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AUDIT REPORT NON-EMERGENCY TRANSPORTATION PROGRAM
A.D.P. NON-EMERGENCY TRANSPORTATION STONE MOUNTAIN, GEORGIA
MEDICAID PROVIDER NUMBER 00610156A FOR THE YEAR ENDED JUNE 30, 1995
Report Prepared By: State ofGeorgia
Department ofAudits and Accounts Medicaid and Local Government Audits Division
254 Washington Street, S. W., Suite 322 Atlanta, Georgia 30334-8400 (404) 656-2006 Michael A. Plant, Director
TABLE OF CONTENTS
LETTER OF TRANSMITTAL ............... : . . . . . . . . . . . . . I
AUDIT OBJE.CTIVES, SCOPE AND METHODOLOGY . . . . . . . I
FINDINGS AND CONCLUSIONS
Sample Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 2 Procedure Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Vehicle Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Insurance Coverage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Number of Vehicles ....................................................... 4 PSC Requirements ........................................................ 4 Drivers' Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Business License Requirements .............................................. 6 Usual and Customary Charges ............................................... 6 Change ofAddress ........................................................ 6
CLAUDE L. VICKERS
STATE AUDITOR
(404) 656-2174
DEPARTMENT OF AUDITS AND ACCOUNTS
254 Washington Street, S.W., Suite 214 Atlanta, Georgia 30334-8400
January 27, 1997
Members of the Board of Medical Assistance, and The Honorable Marge Smith, Commissioner Department ofMedical Assistance 2 Peachtree Street, N.W., Suite 27-100 Atlanta, Georgia 30303
Ladies and Gentlemen:
This report provides the results of our audit of A.D.P. Non-Emergency Transportation, provider number 00610156A, a participant in the Medicaid Non-Emergency Transportation Program for the period July 1, 1994, through June 30, 1995. This audit was conducted in accordance with the terms ofthe December I, 1994, agreement between the Georgia Department of Medical Assistance and the Georgia Department of Audits and Accounts.
This report is intended to be used solely in connection with the administration ofthe Georgia Department of Medical Assistance Non-Emergency Transportation Program and is not to be used or relied upon for any other purpose.
CLV/by
Respectfully Submitted,
~~~
Claude L. Vickers State Auditor
1995 Audit Report: A.D.P. Non-Emergency Transportation
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AUDIT OBJECTIVES, SCOPE, AND METHODOLOGY
The purpose ofthis audit was to determine whether A.D.P. Non-Emergency Transportation, an enrolled provider in the Georgia Medicaid Non-Emergency Transportation (NET) Program, maintained adequate documentation to support claims paid by the Georgia Department ofMedical Assistance (DMA) for non-emergency transportation services from July 1, 1994 through June 30, 1995; and to determine whether A.D.P. Non-Emergency Transportation complied with the DMA policies and procedures for the NET Program in effect during that period. The specific objectives of this audit were to determine if the NET provider:
maintained sufficient documentation to adequately support claims paid by the OMA; utilized correct procedure codes when billing the DMA for services; complied with Appendix G, "Minimum Vehicle Standards for Non-Emergency
Transportation Program" contained in the Policies and Procedures for Non-Emergency Transportation Services; maintained all state required insurance coverage on transportation vehicles; used the same number ofvehicles to transport recipients as the number of vehicles registered with the DMA; complied with Public Service Commission requirements for vehicles used to transport recipients; complied with applicable requirements for NET drivers; complied with applicable business license requirements; billed Medicaid its usual and customary charges; and notified the DMA of changes in address due to a move or a change in ownership.
To accomplish these objectives, we developed a statistically valid attribute sampling plan to test a sample ofthe provider's Medicaid Trip Sheet and Medical Certification for Non-Emergency Transportation (DMA 408) forms to determine if the DMA 408 forms provided sufficient documentary evidence to support claims filed by the provider and paid by the DMA. We also interviewed provider personnel, inspected vehicles used to transport Medicaid recipients, and examined other records and documentation in order to determine if the provider complied with provisions of the DMA Policies and Procedures Manual.
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FINDINGS AND CONCLUSIONS
SAMPLE RESULTS
The OMA requires that non-emergency transportation providers maintain such records as are necessary to fully disclose the extent of services provided. These records must contain a completed OMA 408 fonn for each trip. Except for recipients receiving mental health, chemotherapy, radiation services, or dialysis, a signed medical certification must also be obtained for each trip.
A data file containing all ofthe provider's paid claims for the audit period was obtained from EDS. Based on the total number of records in this data file, a statistically valid sample size was computed, and a corresponding number of paid claims were randomly selected as our sample. For each claim listed in the sample, we attempted to locate and examine the provider's documentation (OMA 408 form) for that claim.
The provider received payments totaling $151,908.62 for claims filed with a service date within the 1995 state fiscal year. The statistically valid sample ofDMA 408 forms represented claims of $5,811.96, or 3.83% of dollars paid. As a result of this audit, it was detennined that $5,779.16 of the claims included in the sample were not sufficiently documented to support payment of the claims. Based on these results, we conclude with 95% certainty that the total population of paid claims includes $150,290.00 in paid claims that are not sufficiently documented to support payment of the claims, and we recommend that the DMA seek to recover that amount from the provider.
