Non-Emergency Medical Transportation (NEMT) Compliance Reviews County .

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Print FormTHE8-31-15NORTH CAROLINA DEPARTMENT OF HEALTH AND HUMANSERVICESDIVISION OF MEDICAL SERVICESNon-Emergency Medical Transportation (NEMT) ComplianceReviewsCounty Departments of Social Services (DSSs)A Review of Regulatory Compliance with the NC Department of Health and Human ServicesMA-2910/MA-3550 Medicaid TransportationFY 2015 - FY2016 – WORKBOOK

County InformationCounty DSS Director:Address:Phone No. (include area code)Email:TransportationCoordinator/Contact :Phone No. (include area code)Email:Back-Up to TransportationCoordinator/Contact :Phone No. (include area code)Email:Person with Access to On-LineVerifications (OVL):Phone No. (include area code)Email:DMA Medicaid ProgramRepresentative/Contact:Phone No. (include area code)Email:2

Table of ContentsOVERVIEW . 4DESK REVIEW DOCUMENTS . 6ATTENDANCE SHEET . 7NEMT SURVEY . 8NOTICES TO RECIPIENTS AND RIDER POLICIES . 9RECIPIENT ELIGIBILTY – NEEDS ASSESSMENTS . 10TRIP ELIGIBILTY AND TRACKING . 11NEMT TRANSPORTATION VENDORS. 13SAFETY AND RISK MANAGEMENT . 16REQUESTS FOR REIMBURSEMENT . 18RECORD KEEPING – TRANSPORTATION FILES . 203

OVERVIEWThe North Carolina Department of Health and Human Services, Division of Medicaid Assistance(DMA) has contracted for consultant services to perform compliance reviews of each County NonEmergency Medical Transportation (NEMT) program. The reviews will be conducted on-site followinga desk review.The reviews are to ensure that the County Department of Social Services (DSSs) are able to manage theNEMT funded programs in accordance with all applicable laws and regulations, including therequirements included in Adult Medicaid Manual MA-2910 MEDICAID TRANSPORTATION and MA3550 FAMILY & CHILDREN’S MEDICAID TRANSPORTATION and subsequent AdministrativeLetters amending those requirements.This compliance Workbook contains an outline of the compliance review process, as well as a list ofmaterials and a survey, both of which need to be submitted prior to the on-site visit.The overall compliance review process involves the following steps: Conduct the Desk Review – Review consultants will conduct desk reviews of thedocumentation that DSSs have provided in advance of the on-site review. Schedule the On-Site Visit – While the desk review is being conducted, the review consultantswill coordinate with DMA and the County DSSs to make arrangements for the on-site visit.Ten (10) business days or more prior to the on-site visit, the consultant team will call the DSSsto schedule a date for the on-site visit. This will be followed up with an e-mail to the CountyDSS Transportation Coordinators that includes the site visit date, explains the purpose of thevisit, and outlines the day’s agenda and transmits the Workbook. Desk Review Preparation - The DSS Transportation Coordinators will be asked to completetheir portion of the Workbook to be returned to the consultants at least five (5) business daysbefore the on-site review. As indicated below, the DSSs also will be asked to send someadditional information to the review team in advance of the site visit. Review Workbook and Prepare for On-Site Visit – Prior to the on-site visit, the review teamwill use the completed Workbook and other materials submitted by the DSSs to identify areasthat need to be addressed during the on-site visit. Conduct On-Site Visit - Site visits will generally require one day on-site at the DSSs offices. Ifneeds assessments are contracted to an outside entity or the agency has one or more largetransportation vendor(s), the agency may want the contractor/vendor(s) to participate in the onsite review at the DSS office. A typical site review will include:o Entrance Conference with the DSS Director, the Transit Coordinator and KeyStaff (may include the transportation contractor/vendors)o Review of Policies and Procedureso Inspection of Administrative Fileso Review of Randomly Selected Tripso Exit Interview and Draft Report4

Corrective Action Plans – The DSSs will be given 30 days to address issues identified, correctdeficiencies and submit a corrective action plan to the review consultants that verifies actionstaken or anticipated. Final Report - A final report matrix will prepared by the review consultants that includes thefindings from the draft report, corrective actions taken by the DSS, and any pending issues thatmay need DMA follow-up.5

