Audit report, Non-Emergency Transportation Program, Metro Non-Emergency Transport, Atlanta, Georgia, Medicaid provider no. 00472139A, for the year ended June 30, 1994 [June 30, 1994]

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

AUDIT REPORT NON-EMERGENCY TRANSPORTATION PROGRAM
METRO NON-EMERGENCY TRANSPORT ATLANTA, GEORGIA
MEDICAID PROVIDER NUMBER 00472139A FOR THE YEAR ENDED JUNE 30, 1994
Report Prepared By: State a/Georgia
Department ofAudilS 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 OBJECTIVES, SCOPE AND METHODOLOGY . . . . . . . 1

FINDINGS AND CONCLUSIONS
Sample Results ..... . Procedure Codes ..... . Vehicle Standards ........ . Insurance Coverage ... . Number ofVehicles .. PSC Requirements ... Drivers' Requirements ..... Business License Requirements Usual and Customary Charges Change of Address ....

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

DEPARTMENT OF AUDITS
254 Washington Street, S.W., Suite 214 Atlanta, Georgia 30334-8400
July 24, 1995

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 Metro Non-Emergency Transport, provider number 00472139A, a participant in the Medicaid Non-Emergency Transportation Program for the period July 1, 1993, through June 30, 1994. This audit was conducted in accordance with the terms ofthe 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.

CLV/by

~~
Claude L. Vickers State Auditor

1994 Audit Report: Metro Non-Emergency Transport
AUDIT OBJECTIVES, SCOPE, AND METHODOLOGY
The purpose of this audit was to determine whether Metro Non-Emergency Transport, 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, 1993 through June 30, 1994; and to determine whether Metro Non-Emergency Transport 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 procedur_e codes when billing the DMA for services; complied with Appendix G, "Minimum Vehicle Standards for Non-Emergency
Transportation Program" contained in the DMA P & P; maintained all state required insurance coverage on transportation vehicles; used the same number ofvehicles to transport recipients as the number of vehicles on file with
theDMA; 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 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 DMA requires !hat non-emergency transportation providers maintain such records as are necessary to fully disclose the extent of services provided. These records must contain a completed DMA 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 (DMA 408 form) for that claim.
The provider received payments totaling $229,346.64 for claims filed with a service date within the 1994 state fiscal year. The statistically valid sample ofDMA 408 fonns represented claims of $9,094.88, or 3.97% of dollars paid. As a result of this audit, it was detennined that none of the claims included in the sample were 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 $229,346.64, plus or minus $11,467.33 (5%), in paid claims that are not sufficiently documented to support payment ofthe claims. We recommend that the DMA seek to recoup $217,879.31 from the provider, which is the lower end of the range of the statistically detennined amount of insufficiently documented claims in the population.
The following is a list ofthe types of errors 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 fonn was provided to document the service Date of transportation service was missing

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Date oftransportation service did not match claim data Date of transportation service did not match medical certification date Provider's name was missing Provider's Medicaid number was missing Recipient's Medicaid number was missing Recipient's Medicaid number did not match claim data 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 Waiting time was not documented Waiting time was not allowable Reason for medical transportation was missing or unallowable Type transportation used was unallowable DMA 408 form was not signed DMA 408 form was signed by an inappropriate person Incorrect NET procedure code was used

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 ofincorrect procedure codes was noted during the audit. These errors were included in the sample errors identified in the previous section and were also included in determining the total amount of insufficiently documented claims.

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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 DMA 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 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 ambulances must also have some reasonable means of securing the wheelchair(s) or stretcher(s).
Four ofthe provider's six vehicles were inspected in order to determine whether the provider complied with Appendix G. Based on our inspection, we determined that:
three of the vehicles contained fire extinguishers that were not mounted within the drivers' reach; all of the vehicles contained fire extinguishers with no gauges or inspection tags; and one of the two vehicles used as wheelchair vans had no reasonable means to secure the wheelchairs.

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 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 on all vehicles for the entire audit period; and to determine if required coverage was provided for all current vehicles. Based on our audit, we determined that the appropriate insurance coverage was maintained for each vehicle for the entire audit period.

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However, the provider's vehicle insurance coverage was lapsed from September 7, 1994 through June 5, 1995.

NUMBER OF VEHICLES
Vehicle identification numbers (VIN) from each vehicle were compared to information provided by the DMA to determine if both the total number of vehicles operated and the VIN for each vehicle agreed with DMA records. Based on our audit, we determined that the number of vehicles operated by the provider and the VIN for each vehicle operated did not agree with the information furnished by the DMA. Specifically, we found that none of the provider's vehicles were on record at the DMA, and the one vehicle identified in the information furnished by the DMA was no longer in service. The vehicles inspected during the audit included two minibuses and two wheelchair vans, although no minibuses and only one wheelchair van are registered with the DMA.

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 earners apply to the Public Service Commission (PSC) for the issuance of a 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 none ofthe vehicles operated by the provider had a current PSC cab card.

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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 of initial 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.
A list of the provider's NET drivers was prepared from information obtained from the provider. A total of eight 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 physical examination or the required annual health review. Furthermore, the provider was unable to document that two drivers had a valid Georgia driver's license, or that the driving records for five 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 of our 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 if the 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 did not comply with local business license requirements. Specifically, we found that the provider had no business license for part of the

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period under audit and has no current business license. According to information obtained from the Fulton County Business License Bureau, the provider should possess a business license issued by Fulton County.

USUALAND CUSTOMARY CHARGES
OMA 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 detennine whether Medicaid patients were charged more than other patients for the same services.
Based 'on our review, we determined that the provider does not transport private pay passengers.

CHANGE OF ADDRESS
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 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 had a change of address and did not properly notify the OMA of this change. The provider's current address is: Metro Non-Emergency Transport 849 Peachtree Street, Suite I 03 Atlanta, Georgia 30308