Issuance of Corrective Action Plan
The Colorado Department of Health Care Policy & Financing (HCPF) has issued a Corrective Action Plan (CAP) to The Resource Exchange (TRE) related to compliance with certain case management requirements, including timeliness standards for assessments, authorizations, and member monitoring activities. TRE takes these findings seriously and accepts responsibility for addressing them. Over the past year, TRE has been conducting extensive internal reviews, gathering feedback from members, families, providers, and staff, and developing a new service delivery structure designed to improve accountability, consistency, and member experience. The CAP reinforces the importance of this work and accelerates its implementation. TRE is committed to transparency, continuous improvement, and ensuring the individuals and families we serve receive the high-quality support they deserve.
New Structure
As TRE has grown and the needs of our community have become more complex, we recognized that some of our internal systems and processes needed to evolve as well. Through listening sessions, operational reviews, and feedback from members, families, providers, and staff, we identified opportunities to strengthen communication, accountability, coordination, and consistency across our services. The Corrective Action Plan (CAP) has accelerated improvements that were already underway.
One of those improvements is TRE’s new Loop service structure. The Loop model is designed to create clearer accountability, stronger coordination among staff, and more integrated ways of working so that members and families experience more consistent support. The goal is to ensure that services, communication, and follow-through are not dependent on any one individual, but are supported by a stronger team-based structure.
The new structure is intended to address concerns that have been identified by both community members and regulators, including communication challenges, service coordination issues, delays in meeting some required timelines, and the need for greater operational consistency. By improving supervision, clarifying responsibilities, strengthening workflows, and identifying potential issues earlier, TRE is working to provide a more reliable and responsive experience for members and partners.
Most importantly, these changes are focused on building a stronger system, not assigning blame to individuals. TRE’s assessment found that many challenges were related to growth, increasing complexity, and processes that had not kept pace with organizational demands. The Loop structure is part of a broader effort to build a sustainable foundation that supports high-quality services, compliance, transparency, and positive outcomes for the people and communities we serve.
Questions, Feedback, and Concerns
We recognize that news of a Corrective Action Plan may raise questions for members, families, providers, partners, and community stakeholders. We believe that questions are an important part of building understanding and strengthening trust.
TRE is committed to listening, learning, and maintaining open communication throughout this process. We welcome your questions, feedback, concerns, and perspectives as we continue our improvement efforts. While we may not have every answer immediately, we are committed to sharing what we know, being transparent about what we are still working through, and providing updates as information becomes available.
As part of our commitment to transparency and continuous improvement, TRE is planning listening sessions throughout October. These sessions will create dedicated time for members, caregivers, providers, families, and other stakeholders to share feedback and perspectives that help guide our work. Session dates and details will be available soon.
If you have questions about the Corrective Action Plan or would like to share feedback, please contact us. Your input helps us better understand community needs and supports our ongoing efforts to strengthen services, improve accountability, and enhance the experience of the people we serve. This email inbox is purely for CAP concerns and feedback.
Contact
Contact@tre.org
FAQ
Why is TRE sharing information about a Corrective Action Plan (CAP)?
Transparency is important to us. We want members, families, providers, partners, and community stakeholders to understand what is happening, what we have learned, and how we are responding.
The CAP process is helping us strengthen our systems and improve how we deliver services while remaining focused on our mission of supporting people with disabilities and strengthening inclusive communities.
What is a Corrective Action Plan (CAP)?
A Corrective Action Plan is a formal process used by the Colorado Department of Health Care Policy & Financing (HCPF) when it identifies areas where a Case Management Agency is not consistently meeting contractual or regulatory requirements.
A CAP requires an organization to identify root causes, implement corrective actions, establish accountability measures, and demonstrate sustained improvement.
Why was TRE placed on a CAP?
HCPF determined that TRE was not consistently meeting required timelines in several case management activities and identified concerns related to timeliness, responsiveness, and service delivery.
As a result, HCPF required TRE to complete a Corrective Action Plan and demonstrate measurable improvement.
Is this a serious matter?
Yes.
A CAP indicates that TRE did not consistently meet certain contractual expectations, and we take that responsibility seriously. At the same time, the CAP provides an opportunity to make improvements that strengthen accountability, consistency, and service quality over the long term.
Did these issues come as a surprise to TRE?
No.
Many of the challenges identified through the CAP reflected concerns TRE had already been examining through internal reviews, complaint analysis, listening sessions, operational assessments, and organizational planning. The CAP reinforced the urgency of work that was already underway.
What caused these challenges?
Our analysis indicates there was not a single cause.
TRE has experienced significant growth over time, while service requirements, regulations, technology, and operational complexity also increased. As those demands evolved, some systems and processes did not evolve at the same pace.
