New Entrant Audit

Guide · the corrective action plan

What a corrective action plan for FMCSA must contain

A corrective action plan (CAP) is the document that stands between a failed new entrant safety audit and a revoked registration. The searches for "fmcsa corrective action plan template" and "sample" are carriers looking for the shape of it. Here is the shape — from §385.319 and FMCSA's own review guidance — and the timing trap that fails more plans than the writing does.

The four contents, per violation

FMCSA's CAP guidance asks the same four questions about every violation in the audit report:

Then the evidence: attach the documents that prove the steps — the new policy, the pool enrollment, the pulled records. And the whole plan closes with a statement signed by a company officer attesting to the corrective actions.

The clocks (where CAPs actually die)

The plan is due 60 days from the failure notice — 45 days for passenger and placarded-hazmat carriers (§385.319(b)–(c)). But FMCSA must also review the plan and answer inside that same window. A plan received on day 52 leaves eight days for review, a possible rejection, and a rewrite that no longer fits. Treat 15 days from the notice as your real deadline for getting a complete plan received, and keep the rest of the window as your margin for a second attempt.

A worked miniature

Violation: no random testing program (§382.305 — line 5 of the 16 lines). Cause: the carrier believed the consortium handled random selection automatically and never verified enrollment. Steps taken: consortium enrollment confirmed in writing (date), first draw completed (date), results filed. Prevention: enrollment proof and draw records are checked in the monthly file review; the expiry engine flags the annual query cycle. Effective dates: listed per step. Evidence attached: enrollment letter, draw list, test results. That is the weight a reviewer can accept.

Templates vs. builders

A downloaded template gives you the headings. What it cannot give you is the contents — your cause, your dates, your evidence — because those live in your files. The CAP builder in New Entrant Audit starts from your failed lines, pulls the evidence already in your vault, and exports the plan in the §385.319 shape for you to review and submit yourself. No software submits it for you: the plan is the carrier's word, given by the carrier.

Questions, answered

Can I send the CAP before the notice arrives?

The duty runs from the notice's date. Fix everything the moment the audit ends — but the plan itself is filed against the notice, inside its clock.

What if FMCSA rejects my plan?

If time remains in the window, correct and resubmit — another reason the 15-day rule matters. If the window closes with no acceptable plan, §385.325 revokes the registration; reapplication opens 30 days later.

Is a CAP the same as an appeal?

No. An appeal (administrative review, §385.319(d)) argues the audit was wrong and has its own 15-day clock. A CAP accepts the findings and fixes the carrier. They are different doors; most carriers need the CAP door.

This software rehearses your audit and flags what an auditor would flag. It does not certify compliance, and it is not the audit. FMCSA decides.