Jeff Barbacci, Audit Shareholder Al Altun, Audit Manager Thomas
Howell Ferguson P.A. 2615 Centennial Boulevard, Suite 200 (850)
668-8100 Florida Commission for the Transportation Disadvantaged
(FCTD) CTC/STP Monitoring Update 1 Slide 2 Presentation Outline
Introductions Monitoring Overview Planning Fieldwork Reporting
Analysis of Issues Identified From Completed Visits Closing Remarks
2 Slide 3 Monitoring Overview Three types of entities being
monitored: 1. Community Transportation Coordinators (CTCs) 2.
Subcontracted Transportation Providers (STPs) 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 Slide 4 Monitoring Overview (continued) Community
Transportation Coordinators (CTCs) 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 4 Slide 5 Monitoring Overview (continued)
Subcontracted Transportation Providers (STPs) 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 CTCs and STPs.
5 Slide 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: 1. Documents to be Provided by
client listing (PBC list). 2. 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. 6 Slide 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. 7 Slide 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. 8 Slide 9 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. Slide 10 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. Slide 11 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. Slide 12 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. Slide 13 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. Slide 14 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 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. Slide 15 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. Slide 16 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. Slide 17
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. Slide 18 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. Slide 19
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. Slide 20 20 Questions for You Slide 21 Which
of the following powers or duties is not provided for in 427.0155
21 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 Slide 22 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 Slide 23 In accordance with FAC 14-90 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 Slide 24 In accordance with FAC 14-90 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 Slide 25 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 Slide 26 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 Slide 27
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 Slide 28 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 Slide 29 Which of the following is not
a gatekeeper responsibility per the Medicaid contract? 29 A.
Determine if transportation resources exist within the Medicaid
Beneficiarys 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. Slide 30
What is Als middle name? 30 A. Alex B. Martinez C. Julio D. Tom E.
Al F. Emrah G. Carol H. Mark I. None of the above Slide 31 What
levels of Insurance are required per FAC 41-2.006? 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 Slide 32 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 Slide 33
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
Slide 34 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 Slide 35 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 e-mail 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 Slide 36 Closing
Remarks 36 Questions? Contact Information Jeff Barbacci, Audit
Partner/Director of Audit Thomas Howell Ferguson P.A.
[email protected] Al Altun, Audit Manager Thomas Howell Ferguson
P.A. [email protected] Address and Phone/Fax Numbers: 2615
Centennial Boulevard, Suite 200 Tallahassee, FL 32308 Phone: (850)
668-8100 Fax: (850) 668-8199
