specific to the root cause errors identified and reasonable to implement at your pharmacy – there is no one size fits all
- A stepwise approach will help create a documented plan of action to ensure follow through
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