Florida Commission for the Transportation Disadvantaged (FCTD) CTC/STP Monitoring Update

1. Florida Commission for the Transportation Disadvantaged (FCTD)CTC/STP Monitoring Update Jeff Barbacci, Audit Shareholder Al Altun, Audit Manager Thomas Howell Ferguson P.A. 2615 Centennial Boulevard, Suite 200 (850) 668-8100

2. Presentation Outline • Introductions • Monitoring Overview • Planning • Fieldwork • Reporting • Analysis of Issues Identified From Completed Visits • Closing Remarks

3. Monitoring Overview Three types of entities being monitored: • Community Transportation Coordinators (CTC’s) • Subcontracted Transportation Providers (STP’s) • Combination CTC/STP – This is the case when there is only a CTC in a given county and the CTC has a Memorandum of Agreement (MOA) with the FCTD for non-sponsored services and a contract with the FCTD for Medicaid services.

4. Monitoring Overview (continued) Community Transportation Coordinators (CTC’s) Governed By: • Florida Statutes chapter 427.0155 • Florida Administrative Code Rule 41.2 • Florida Administrative Code Rule 14.90 • Transportation Disadvantaged Service Plan (TDSP) • System Safety Program Plan (SSPP) • MOA with FCTD • Other internal CTC Policies

5. Monitoring Overview (continued) Subcontracted Transportation Providers (STP’s) Governed By: • Florida Administrative Code Rule 14.90 • System Safety Program Plan (SSPP) • Medicaid Contract with FCTD • Other internal STP Policies Combination CTC/STP • Governed by all referenced listings for both CTC’s and STP’s.

6. Planning • A phone call is made to the CTC/STP by the Thomas Howell Ferguson P.A. (THF) engagement manager to verbally confirm the visit dates. • A follow up confirmation email is sent to the CTC/STP with two attachments: • Documents to be Provided by client listing (PBC list). • Internal Control Survey (Survey) • Confirmation email includes the name and contact information for the THF Monitor that will perform the visit. • All PBC list documents and the completed Survey are due to the THF Monitor, in electronic form where feasible, two weeks prior to the start date of the monitoring visit. • CTC/STP can contact the THF Monitor for any questions with regard to the PBC list, Survey, or general monitoring process.

7. Planning (continued) • A sample of items on the PBC List: • Listing of CTC/STP and Operator drivers. • Listing of rider beneficiaries for a given date. • Listing of operator contracts. • Listing of grants. • Listing of vehicles. • Copy of the TDSP. • Copy of the SSPP. • Copy of MOA and Medicaid Contract with the FCTD, as applicable. • Copy of Rider Brochure/Guide. • Copy of internal policies and procedures for the CTC/STP. • Copy of complaint process and form. • Copy of the most recently completed TD Rate Calculation Model and any supporting documents, along with any policies and procedures. • Copy of the most recent audited financial statements.

8. Planning (continued) • THF Monitor begins planning the visit by reading TDSP, SSPP, and completing the planning sections of the monitoring tool. • THF staff interviews 15 riders. • The week preceding the start of the monitoring visit, each CTC/STP will receive an email from the Monitor identifying: • The eligibility files needed for testing on the first day of fieldwork. • The driver files needed for testing on the first day of fieldwork. • The contracts needed on the first day of fieldwork. • The five internal control questions with a “yes” response selected for testing. • The address where the Monitor will arrive on the first day of fieldwork. • The time of the entrance conference. • PBC listing items still needed.

9. Fieldwork First Day • Entrance conference: Performed the morning of the first day to provide an overview of monitoring tasks. One member of management is required to attend. • Eligibility Files Testing: Monitor identifies the eligibility attributes through reading the TDSP and the Medicaid Contract, as applicable, and performs testing for the sampled riders. • Driver Files Testing: Monitor identifies the requirements through reading applicable statutes/rules, the TDSP, the SSPP, the MOA, and the Medicaid Contract, as applicable, and performs testing for the sampled drivers. • Contract testing: Monitor performs contract testing of operator contracts. • At the end of the day, the Monitor provides a summary of any non-compliance issues identified.

10. Fieldwork (continued) Second Day • Monitor performs an on-site observation of the system by taking a ride on one of the buses/vans (usually no longer than two hours). • Monitor randomly selects a vehicle off the CTC/STP or Operator lot to perform an American with Disabilities Act (ADA) inspection. • Monitor performs internal control testing: • Monitor selects five “yes” responses and requests support documentation. • Monitor determines any existing mitigating controls for the “no” answers. • Monitor performs financial activity analysis by inspecting the audited financial statements for any indications of financial hardship, in addition to resolution actions taken by the CTC/STP with any issues identified by the Certified Public Accountants.

