OIG audit of Texas Medicaid medical transportation organizations: Part 1

The Texas Office of Inspector General (OIG) recently released the last in a series of reports on non-emergency medical transportation services in Texas Medicaid managed transportation organizations (MTOs). 

Based on the audits of four MTOs — AMR, MTM, Amistad, LogistiCare — OIG auditors offered recommendations to improve efficiencies and reduce administrative burdens.

The Texas Health and Human Services Commission (HHSC) contracts with MTOs to provide non-emergency medical transportation services, which are provided to eligible Medicaid recipients who have no other means of transportation. 

The objective of the audits was to determine whether the MTOs performance in selected areas was up to par. The audit scope zeroed in on ummatched Demand Response and Individual Transportation Participant (ITP) encounters for one year, between September 1st, 2016 and August 31st, 2017.


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Demand Response transportation services are provided when fixed-route services are either unavailable or do not meet recipients’ needs. 

ITP services are provided by individuals who volunteer to provide transportation services for recipients by entering into a participation agreement with an MTO. This service allows individuals the flexibility to transport recipients in a personal vehicle to health care appointments.  

In order to support a paid claim, drivers for Demand Response must maintain logs with information — such as the number of miles driven and various pieces of identifying about the recipient — validating that transportation services were authorized and performed. 

Similarly, MTOs are tasked with, prior to processing a request for payment, verifying the information provided on the ITP Service Record.

According to the audit report, all four MTOs paid Demand Response transportation providers and ITPs for claims that were not supported by driver logs and did not always ensure the standardized logs were used before approving claims for payment.  

Of the 283 Demand Response driver logs tested, 226 (80 percent) were missing one or more contractually required data elements. In addition, at least 77 percent of 192 driver logs submitted by transportation providers on or after December 1, 2016, were not on the standardized Driver Logs. 

Of the 175 ITP mileage reimbursement forms tested, 169 (97 percent) were missing one or more data elements required by HHSC’s written policy notification, and 32 percent of 175 ITP mileage reimbursement forms tested were not on the ITP Service Record required by HHSC’s written policy notification,” wrote the auditors. 

The report noted that transportation providers may face difficulties properly and completely completing all required fields in the logs and service records. Information such as a recipient’s Medicaid number or the health care provider national identification number may be difficult to access. 

To remedy the situation, the report recommends that Medicaid and CHIP Services (MCS) “evaluate and establish the information required to support Demand Response and ITP mileage reimbursement claims. Based on the results, MCS should determine whether to continue requiring MTOs to use the Demand Response Driver’s Log and ITP Mileage Reimbursement Form in addition to the MTOs’ internal transportation management systems.” 

MCS concurred with the recommendation writing,

“MCS agrees with the recommendation and will clarify currently available options, as well as explore the feasibility to utilize internal management systems to track required elements on the documentation for demand response and ITP mileage reimbursement.”