On August 9, 2016, the Department of Health (DOH) issued a memo summarizing changes effecting OPWDD’s Intermediate Care Facilities (ICF/IDDs) and the following Medicaid HCBS Waiver services: site-based day habilitation, site-based prevocational services, Individualized Residential Alternatives (IRAs) and Community Residences (CRs). The following changes are in effect as of January 1, 2017:
- The following providers were automatically enrolled by the DOH as Medicaid transportation provider: site-based day habilitation providers, site-based prevocational providers, IRAs, and community residences that directly provide transportation services.
- An ICF/IDD provider that directly provides transportation was only automatically enrolled if the provider also provides an OPWDD funder HCBS Waiver service. Those that do not provide HCBS Waiver services were required to complete an enrollment form by October 1, 2016.
- Transportation subcontractors were not automatically enrolled as Medicaid transportation. Enrollment for subcontractors will occur on a rolling basis as contracts expire. A subcontractor is required to be enrolled as of the expiration date of its existing contract.
- OPWDD providers utilizing subcontractors are responsible for ensuring their subcontractors are enrolled as Medicaid Transportation Providers.
- All enrolled providers and subcontracted transporters must have drivers enrolled in a License Event Notification Service (LENS) program, or a similar program that provides automatic updates of motor vehicle infractions. Participation in such a program will be required within 12 months from the date of enrollment as a Medicaid transportation provider.
- Although there is no prescribed format, documentation related to transportation services provided by OPWDD HCBS waiver providers is required to be maintained for six years from its creation date and must include the following:
- Medicaid enrollee’s name
- Date of transport
- Time of trip origination and destination (GPS data is acceptable to meet this requirement)
- Driver’s license number of the driver (including printed name and signature)
- For certified residential programs the same documentation requirements apply to agency provided or subcontracted transportation, with the following exceptions:
- Addresses are not required to be provided, however, the purpose of the trip should be included.
- The “time documentation” should consist of recording the time that the vehicle left the certified residence and the time the vehicle returned to the certified residence.
- Medicaid enrolled transportation providers who are reasonably expected to receive or claim at least $500,000 in a consecutive twelve month period of time are required to maintain a compliance plan that meets standards as determined by the Office of the Medicaid Inspector General. Additionally, all OPWDD funded providers that contract for transportation services are required to ensure that the Medicaid transportation provider is not listed on the Medicaid Exclusion List.
DOT Operating Authority
- All Medicaid enrolled transporters utilizing ambulette vehicles must obtain Department of Transportation (DOT) operating authority, unless the agency chose to seek and receive a waiver from this requirement from the DOT. Medicaid transportation waiver requests were required to be submitted by October 1, 2016.
- OPWDD will survey providers regarding the age and description of current vehicles. The purpose of the survey will be to establish a timeline for the phase in of retirement of vehicles.
Mahnaz Cavalluzzi, CPA
Mahnaz has been a member of Cerini & Associates’ audit and consulting practice area for over 8 years where she focuses on serving nonprofit organizations, education, and healthcare clientele. Mahnaz has experience in financial statement audits, financial statement reviews, tax return preparation, cost report filing, and other consulting. Mahnaz brings her expertise, diversified background, and helpful approach to all of her engagements.