DESK REVIEW DOCUMENTSIN ADDITION to completing the survey questions below you must remit the following information asindicated below.Note: Electronic submission of requested information is preferred. Information and the completedworkbook can be uploaded through the consultant’s website (www.ibackup.com). To sign-in, your username is ncdss and your password is nemt01. Once signed in, you can download the blank Workbook byclicking on the file. Your completed Workbook and additional materials can be uploaded using the“upload” icon then browsing to the location of the materials on your computer.Alternatively, materials can be e-mailed to Sue Knapp at KFH Group (sknapp@kfhgroup.com) or thereviewer that telephones you to set up the on-site interviews. Hard copy materials should be sent to theirattention at KFH Group, Inc, 4920 Elm Street, Suite 350, Bethesda, MD 20814. If you have questions ondata submission (technical or otherwise) you can contact either Jason Quan or Sue Knapp at KFH Group(301-951-8660).Documents1.1Written transportation policies and procedures for yourCounty, if available.2.2List of available transportation resources ranked from nocost options to most costly.3.3List of outside entities that perform NEMT administrativefunctions for your agency (e.g., subcontracts fortransportation assessments).4.4List of NEMT transportation vendors with which the DSSshas contractual relationships.5.6Copies of the contracts your agency holds with the NEMTvendors or for outside administrative functions (e.g., toperform needs assessments) listed in #3 or #4.6.7Copy of your agency’s DMA-2055 – ReimbursementRequest Form(s) for April – June 20157.A brief summary of how your agency logged and trackedtrip requests in April – June 2015 (e.g., was the agencyusing the DMA-2056 Medicaid Transportation Log oranother method)?Date SentComment6

ATTENDANCE SHEETSite VisitATTENDANCE SHEETNote: Review Team members should also 11213141516171819207

NEMT SURVEYInstructions and Submission Information: All questions contained in the survey must be answered. Responder may use N/A, if the questionis not applicable to their County. Responder should answer questions as completely as possible. Questions regarding the workbook should be directed to the consultant review team. As noted above, electronic submission of requested information is preferred. Materials and thecompleted survey can be uploaded through the consultant’s website (www.ibackup.com). Tosign-in, your user name is ncdss and your password is nemt01. Once signed in, you can downloadthe Workbook by clicking on the file. Your completed survey and additional materials can beuploaded using the “upload” icon then browsing to the location of the materials on yourcomputer. Please re-name your workbook with the name of your County.Alternatively, the completed Workbook can be e-mailed to Sue Knapp at KFH Group(sknapp@kfhgroup.com) or the reviewer that contacted you to set up the on-site visit. Hardcopy materials should be sent to KFH Group, Inc, 4920 Elm Street, Suite 350, Bethesda, MD20814.8

NOTICES TO RECIPIENTS AND RIDER POLICIESThere are a number of notices that pertain to transportation that DSSs are required to provide toapplicants and enrollees. These notices begin when an applicant is first enrolled in the program (toinform them that transportation is available to Medicaid covered services and how it may be applied forand accessed). The initial notices to recipients are explored in this section while subsequent notices,dealing with other aspects of the process, are included in sections that follow.In addition to rights, riders have responsibilities for conduct and not abusing the system through noshows. These are clearly identified up front with recipients.These notices, or documentation that they have been given to the recipient, are filed in the NEMT clientfiles.QUESTIONDSS RESPONSEOBSERVATION1. How and when is DMA-5046 - Notice ofRights/Responsibilities given toapplicants/enrollees? Mailed or face-toface? Where are these filed?2. How does your agency, as part of theNeeds Assessment process, informrecipients how to request a trip?3. What is your agency’s no-show policy forwhen a recipient misses a scheduled tripwithout good cause (illness of recipient,illness or death of recipient’s spouse, childor parent)?a.Is it consistent with the prescribedDMA No-Show Policy?b. How is the process documented?4. What is your agency’s policy regardingconduct that jeopardizes the safety of otherpassengers and/or the driver?a.Does your agency have its own policyor does it allow public transit or otherNEMT vendors to follow their ownestablished policies?b. If suspended for conduct, does youragency provide a gas voucher or makeother transportation arrangements fortrips to Medicaid eligible services forcritical services such as chemotherapyand dialysis? Please explain.9