Our review found that factors such as organizational growth, process design challenges, competing priorities, staffing pressures, inconsistent practices, limited visibility into operations, and role clarity all contributed to the issues identified through the CAP.
Did staff members cause these problems?
No.
Our root cause analysis found that the issues identified through the CAP were not the result of isolated individual performance concerns. The focus of this work is understanding and improving systems, processes, accountability structures, and organizational design so employees have the support they need to succeed consistently.
Will members continue to receive services?
Yes.
TRE remains committed to serving members and families throughout the CAP process. Our focus is on improving systems and performance while maintaining services and strengthening the member experience.
What is TRE doing to address these issues?
TRE is implementing corrective actions, strengthening accountability measures, improving workflows and processes, enhancing operational visibility, expanding training and support, and continuing implementation of organizational changes designed to improve consistency and service delivery. These measures can identify potential issues earlier before they create barriers for members and families.
Our goal is not simply to resolve specific findings but to build systems that are sustainable, reliable, and better equipped to manage complexity in the future.
What is the Loop model?
The Loop model is a redesigned operating structure developed before the CAP was issued. It was created to address challenges TRE had already identified related to accountability, communication, role clarity, member experience, and operational efficiency. At a high level, the Loop model is built on the idea that members are best supported when teams are organized around clear roles, shared accountability, consistent communication, and stronger coordination. Rather than relying on disconnected processes or individual staff working in isolation, the model is designed to create a more connected system where needs can be identified earlier, follow-up is clearer, and members, families, and providers have a more consistent experience.
The CAP accelerated implementation of this work, but it did not create the plan.
How will TRE know whether improvements are working?
The CAP includes required corrective actions, accountability measures, reporting requirements, and ongoing monitoring.
TRE will continue tracking progress and demonstrating improvement while working with HCPF to ensure expectations are being met.
What does success look like?
Success means consistently meeting contractual requirements while delivering a high-quality experience for members, families, providers, and community partners.
It also means building stronger systems that support accountability, improve operational visibility, reduce risk, and help ensure quality service and compliance can be achieved together.
Updates
10/1/2026
As we continue implementing our Corrective Action Plan (CAP), we are making significant progress toward creating a more consistent, responsive, and sustainable service experience for members and families. The Loop model is a key part of this work, helping us strengthen teamwork, accountability, and support across our case management system.
What We’ve Accomplished
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The Loop model is nearly fully implemented across TRE’s case management teams. More than 400 case management staff have transitioned into the new structure and completed initial training, creating a stronger foundation for coordinated member support. A few staff remain working in the previous structure to ensure no outstanding backlogs.
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Dedicated support teams are helping case managers focus on members. Additional document processing staff are assisting with administrative work and information management, helping ensure records are accurate and information is transferred efficiently into the Vault system.
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Staff are building new skills to better support members. All case management staff have completed initial PAR training, expanding their ability to support authorization and service planning processes. Ongoing coaching and training are continuing to build staff confidence and expertise.
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Backlog reduction efforts are showing progress. Additional resources have been added to support PAR processing and monitoring activities, helping reduce outstanding work while allowing teams to transition successfully into the new model.
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Strong partnerships continue to guide this work. TRE is collaborating closely with HCPF and advocacy organizations to support a smooth transition, share information, and help members and providers navigate changes with confidence.
How the Loop Model Supports Our Goals
The Loop model is helping TRE build a more responsive, reliable, and sustainable case management system. By combining dedicated points of contact with team-based support, the model strengthens communication, improves continuity, and ensures members have access to support when they need it.
We’ve heard your feedback and understand that many members and families have questions about how the Loop model will improve their experience. To help explain the approach, we’ve included the graphic below.






With the Loop model, you’ll continue to have a primary contact who knows you and your needs, while also benefiting from the support of a broader team. This approach helps reduce service interruptions, improves responsiveness, and creates a more consistent member experience.
Before the end of the month, your Loop team will contact you with information about your dedicated team members, including phone numbers, email addresses, and the best ways to connect with them.
Thank you for your continued feedback and partnership as we work to strengthen the quality, consistency, and responsiveness of services for members and families. As we continue implementing our Corrective Action Plan (CAP), we are making significant progress toward creating a more consistent, responsive, and sustainable service experience for members and families. The Loop model is a key part of this work, helping us strengthen teamwork, accountability, and support across our case management system.
We invite members, families, providers, and community partners to share feedback and ask questions during our upcoming listening sessions. Please note that the sessions are geared towards specific audiences and have options for virtual, in person, and location-specific feedback.
Upcoming sessions in October:






