Capitalizing on Your Quality Assurance Review

1. Capitalizing on Your Quality Assurance Review 2011 FCTD Annual Conference Daniel Anderson, CPA

2. Presentation Outline • Quick Recap on Monitoring • Discussion on Authoritative Guidance • Common Areas of Non-Compliance • Common Suggestions • Best Practices • Single Audit Requirements

3. Recap of Monitoring • Monitor compliance with Statutes, Contracts, Policies & Procedures • Review & Testing Approach • Monitoring Timeline

4. Authoritative Guidance • Chapter 427 • FAC 41-2 • FAC 14-90 • MOA • Powers and Duties of the CTC • Safety Requirements • Equip. & Operational Safety Standards • CTC & CTD Agreed Upon Roles

5. Authoritative Guidance • TD Trip & Equipment Grant • Medicaid Contract • TDSP • SSPP • Responsibilities for Use of TD Trust Fund Dollars • Responsibilities for Medicaid • CTC Established Polices & Procedures • CTC Established Safety Standards

6. 2009-2010 Common Findings • See Attachment 1

7. 2010-2011 Findings • See Attachment 2

8. Common Findings • TD Eligibility • Two Main Issues • Establishing and Documenting CTC determined Criteria • Providing Sufficient Documentation to Demonstrate Proper Determination was Made

9. Common Findings (Continued) • Establishing CTC Determined Criteria • Document Within Eligibility Section of TDSP • If Not Documented, No Way For Monitor To Determined if Beneficiary is Eligible or Not

10. Common Findings (Continued) • Documenting Eligibility Determination • Must provide sufficient evidence to demonstrate the correct determination was made • Paper documentation vs. System documentation

11. Common Findings (Continued) • TD Eligibility • Florida Single Audit Act Requirements • Eligibility Requirements Unique to projects, contracts or grant agreements • Entity may use a computer system for determination of eligibility benefits • Auditor required to determine whether eligibility determinations were made

12. Common Findings (Continued) • Medicaid Eligibility • Contract Establishes Eligibility • Beneficiary is a Resident of Florida & Medicaid Eligible • Also, additional Gate Keeping Criteria • Medicaid Compensable Trip • Medicaid Payer of Last Resort • No Other Form of Transportation

13. Common Findings (Continued) • Medicaid Eligibility • Documentation Criteria in CFR 42 • Section 435.902 • “Agency’s policies and procedures must ensure that eligibility is determined in a manner consistent with simplicity of administration and the best interests of the applicant or recipient” • Section 435.903 • “Agency must have methods to keep itself currently informed of the adherence of local agencies to the state plan provisions and the agency’s procedures for determination AND take corrective action to ensure their adherence

14. Common Findings (Continued) • Eligibility - What We’ve Seen in Field • Majority of CTCs have TD criteria outlined in TDSP • Not All Include “Qualifying Criteria” • Criteria Documented in Other Capacity • Ride Guide • In-take Form • Call Script

15. Common Findings (Continued) • Eligibility - What We’ve Seen in Field • In-Take Forms • FCTD Issued Form • CTC created Form • Software with sufficient documentation • Software without sufficient documentation • If insufficient documentation, determination was not properly made

16. Common Findings (Continued) • Deficiencies with Eligibility • No Direct Guidance • Cost effectiveness of “sufficient” documentation • Best Practices with Eligibility • Periodic Recertification • Periodic Self-Monitoring

17. Common Findings (Continued) • Contract Testing • Requirements per Chapter 427 • Standard Template Used • Performance Standards Identified • Requirements per TD Trip & Equipment Grant • Proper language concerning payment to subcontractors • Section 0287.0585

18. Common Findings (Continued) • Driver Records • Requirements per FAC 14-90 • CPR/First Aid determined by CTC • Other Requirements determined by CTC

19. Common Findings (Continued) • Driver Records • Main Issues Noted • Lack of/Out of Date DOT physicals • Lack of documentation for 14-90 requirements • Lack of documentation for CTC requirements • Best Practice Noted • Master Log of All Driver Training

20. Common Findings (Continued) • Bus/Van Ride & Vehicle Inspections • Main Issues Noted • No sign posted (Including BOTH Local and TD Helpline Number) • Lift Issues • Seatbelts

21. Suggestions • See Attachment 3

22. Common Suggestions • TD Rate Calculation • Documented Procedures • Sufficient Support • No or N/A Responses on Internal Control • See Attachment 4

23. Common Suggestions (Continued) • Updating TDSP • Give yourself credit for what you’re doing • Allow proper oversight • Measurable Standards/Goals • Setting accurate standard & re-evaluating • Self-monitoring against standard to determine where possible improvements exist

24. Best Practices • Multi-loading on Out-of-County Trips • Agreements with surrounding counties • GPS & Video Surveillance on Bus • Route Match Software to Maximize Loading

25. Best Practices • Simulated Bus Training Module • No duplication of trips among operators • Cross Training of Staff • Unannounced Monitoring Procedures

26. Fl Single Audit Act Requirements • Audit Threshold • Expend total amount of state financial assistance > $500,000 in entity’s fiscal year • Consider All Sources of Income • Section 217.97 (7) – Operators • Provide information regarding Single Audit Requirements • Inspect Reports of Operator, and Corrective Action to Any Non-Compliance • Require Recipient to Allow Auditor to Inspect Documentation

27. Follow-Up to Questions Asked During Presentation • Q: For CTCs that do not provide Medicaid Transportation (as there is a separate STP), what is required of the CTC regarding documentation of Medicaid in the TDSP? • A: They should, at a minimum, state who the provider is.

28. Follow-Up to Questions Asked During Presentation • Q: Since Cab drivers are exempt from being required to complete DOT level physicals, are they also exempt from other training requirements (Defensive Driving, ADA, etc.)? • A: It depends on the type of contract with the CTC and local ordinance, i.e. • Purchase Order – No, outside the system • Sub-contract – Yes, inside the system with training requirements

29. Follow-Up to Questions Asked During Presentation • Q: Do LCBs still need to monitor CTCs the same year that the FCTD monitors the CTCs? • A: Yes, the LCBs are required to evaluate CTCs annually at this time.