Overview
During the audit period, MassHealth and its transportation brokers did not ensure that all nonemergency transportation services were adequately documented. Specifically, brokers could not provide trip sheets to support 18 out of 75 (24%) nonemergency transportation claims in our sample, totaling $558.70.
Without sufficient evidence of trips, MassHealth may be paying for transportation services that did not take place.
Authoritative Guidance
Section 8 (Reports and Billing) of the contracts MassHealth had with its brokers states,
Daily trip sheet identifying each scheduled One-Way Trip with a check box indicating if the Consumer was transported, canceled or was no-show and signed by the driver (and by program staff, if required). Trip sheets must include the driver’s name and vehicle license plate number listed, the date, the Consumer’s name, pickup location, time of pickup, drop off location, and time of drop off.
According to 130 CMR 450.205(A),
The MassHealth agency will not pay a provider for services if the provider does not have adequate documentation to substantiate the provision of services payable under MassHealth. All providers must keep such records, including medical records, as are necessary to disclose fully the extent and medical necessity of services provided to, or prescribed for, members and must provide to the MassHealth agency and the Attorney General’s Medicaid Fraud Division, the State Auditor and the United States Department of Health and Human Services on request such information and any other information about payments claimed by the provider for providing services or otherwise described in 130 CMR 450.205.
Reasons for Issue
According to several transportation providers and the brokers, some of the trips did not occur due to the member canceling, or some trip sheets were not completed. In addition, software updates prevented some providers from accessing the trip sheets.
Recommendations
- MassHealth should ensure that brokers maintain documentation for all transportation services provided to MassHealth members.
- MassHealth should work with the brokers to determine the amount overpaid for nonemergency transportation services.
Auditee’s Response
EOHHS Response [regarding Recommendation 1 for Finding 2]:
EOHHS agrees with the OSA’s recommendation. As noted under Finding 1’s recommendation, Brokers have implemented software that will collect and maintain trip logs, driver credentials, and vehicle credentials within a central repository which will ensure documentation for older claims are available upon request by EOHHS or external auditors. EOHHS will continue to audit brokers annually to ensure that all records and documentation are stored properly and accurately reflect the NEMT services billed to MassHealth and will explore expanding the scope of these audits to better enforce broker and transportation provider compliance. . . .
EOHHS Response [regarding Recommendation 2 for Finding 2]:
EOHHS agrees with the OSA’s recommendation. When evidence suggests transportation may not have been provided as claimed, brokers are to only pay for transportation services where the vendor can provide trip logs or [Global Positioning System (GPS)] to verify trip occurrence. If trip logs or GPS are not presented, then payment will not be made to the vendor. EOHHS will review the OSA’s findings and recoup any overpayments where the brokers and transportation providers were unable to produce documentation reflecting the transportation billed to MassHealth.
Conclusion
EOHHS is committed to addressing all findings identified in the OSA audit. We will continue to strengthen our oversight of the NEMT program through improved documentation requirements, expanded audit processes, and enhanced technology solutions. These efforts will ensure compliance with all applicable regulations while maintaining this essential service for MassHealth members.
Auditor’s Reply
Based on its response, MassHealth is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | May 8, 2025 |
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