11. Fieldwork (continued) Second Day (continued) • Monitor performs TD rate calculation tasks: • Monitor determines if the numbers used in the rate calculation model are properly supported with the documents used. • Monitor determines if there is a documented process for completing the rate calculation model. • At the end of the day, Monitor provides a summary of any non-compliance issues identified during the first two days. • Monitor confirms the time of the exit conference for the third day.

12. Fieldwork (continued) Third day (usually only a half a day) • Monitor wraps up the engagement file. • Monitor determines if there are any FCTD level findings or suggestions that will need to be included in the management letter or communicated verbally to TD. • Monitor prepares the exit conference memo and distributes to the CTC/STP and the FCTD at least one hour prior to the exit conference call. • Monitor conducts exit conference, FCTD program staff attend via conference call. • The CTC/STP representative and the Monitor sign the exit conference document.

13. Reporting • Monitor prepares a draft report that is sent to the CTC/STP and the FCTD, simultaneously, within 15 calendar days after the date of the exit conference. (If it falls on a weekend, then the next business day.) Note: In some instances, the CTC/STP may have been granted a 5-day extension to submit certain documents. If this is the case, then the 15-day clock starts at the end of the 5-day extension. The extension revises the exit date. • Once the draft is issued, the CTC/STP and FCTD have seven calendar days to submit any comments. • If there are any significant changes to the original draft report another draft will be sent out.

14. Reporting (continued) • Once THF receives final report acceptance from the FCTD, the final report is issued, usually 22 calendar days after the exit conference, unless there is a special circumstance such as a need for another draft. • Along with the final report, a copy of the signed entrance and exit conference documents are emailed to the CTC/STP and FCTD. • The CTC /STP must submit a Corrective Action Plan to the FCTD Area Project Manager within 30-days after the issuance date of the final report. • Any questions regarding corrective action must first go through the FCTD Area Project Manager.

15. Analysis of Issues from Completed Visits • Completed visits as of June 30, 2010: CTC visits: 15 STP visits: 6 Most common findings: • Driver Records Testing: • No files to be examined. • Expired driver physicals. • Expired driver licenses. • No support/certificates for training received. • Hiring of drivers with a background history that is strictly prohibited per CTC/STP policies. • No refresher training provided, only during initial hiring process. • Taxi drivers and other independent contractors are not subject to regular driver physical and training requirements.

16. Analysis of Issues from Completed Visits(continued) Most common findings: (continued) • Eligibility Testing: • The eligibility criteria/attributes for non-sponsored services not clearly identified within the TDSP. • No eligibility files provided for selected riders. • The eligibility files contain only a checklist with no documented proof/support for responses. • For Medicaid services, all eligibility and gate keeping requirements are not met as required per the Medicaid contract. • Eligibility files are not updated on a regular basis, in some instances eligibility was determined five years ago.

17. Analysis of Issues from Completed Visits (continued) Most common findings: (continued) • Vehicle Issues: • Vehicles non-ADA compliant. • Vehicle safety issues. • Vehicles do not have sign posted that identifies the local toll-free number and the FCTD Ombudsman toll-free number for any complaints or commendations. • General Issues: • ADA Accessible formats are available; disclosure is not noted in the brochures/guides and/or no accessible formats are available at the CTC/STP. • CTC not meeting performance measures identified within the TDSP.

18. Analysis of Issues from Completed Visits (continued) Most common findings: (continued) • Medicaid Beneficiary Transportation Services Handbook: • Requirement per the Medicaid Contract with FCTD. • No CTC (Medicaid only)/STP has a handbook, waiting on FCTD to provide an example. FCTD has an example that is currently in the review phases with the Agency for Health Care Administration (AHCA). • Commission is aware that Monitors are writing this as a finding because it is strictly required per the Medicaid contract. FCTD will resolve during the corrective action stage. • Monitors are giving credit for information included in the rider brochure/guide. • ADA Accessible formats are available; disclosure is not noted in the brochures/guides and/or no accessible formats are available at the CTC/STP.

19. Analysis of Issues from Completed Visits (continued) Most common suggestions: • Incomplete and/or inaccurate supporting documentation is used to complete FCTD rate model. • No documented process for the completion of the FCTD rate model, such as a documents used in the process. In case of employee turnover or other unforeseen circumstances. • No mitigating controls for the “no” responses from the Internal Control Surveys. • Identification of certain quantifiable performance measures.