The following is a list ofthe types oferrors identified in the sample. In accordance with DMA instructions, any one of these errors causes the claim to be insufficiently documented. Each claim included in the amount ofinsufficiently documented claims in the above paragraph contained one or more ofthe following types of errors:
No OMA 408 form was provided to document the service Date of transportation service did not match medical certification date Provider's name was missing Provider's Medicaid number was missing
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Recipient's Medicaid number was missing Recipient's Medicaid number did not match claim data Escort's name was missing Place of pickup was missing or inappropriate Destination was missing or unallowable Odometer readings were missing Number of miles billed exceeded the number of miles documented Mileage was unallowable or unreasonable for claimed destination Reason for medical transportation was missing or unallowable Type transportation used was missing or unallowable OMA 408 form was not signed OMA 408 form was signed by an inappropriate person
PROCEDURE CODES
OMA policies and procedures specify that providers must use the appropriate code as outlined in Appendix D of the OMA Policies & Procedures Manual when billing for services.
Our audit included a review of the NET procedure code associated with each claim in the sample. We compared the procedure code billed for each claim to the provider's documentation in order to determine ifthe appropriate code was used. The use of incorrect procedure codes was not noted during the audit.
VEHICLE STANDARDS
None of the provider's vehicles were inspected because the provider ceased business operations effective July 1, 1996.
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INSURANCE COVERAGE
As a condition ofparticipation in the NET program, providers must maintain all state-required insurance coverage. The Georgia Public Service Commission requires minimum liability vehicle insurance coverage as follows: $100,000 bodily injury each person, $300,000 bodily injury each accident, and $50,000 property damage each accident.
Our audit included a review of the provider's insurance coverage to determine whether required coverage was maintained from the beginning of the audit period through the date of our audit. Based on our review, we determined that the required insurance coverage was maintained for the entire period. However, only one vehicle was listed on the provider's insurance policies from June, 1994 through June, 1996.
NUMBER OF VEHICLES
The vehicle identification number (VIN) from each vehicle identified from the provider's records was compared to information furnished us by the DMA to determine whether the number of vehicles operated by the provider and the VIN for each vehicle agreed with the DMA records. Based on this comparison, we determined that the number ofvehicles operated by the provider and the VIN for each vehicle operated did not agree with the information from the DMA. Three vehicles were registered with the DMA, but the provider had documentation that only one of those vehicles existed.
PSC REQUIREMENTS
DMA Policies and Procedures require that NET providers maintain current licenses, permits, or certifications as required by all levels of government in Georgia for operation of a vehicle. The State ofGeorgia requires that intrastate motor carriers apply to the Public Service Commission (PSC) for the issuance ofa vehicle registration and identification stamp and cab card (Form G). A current, original Form G, with registration and identification stamp affixed, must be maintained in each
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vehicle. We inspected no vehicles because the provider is no longer in business. We did obtain
information from the PSC that the provider purchased three PSC stamps in 1995 and one stamp in 1996. However, the provider was able to furnish us with copies of only one cab card with stamp attached for each of those years.
DRIVERS' REQUIREMENTS
OMA Policies and Procedures provide that each NET driver must possess a valid Georgia driver's license, receive a pre-employment health screening and physical examination by a physician within six weeks ofinitial employment, and receive an annual health review if driving responsibilities account for 40% or more of that driver's work time. In addition, any driver who operates a wheelchair van or minibus that is designed to carry sixteen or more persons including the driver is required to possess a class C driver's license. For any driver hired after August 1, 1988, the provider must document that a driving record was obtained for that driver prior to employment. Effective July 1, 1989, non-emergency ambulance attendants must have training in cardiopulmonary resuscitation (CPR) or first aid.
A list of the provider's NET drivers was prepared from information obtained from the provider. A total of six drivers were identified from the beginning of the audit period through the date ofthe audit. For each driver identified, we determined whether the provider complied with the driver's requirements stated in the previous paragraph.
As a result ofour audit, we determined that none ofthe drivers had received the required preemployment health screening or a physical examination within six weeks of initial employment, and that one driver had not received the required annual health review. Furthermore, the provider was unable to document that four ofthe drivers possessed a valid Georgia driver's license when hired, or that the driving records for four drivers had been obtained prior to employment.
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BUSINESS LICENSE REQUIREMENTS As a condition ofparticipation in the NET program, providers must maintain current licenses
as required by all levels ofgovernment. Many local governments in Georgia require that businesses pay an annual fee in order to obtain a business license.
As part ofour audit, we determined whether the provider complied with local business license requirements during the period under audit and through the date of this audit report. We examined all business licenses to determine ifthe provider was properly licensed during the periods reviewed, and to determine if the business address agreed with the provider's address on file with the DMA.
As a result of our audit, we determined that the provider complied with all business license requirements, and that the provider's business address agrees with the address on file with the DMA.
USUAL AND CUSTOMARY CHARGES
DMA Policies and Procedures stipulate that a provider's submitted charges to the DMA must not exceed the provider's usual and customary charge to private paying passengers.
As part ofour audit, we reviewed the provider's transportation charges for both Medicaid and non-Medicaid patients in order to determine whether Medicaid patients were charged more than other patients for the same services.
Based on our review, we determined that the provider's usual and customary rate could not be determined because no records were maintained for non-Medicaid passengers.
CHANGE OFADDRESS
Instructions for completing the Provider Data Form for the Georgia Medical Assistance Program stipulate that ifany ofthe information on the form changes, the providershould submit those changes to the Provider Enrollment Unit in writing.
As part of our audit, we determined if the provider had a change of address due to a move
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or a change in ownership, and if so, whether the provider properly notified the OMA of this change.
As a result ofour audit, we determined that the business is no longer in operation, and all mail
goes to the owner's home address. The owner's current address is:
Alfreda Parker 6734 Winter Berry Ridge Drive Stone Mountain, Georgia 30087