RECIPIENT ELIGIBILTY – NEEDS ASSESSMENTSDSSs are required to conduct needs assessments for recipients that request assistance with transportationto Medicaid covered services. The DSS (or its agent) completes the assessment and determines need.This includes evaluation of the recipients resources and whether NEMT assistance is needed, the nearestappropriate medical service provider, the least expensive transportation means appropriate.Therecipient is notified of the outcome of the assessment and has the right to a hearing to appeal thedecision.QUESTIONDSS RESPONSEOBSERVATION5. Who completes the Needs Assessments?Is this done in your agency or by an outsidecontractor?6. Where are records kept and by whom?7. What processes are in place to:a. Conduct the Needs Assessment usingDMA-5047 including identifying specialneeds and exceptions.b. Verify exceptions using DMA-5048 –Medicaid Transportation Exception Verification.c. Notify recipients of the outcome of theirTransportation Assessment. DMA-5024d. Conduct re-assessments, as needed.e. Address hearing/appeals.8. Does your agency have a print-ready list ofavailable transportation resources rankedfrom no-cost options to most costly including free and other communityresources with related costs indicated fordetermining least expensive means?9. How does your agency participate in thedevelopment of the CommunityTransportation Service Plan (CTSP) foryour County?10. What does your agency do if your NEMTvendors inform you that they suspectbeneficiary fraud?10

TRIP ELIGIBILTY AND TRACKINGThe DSS (or its agent) arranges and/or provides transportation as needed. The DSS must process andtrack trip requests.The recipient contacts the DSS (or its agent) for each trip needed and all authorized trips are logged bythe DSS (or agent). The DSS transmits information regarding approved trips to the NEMT vendor. TheNEMT vendor keeps its own trip log and, once complete, the NEMT vendor invoices the DSS for tripsprovided. Reimbursement procedures and requirements are covered in a separate section (below).QUESTIONDSS RESPONSEOBSERVATION11. What hours are trip requests taken?a. Does your agency have a phone systemfor making trip requests orcancellations 24 hours a day?b. When are messages retrieved?c. Are clients instructed on the machineto call 911 if they are having anemergency?12. How far in advance are recipients requiredto request trips?13. How does your agency handle requests fortrips that are urgent?14. Does your agency use the TransportationLog DMA-2056 to track trip requests fromtrip request through disposition?15. If your agency uses an alternative database,does it include all information required onthe latest version of the DMA-2056 log?16. Does your agency document all triprequests, even if it appears obvious that theindividual will not be entitled to NEMT forthe trip requested, as long as that theindividual is eligible in some Medicaidprogram?17. How does your agency notify the recipientthat trip request was approved?18. How does your agency notify recipientsthat their trip request was denied usingDMA-5119 - Denial of Transportation Request?11

19. How is DMA-5119 given to the recipient?by telephone, in person or otherwise?20. How does your agency verify that theperson is eligible for a Medicaid programthat includes NEMT at the time of the trip?21. How does your agency verify that the leastexpensive mode and suitable to their needsis used?22. How does your agency verify that theperson is going to the nearest AppropriateMedical Provider?23. How does your agency verify that theperson is going to a Medicaid CoveredService?a. How does that agency verify that themedical service is covered by Medicaid?b. After the trip, how does your agencyverify that a Medicaid covered service wasreceived on the date of transport? IsDMA-5118 – Verification of Receipt ofMedicaid Covered Service or another methodused?24. How does your agency address multipletrip requests, such as for a series ofappointments with one medical provider?25. What hours are transportation servicesavailable?26. How does your agency ensure thattransportation is available after normalbusiness hours in cases where medicalservices required by a recipient are availableduring those hours?27. How does your agency arrange for tripswith your NEMT vendors? Transmitinformation regarding approved trips to theNEMT vendors?28. Do your agency’s NEMT vendors maintaintheir own transportation logs29. How does your agency compare thecontractor’s log to the DMA-2056 or yourinternal logs in order to ensure an accuratecount of all NEMT trips?12

NEMT TRANSPORTATION VENDORSThe DSS may have contracts with one or more NEMT vendors or providers in their community. Aspart of the desk review, the DSSs will provide a list of NEMT vendors with which they contract forservices. The DSS has a number of responsibilities with regard to these NEMT vendors that are to beincluded in the contracts including monitoring NEMT vendor performance (quality of services) andwhether the NEMT vendors have been excluded from participating in Medicaid programs.CONTRACTS WITH NEMT VENDORSQUESTIONDSS RESPONSEOBSERVATION30. Do your agency’s contracts with NEMTvendors include all provisions required byDMA (IX.I), including the certificationand/or assurance of compliance withcontractual safety and risk obligations?31. Does your agency have a contract ornegotiated rate for ambulance transportationthat is not medically necessary – to excludelife support or advanced life supportservices?NEMT VENDOR MONITORING32. How does your agency monitor NEMTvendors?a. Does your staff visit NEMT vendorfacilities periodically?b. How often?c. Does your agency conduct an annualreview of your NEMT vendors toensure all contract requirements aremet?33. How does your agency monitor servicequality?a. Late arrivals time of drivers- whetherrecipients arrived on time for appointmentb. Missed trips – vendor no-showsc. Complaints13