20. Questions for You

21. Which of the following powers or duties is not provided for in 427.0155 • Review all transportation operator contracts annually. • Establish eligibility guidelines and priorities • Develop appropriate driver training programs • Execute uniform contracts for service • Approve and coordinate the utilization of school bus and public transportation services

22. In accordance with FAC 14-90, the SSPP should address which of the following safety elements or requirements? • Coordination with RWBs for the Welfare Transition Program • Utilization of school buses and other public transportation • Performance measures • Development a transportation provider handbook for all eligible riders • None of the above

23. In accordance with FAC 14-90 how often are driver physicals required? • Annually • Semi-annually • Every other year • Upon hiring • Not required • Every three years • B and D • A and F

24. In accordance with FAC 14-90 how long are documentation of driver physicals required to be maintained? • 4 years • Not required to maintain as long as it is performed • 2 years • 5 years • 7 years

25. How far in advance of the site visit are the CTCs/STPs expected to provide monitors (THF) requested documents. • 4 weeks • 3 weeks • 2 weeks • 1 week • Day of arrival

26. Corrective Action Plans are required for which of the following and how many days? • For all monitoring report suggestions within 30 days of final report issuance • For all monitoring report findings within 30 days of final report issuance • For all monitoring report findings and suggestions within 30 days of final report issuance • For all monitoring report findings within 60 days of final report issuance

27. Corrective Action Plans should be submitted to… • Bobby Jernigan at his home address • J.R. Harding at the next Commission meeting • Karen Somerset at TD • TD area project manager • Thomas Howell Ferguson • None of the above

28. Which of the following is not a safety requirement of the ADA? • All buses should be equipment with beverage holders • All buses should be equipment safety belts • The lift must be designed to allow boarding in either direction • The lift must have 4 handrails • Controls to operate the lift must require constant pressure • None of the above • A and D • B and C

29. Which of the following is not a gatekeeper responsibility per the Medicaid contract? • Determine if transportation resources exist within the Medicaid Beneficiary’s household • Determine if there is a reason why the Medicaid Beneficiary cannot utilize his/her own transportation • Assure that the Medicaid Beneficiary is a resident of Florida and is currently Medicaid eligible. • Allow the Beneficiary to drive your own vehicle to see if they are capable of operating it. • Determine if the Medicaid Beneficiary is ambulatory, requires a mobility device, or requires a stretcher for transport.

30. What is Al’s middle name? • Alex • Martinez • Julio • Tom • Al • Emrah • Carol • Mark • None of the above

31. What levels of Insurance are required per FAC 41-2.006? • $100,000 per person and $200,000 per incident • $200,000 per person and $300,000 per incident • $300,000 per person and $400,000 per incident • $400,000 per person and $500,000 per incident • None of the above • All of the above

32. CTC and any Transportation Operator from whom service is purchased or arranged by the CTC shall adhere to which of the following standards. • Drug and alcohol testing for safety sensitive job positions • An escort of a passenger and dependent children • Vehicle transfer points shall provide shelter, security, and safety of passengers • A local toll free phone number for complaints or grievances shall be posted inside the vehicle • All of the above

33. Monitoring visit exit conferences are designed to allow for which of the following? • As a way for the monitor to say “Gotcha!” • For the CTC/STP to argue and argue until the finding is removed • To allow the CTC/STP, TD and monitors to discuss the findings and recommendations prior to issuing a report • To provide the opportunity for the CTC/STP to complain to TD about the monitors

34. Which of the following is not an acronym in the transportation environment? • SSTP • FCTD • CTC/STP • TDSP • PDAP • MOA • MPO • DOT

35. Once the timing of the site visit has been confirmed which of the following is false • The timing of the visit is always flexible – all you need to do is call THF • The visit may be rescheduled if notice is received 3 weeks prior to the visit • Call or e-mail Bobby to force him to force THF to change the date • The visit may be rescheduled if the other CTC/STP affected by the change also agrees • The visit may be rescheduled if THF schedule allows • A and C

36. Closing Remarks • Questions? Contact Information Jeff Barbacci, Audit Partner/Director of AuditThomas Howell Ferguson P.A.barbacci@thf-cpa.com Al Altun, Audit ManagerThomas Howell Ferguson P.A.Ealtun@thf-cpa.com Address and Phone/Fax Numbers: 2615 Centennial Boulevard, Suite 200 Tallahassee, FL 32308 Phone: (850) 668-8100 Fax: (850) 668-8199