By now, many clients are familiar with the process of payor audit findings resulting in an agreed on Corrective Action Plan (CAP).  The latest wave of activity from Cigna shows that they are now coming back around to the facilities that entered into these CAPs to determine compliance with the agreed on terms. Internal audit activity throughout the course of operations should have been consistent in order to be meaningful and meet Cigna’s requirements. Compliance is an ongoing commitment and process, not something that can be strung together in the eleventh hour.