Audit report, Non-Emergency Transportation Program, MHT of Middle GA, Inc., Ray City, Georgia, Medicaid provider no. 00602852A for the year ended June 30, 1995

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STATE OF GEORGIA DEPARTMENT OF AUDITS
254 WASHINGTON STREET ATLANTA. GEORGIA 30334

AUDIT REPORT NON-EMERGENCY TRANSPORTATION PROGRAM
MHT OF MIDDLE GA., INC. RAY CITY, GEORGIA
MEDICAID PROVIDER NUMBER 00602852A FOR THE YEAR ENDED JUNE 30, 1995
Report Prepared By: State ofGeorgia
Department ofAudits andAccounts 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 OBJECTIVES, 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 ........................................................ 5 Drivers' Requirements ..................................................... 5 Business License Requirements .............................................. 6 Usual and Customary Charges ............................................... 6 Change of Address ........................................................ 6

CLAUDE L. VICKERS
STATE AUDITOR
(404) 656-2174

DEPARTMENT OF AUDITS AND ACCOUNTS
254 Washington Street, S.W., Suite 214 ~tlanta, Georgia 30334-8400
August 20, 1996

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 ofMHT ofMiddle Ga., Inc., provider number

00602852A, 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 of the

December 1, 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 of the Georgia

Department of Medical Assistance Non-Emergency Transportation Program and is not to be used

or relied upon for any other purpose.

Resp=~

CLV/by

~ickers State Auditor

1995 Audit Report: MHT ofMiddle Ga., Inc.

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AUDIT OBJECTIVES, SCOPE, AND METHODOLOGY
The purpose of this audit was to determine whether MHT of Middle Ga., Inc., 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 MHT of Middle Ga., Inc., 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 DMA; 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 of the provider's Medicaid Trip Sheet andMedical 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 DMA requires that non-emergency transportation providers maintainsuch records as are necessary to fully disclose the extent of services provided. These records must contain a completed DMA 408 form 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 (DMA 408 form) for that claim.
The provider received payments totaling $417,463. 78 for claims filed with a service date within the 1995 state fiscal year. The statistically valid sample ofDMA 408 forms represented claims of $14,171.96, or 3.39% ofdollars paid. As a result ofthis audit, it was determined that $10,530.81 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 $310,217.33, plus or minus $15,510.87 (5%), in paid claims that are not sufficiently documented to support payment of the claims. We recommend that the DMA seek to recover $294,706.46 from the provider, which is the lower end of the range of the statistically determined amount of insufficiently documented claims in the population.
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 of the following types of errors:
No DMA 408 form was provided to document the service Date of transportation service did not match medical certification date

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Provider's name was missing Provider's Medicaid number did not match claim data Recipient'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 DMA 408 form was not signed

PROCEDURE CODES
DMA policies and procedures specify that providers must use the appropriate code as outlined in Appendix D of the DMA 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
As a condition ofparticipation in the NET program, providers must comply with requirements specified in Appendix G, Minimum Vehicle Standards for the Non-Emergency Transportation Program of the OMA Policies and Procedures manual. Appendix G requires that all vehicles used by the provider to transport Medicaid recipients contain a basic first aid kit, a class B chemical type fire extinguisher (extinguisher must have a visible gauge or annual inspection tag and be mounted in

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a bracket within the driver's reach), seat belts for all passengers, valid proof of vehicle insurance, and no hazardous debris or unsecured items. In addition to these requirements, vehicles used as wheelchair vans or non-emergency stretchers must also have some reasonable means of securing the wheelchairs or stretchers, and vehicles used to transport infants or children must contain approved child seating.
All ofthe provider's seven current vehicles were inspected in order to determine whether the provider complied with the provisions of Appendix G. Based on our inspection, we determined that one ofthe vehicles contained a fire extinguisher with no gauge or inspection tag.

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.

NUMBER OF VEHICLES
The vehicle identification number (VIN) from each vehicle was compared to information furnished us by the OMA to determine whether the number of vehicles operated by the provider and the VIN for each vehicle agreed with the OMA records. Based on this comparison, we found that five vehicles registered with the OMA were no longer in service. The vehicles inspected during the audit included seven minibuses. The OMA records indicate that the provider should have 12 minibuses.

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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 vehicle.
As part of our audit, we determined whether each vehicle operated by the provider contained a valid PSC cab card. We found that three of the vehicles operated by the provider contained no current PSC cab cards.

DRIVERS' REQUIREMENTS
DMA 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 of18 drivers were identified from the beginning ofthe audit period through the date of the 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, a physical examination within six weeks of initial employment, or the

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required annual health review. Furthermore, the provider was unable to document that three ofthe drivers possessed a valid Georgia driver's license when hired, or that the driving records for seven
drivers had been obtained prior to employment.

BUSINESS LICENSE REQUIREMENTS
As a condition ofparticipation in the NET program, providers must maintain current licenses as required by all levels of government. 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 ofthis audit report.
As a result of our audit, we determined that no business license was required.

USUAL AND CUSTOMARY CHARGES
DMA Policies and Procedures stipulate that a provider's submitted charges to the OMA must not exceed the provider's usual and customary charge to private paying passengers.
As part of our 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 charged Medicaid recipients its usual and customary rates for non-emergency transportation services.

CHANGE OFADDRESS
Instructions for completing the Provider Data Form for the Georgia Medical Assistance
Program stipulate that if any ofthe information on the form changes, the provider should submit those

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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
or a change in ownership, and if so, whether the provider properly notified the OMA of this change. As a result of our audit, we determined that the provider has not had a change of address.
The provider's current address is:
MHT ofMiddle Ga., Inc. Rt. 2, Box 260 Ray City, Georgia 31645