7.1        Communication of DBHDS-OL Corrective Action Plans to MCOs suggests that a CAP is relevant to one or more individuals who are associated with a particular MCO – obviously that will most likely not be true.  Individuals are not (for HIPAA reasons) identified in a CAP.  By having a secondary review by all six MCOs – using different formats, with different criteria when it is possible that none of their clients were involved will be an expensive, and time-consuming exercise for any provider months into the future!

              Any of the MCOs will be entitled to use their own criteria for review, response, and for any requirements for “corrective action”, while possibly none of the specific citations are relevant to either an individual supported by the MCO or a service paid for by the MCO.   

              Adding a requirement (which will also require monitoring by an entity with authority to do so) will not make a material difference for any provider inclined to skirt the edges of the rules, but will add an additional burden for all providers who make every attempt to comply.  How will you know, and how will you monitor, and what are the consequences for non-compliance?