OIG audit of Texas Medicaid medical transportation organizations: Part 2

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 audit report’s findings were split into two main observations. The first observation, which State of Reform reported on yesterday, dealt with MTOs validating transportation services with incomplete information.  

The second observation involved monitoring transportation providers with incomplete complaint, accident, or incident data. According to the report, “Three of the four MTOs (AMR, MTM, and LogistiCare) did not comply with all contract requirements tested for managing selected complaints, accidents, and incidents.” 

Amistad was found to have sufficiently complied with contract requirements for completing and monitoring complaint, accident, and incident data. 

While all four MTOs evaluated complaints, accidents, and incidents to monitor transportation providers performance, AMR was the lone MTO to not have defined and documented policies. 

Among the three MTOs who had established monitoring policies, the report found that some of their policies did not go far enough.   

Two MTOs with defined monitoring policies used a complaint ratio to help determine when additional monitoring or corrective actions were needed to improve the performance of transportation providers. However, one of the MTOs that had a complaint ratio did not have a process in place to ensure it identified providers or required corrective action for providers who exceeded the ratio.”

MTOs are contractually required to develop their own monitoring plans and policies for measuring transportation providers performance. Without such measures, according to the report, MTOs may not be able to ensure recipients are receiving the services to which they are entitled. 


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The report also highlighted discrepancies in complaint tracking data. 

When a complaint is received by the Medical Transportation Program (MTP), it is entered into Health and Human Services Enterprise Administrative Report and Tracking, or HEART. MTOs do not have access to HEART, forcing them to develop internal management systems for tracking and managing complaints. 

When the OIG auditors compared MTO complaint data to complaint data in HEART, they found that the data sets did not match for three of the four MTOs. 

The current arrangement of tracking and managing complaint data in both HEART and the MTOs’ internal management systems results in “duplicative efforts to track complaints when the system of record is HEART,” according to the report.

Additionally, MTOs are currently prohibited from contacting complainants to assist with the investigation during their reviews. The auditors found this policy to be flawed, writing that it “hinders the MTOs’ ability to effectively and efficiently determine appropriate complaint resolutions and causes a delay in addressing the complaints, since MTP reviews the information provided by the MTOs before determining the complaint categories.”

Underscoring the inefficiency of the process, the reports notes that if, for example, a complaint is filed with a legislator’s office, the MTO has only 24 hours to respond to MTP after reviewing the complaint, conducting an investigation, and formulating a resolution.  

To address these issues, the auditors wrote the following:

MCS should evaluate the complaint process for improvements in data accuracy and complaints management, to include:

  1. Establishing a single system of complaint records that both the MTOs and HHSC use to better manage complaints and transportation provider performance.
  2. Determining whether allowing the MTOs to contact the complainant would improve the complaint process and result in a more efficient resolution of a complaint.”

As with the first recommendation, MCS wrote that they agreed and were taking steps to enact reforms.