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

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

Monitoring Overview Three types of entities being monitored: 1. Community Transportation Coordinators (CTC’s) 2. Subcontracted Transportation Providers (STP’s) 3. 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. 3

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

Monitoring Overview (continued) Subcontracted Transportation Providers (STP’s) Governed By:  Florida Administrative Code Rule  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. 5

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 is sent to the CTC/STP with two attachments: 1. Documents to be Provided by client listing (PBC list). 2. Internal Control Survey (Survey) Confirmation 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. 6

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. 7

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 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. 8

Fieldwork 9 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.

Fieldwork (continued) 10 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.

Fieldwork (continued) 11 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.

Fieldwork (continued) 12 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.

Reporting 13 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.

Reporting (continued) 14 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 ed 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.

Analysis of Issues from Completed Visits 15 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.

Analysis of Issues from Completed Visits (continued) 16 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.

Analysis of Issues from Completed Visits (continued) 17 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.

Analysis of Issues from Completed Visits (continued) 18 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.

Analysis of Issues from Completed Visits (continued) 19 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

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

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

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

In accordance with FAC how long are documentation of driver physicals required to be maintained? 24 A. 4 years B. Not required to maintain as long as it is performed C. 2 years D. 5 years E. 7 years

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

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

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

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

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

What is Al’s middle name? 30 A. Alex B. Martinez C. Julio D. Tom E. Al F. Emrah G. Carol H. Mark I. None of the above

What levels of Insurance are required per FAC ? 31 A. $100,000 per person and $200,000 per incident B. $200,000 per person and $300,000 per incident C. $300,000 per person and $400,000 per incident D. $400,000 per person and $500,000 per incident E. None of the above F. All of the above

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

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

Which of the following is not an acronym in the transportation environment? 34 A. SSTP B. FCTD C. CTC/STP D. TDSP E. PDAP F. MOA G. MPO H. DOT

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

Closing Remarks 36 Questions? Contact Information Jeff Barbacci, Audit Partner/Director of Audit Thomas Howell Ferguson P.A. Al Altun, Audit Manager Thomas Howell Ferguson P.A. Address and Phone/Fax Numbers: 2615 Centennial Boulevard, Suite 200 Tallahassee, FL Phone: (850) Fax: (850)