34. How do your vendors report on rider noshows and cancelled trips?35. Does your agency pay NEMT vendors forno-shows and wait time?a. If so, do NEMT vendors invoiceseparately for no-shows and wait time?36. How does your agency randomly review 2%of the trips on the DMA-2056Transportation Log each quarter?a. Does this review capture all modes andNEMT vendors?b. When was the most recent reviewconducted?c. What were the results of the most recentreview?14

QUESTIONDSS RESPONSEOBSERVATIONNEMT VENDOR EXCLUSIONS37. Does your agency have NEMT vendorscomplete the DMA-5124? Including anypublic transit agencies that are NEMTvendors?a. Have you added the addresses of theowners, relatives and managers to thelist of information you request from theNEMT vendors?38. How does your agency obtain disclosures of“business transaction information” fromNEMT vendors?39. How does your agency check the federal(Office of the Inspector General OIG)database) and state NC DHHS ProviderPenalty Tracking Database (PPTD)) toensure that each NEMT vendor, includingthe NEMT vendor owners and managers, isnot excluded from participation in federalhealth care programs?a. Does your agency conduct federal andstate exclusion inquiries when it negotiatesthe contract?b. On a monthly basis? How is this doneand documented monthly?c. And when the NEMT vendor reports achange?40. Is this documented on DMA-5124 – ProviderDocumentation Form? Does your agency alsocomplete DMA-5124A monthly for eachNEMT vendor, as well as print the screenfrom the database? Where are these fileskept?41. If the NEMT vendor is excluded fromparticipating in the Medicaid transportationprogram, does your agency notify theNEMT vendor in writing and place a copy inthe NEMT vendors file? Does the agencyalso notify DMA?15

SAFETY AND RISK MANAGEMENTThe DSS has a responsibility to ensure that NEMT services are safe for recipients. This includesensuring that drivers are properly licensed, have good driving records, have undergone criminalbackground checks, and are tested for drug and alcohol use/abuse. It also includes requiring adequateliability insurance in the event that a recipient is injured.QUESTIONDSS RESPONSEOBSERVATIONDRIVER SAFETY AND VEHICLE INSPECTIONS42. Does your agency maintain safe driving filesfor agency staff, agency-approvedvolunteers and recipients’ relatives andfriends who are reimbursed directly by thecounty?a. How does your agency ensure thatdrivers are at least 18 years of age(including county employees, volunteers,contactors, family members/friendsdirectly reimbursed by the agency)?b. Do these files include all the other itemsrequired by DMA?c. Are driving records of agency staff andvolunteers reviewed every 12 months?43. Are these files reviewed monthly to ensurethey are up-to-date and correct?44. Does your agency perform a criminalbackground check on all employees andagency volunteer drivers through the NCLaw Enforcement Division of NCIC?a.Does your agency disqualify driversbased on the 10 items in the policy?b. Has the agency included “health carerelated criminal convictions under yourbackground checks?c. Are these done prior to enlistment andquarterly?45. How does your agency ensure that allvehicles used to transport recipients have avalid registration and state inspection? Howare files kept?46. How does your agency ensure that itsprivate and/or public contract NEMTvendors participate in a random alcohol anddrug testing program that meets therequirements of the Federal TransitAdministration (FTA)?16

QUESTIONDSS RESPONSEOBSERVATIONINSURANCE47. For contract NEMT vendors operatingcommercial vehicles (16 passengers ormore), does your agency obtain a Certificateof Insurance documenting that the DSSDirector or designee is an “additionalinsured”? How and where are these fileskept?48. Does your agency require the minimumcoverage for common carrier passengervehicles set by the NC UtilitiesCommission?a. For Hire Vehicles (does not includepublic transit or taxi cabs) – Does youragency require 1.5M liability insurance forvehicles seating 15 passenger or less and 5M for vehicles designed to transportmore than 15 passengers, including thedriver?b. Taxicabs – Does your agency require theminimum level of insurance set by the statefor the vehicle’s particular classification orhigher as set by local ordinance?c. Agency Owned Vehicles – Does the DSScarry “Symbol 1” type vehicle insurance?d. Non-Owned Agency Coverage – If youragency doesn’t own vehicles used forMedicaid transportation, does the DSScarry Non-Owned Auto type coverage?e. DSS Staff, Volunteer and FamilyMembers/Friends reimbursed or paid totransport recipients – Does your agencyrequire the minimum set by the state fortheir vehicle’s particular classification?17

REQUESTS FOR REIMBURSEMENTThe DSS requests reimbursement from DMA for NEMT using the appropriate forms.QUESTIONDSS RESPONSEOBSERVATION49. How are your agency’s DMA-2055 Request for Reimbursement Forms prepared?50. Does your agency use the billing codes onDMA-2056 - Medicaid Transportation Log?51. Does your agency require NEMTvendors to provide the transportationbilling codes on invoices to the DSS forreimbursement?52. How often does your agency submitreimbursement requests to DMA?53. For which of the following modes doesyour agency request reimbursement:a. Reimbursement for mileage tovolunteers (volunteer provided vehicle)?A0080b. Reimbursement for mileage toenrollee, family, neighbor? A0090c. Taxi fares A0100d. Bus fares on intra and interstatecarriers? A0110e. Van service, public and privatetransportation (except wheelchair vans)?A0120f. Wheelchair van service, public andprivate transportation? A0130g. Mileage paid to caseworkers or socialworkers? A016018

h. Recipient travel expenses A0180,A0190i.Attendant travel expenses? A0200,A0210j. Ancillary Costs – parking, tolls A0170k. Ambulance (stretcher only – no lifesupport) A099954. Do you allow NEMT vendor deliverycharge for prescriptions as long as itmeets least expensive criteria?55. For Reimbursement for Travel RelatedExpenses? Do you use the state mileage,subsistence and lodgingreimbursement rates? Do you provide money for travel inadvance or after the trip is complete?19

RECORD KEEPING – TRANSPORTATION FILESThroughout the process, the DSS keeps records and documents activities. This section explores how theprocess is documented and files kept. This also is the place for the review team to record observations asthe files are reviewed on site.QUESTIONDSS RESPONSEOBSERVATIONRECIPIENT TRANSPORTATION FILES56. Does your agency keep a recipienttransportation file for each eligibleindividual or family, labeled with thecasehead’s name that contains:a. DMA-5046 - Notice ofRights/Responsibilities, or document that itwas mailed (or handed?) to recipientb. DMA-5047 – Medicaid TransportationAssessment – completed during the currentcertification period or within past 12monthsc. DMA-5048 Exception Verification Form(where applicable)d. Prior Approval Notices/documentation(where applicable) – letter (includingEPSDT service prior approvals) or name ofindividual with DMA Clinical Policy officewho verified prior approvale. DMA-5024 – Transportation AssessmentNotificationf. No Show and Suspension Notices (whereapplicable) DMA-5125 - No-Show Notice DMA-5125A- No-Show Final Notice DMA-5125B – Suspension Noticeg. DMA-5119 - Denial of TransportationRequest(s)20

NEMT VENDOR FILES57. Does your agency keep a file on eachNEMT vendor that documents they are notexcluded from participating, that contains:d. DMA-5124 – Medicaid TransportationProvider Documentatione. DMA-5124A – MedicaidTransportation Provider DocumentationAddendum to document verificationthat the NEMT vendor is not inthe Federal and/or State excludedparties databasesTRIP LOGS, VERIFICATION AND MONITORING FILES58. Does your agency keep transportation logsusing DMA-2056? If not, what log is used(please provide a copy)?59. How does your agency documentverifications that Medicaid CoveredServices were received on the date each tripwas provided?a.Is DMA-5118 - Verification of Receipt ofMedicaid Covered Service used?b. If not, what form or process is used?60. How does your agency document thequarterly 2% random review oftrips/monitoring efforts – using DMA5078 - Medicaid Transportation MonitoringReport?61. How are your agency's DMA-2055 Reimbursement Request Form filed?21

The North Carolina Department of Health and Human Services, Division of Medicaid Assistance (DMA) has contracted for consultant services to perform compliance reviews of each County Non-Emergency Medical Transportation (NEMT) program. The reviews will be conducted on-site following a desk review.

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