218 Transportation Services | HCBS-5300-MANUAL

This chapter establishes the guidelines and requirements for Area Agencies on Aging that provide transportation services to older adults, people with disabilities, and accompanying caregivers through direct service, contract, or partnerships with other community entities.

These guidelines and requirements apply to transportation that:

Applicable services include those that are provided by government and for-profit providers, partnering community organizations, volunteer drivers, voucher-paid drivers, independent contractors, and sources of supplemental transportation not defined above.

These guidelines are suggested, but not required, for transportation services provided via other funds sources or outside the DHS Coordinated Transportation System.

The Department of Human Services (DHS) provides quality and cost-effective transportation to eligible consumers for vital services that enhance health, independence, and self-sufficiency. This program is managed by the Office of Facilities and Support Services (OFSS). The Coordinated Transportation System serves the following agencies:

Prior to the Coordinated Transportation system, the divisions and programs operated independently of each other, resulting in segregated services and duplication of transportation efforts. The Coordinated Transportation system began in fiscal year 1999 with the start-up in four DHS regions (Regions 1, 4, 5, and 10) and has since expanded to all 159 counties.

The structure and operating policies for the DHS Coordinated Transportation System can be found in MAN 1425 in the Office of Facilities and Support Services.

Essential trips for transportation services include the following:

It is the responsibility of each AAA to identify and, if necessary, prioritize in its Area Plan documents the types of trips to be funded during each program year.

Each AAA may determine eligibility requirements for transportation services that are funded fully or partially with Older Americans Act funds. Individuals who are served using Title III funds must meet the following eligibility requirements:

AAAs must also follow Division guidelines regarding client prioritization (MAN 5300, 118 Prioritizing Clients) when demand exceeds available resources.

Children who are in older adults’ care may also receive trips when accompanying eligible individuals as programmatic and local policies exist to support this service. The AAA or partnering organization is responsible for determining fare guidelines that apply to accompanying adults or children.

Active participants in nursing home transition programs administered through Area Agencies on Aging (or their sub-contractors) are eligible for transportation services to attend program-approved evidence-based sessions.

AAAs, contractors and partnering community organizations providing transportation services will practice sound and effective fiscal planning and management, financial and administrative record keeping and reporting. Refer to Manual 5600, 2009 Allowable Services by Fund Source and Appendix F, “Taxonomy of Services”.

Allowable Fund Sources - Fund sources that may be used for transportation services include:

Funds from Older Americans Act Title IV grants and contracts may also be used to develop transportation components of innovative programs.

Cost sharing – DAS encourages the use of cost sharing to support expansion of transportation services in accordance with MAN 5600, 2026 Cost Share.

Voluntary Contributions - The Older Americans Act allows for non-coercive solicitation of voluntary contributions for all services funded through the Act. Refer to MAN 5600, 2027 Voluntary Contributions.

Each AAA must implement a “No Show” policy that includes the maximum percentage of trips that will be allowed as “no shows” per human services provider and must monitor available data on a regular basis to ensure that all providers comply. The AAA, in collaboration with TSS staff, may establish or adjust the target percentage, determine corrective actions, and provide any technical assistance needed.

The No Show policy must include clear language about the definition of a no show, the frequency of no shows that constitutes a policy violation (example: 2 no shows per month), and the process for counseling consumers to mitigate further violations. The goal of the no show policy is to maximize resources, not to punish consumers.

Organizational relationship may take many forms, including but not limited to contracts with providers, partnerships with community organizations, and agreements with voucher program participants. DAS recommends that each AAA develop appropriate written agreements with partners, subcontractors, and other entities that may assist the AAA with the delivery of formal and informal transportation services.

Each AAA is expected to actively participate in the DHS Regional Transportation Coordinating Council (RTCC) for its area. Active participation includes:

AAAs, providers, and partners are required to adhere to all applicable state, federal, and local laws and codes regarding vehicle operations and maintenance. Refer to MAN 1425 in the Office of Facilities and Support Services.

The AAA and contract provider must maintain systems that are sufficient to manage and support the record keeping demands of each program. A computerized system is recommended. Programs that are supported fully or in-part with Older Americans Act, SSBG, or CBS funds may require documentation in the DAS data system as group services. AAAs should consult their assigned DAS Regional Coordinator for technical assistance.

Documentation of such funded trips should include:

For transportation programs funded fully or in-part with Older Americans Act funds, AAAs must maintain appropriate records pertaining to said transportation, and make such materials available for inspection upon request to DHS and participating organizations or their representatives. These records must also include evidence of required annual inspection records. Refer to the Vehicle Maintenance section of MAN 1425 in the Office of Facilities and Support Services.

AAAs and providers are encouraged to develop a written grievance policy that is specific to the transportation program’s structure and needs. Policies must be in alignment with requirement stated in HCBS Manual 5300, §110 “Grievance Procedures for Participants in Non-Medicaid Home and Community-Based Services Programs.” The DHS Coordinated Transportation system’s complaint process is required for all providers in that system. Refer to the Complaint Process section of MAN 1425 in the Office of Facilities and Support Services.

Programs that are funded fully or partially with Older Americans Act funds must include a monitoring and evaluation component to ensure program safety, efficiency, and responsiveness to consumer needs. DHS Coordinated Transportation staff conducts monitoring of service providers. AAAs are encouraged to coordinate monitoring of its transportation services to avoid duplication of effort.

The AAA and its provider are encouraged to conduct consumer satisfaction evaluations on at least an annual basis. DHS Coordinated Transportation staff conducts periodic customer satisfaction surveys, and the AAA may utilize these surveys to determine the appropriateness and effectiveness of services in its area. Collection methods may include surveys, interviews, and/or focus groups. The DAS Program Integrity section is available to provide technical assistance with survey design.

This requirement pertains only to AAA transportation activities not funded through the DHS Coordinated Transportation System. DAS recommends that the AAA conduct regular desk reviews of each provider’s records to ensure that programs are managed efficiently and sustainably. Such reviews may include, but are not limited to, an examination of financial data, consumer information records, vehicle maintenance documentation, and complaint resolution summaries. At any time, DAS representatives may request to read AAA’s desk review files on funded transportation programs.

Area Agencies will ensure through contractual requirements that subcontractors protect consumer information records, in accordance with the requirements set forth in HCBS Manual 5300, 202 Program Guidelines and Requirements.

DAS requires that AAAs develop and enforce a confidentiality policy that is in alignment with federal, state and Division standards. All individuals who participate in programs that provide transportation to DHS consumers must receive information about confidentiality expectations and consequences for violating privacy policies. Providers are required to document consumer’s receipt of privacy policy information.

The AAA will monitor transportation, using standards in MAN 1425 in the Office of Facilities and Support Services. AAAs may adapt DHS vehicle inspection forms as needed. DAS recommends that AAAs consult their legal counsel to develop local program policies.

DAS encourages the use of volunteer driver programs where feasible. The following guidelines are intended to provide support to agencies offering a volunteer driver program.

Concerns over liability issues often arise in discussions about volunteer driver programs. While liability may always be an issue, best practices suggest that the most effective way to mitigate liability is to ensure that the volunteer drive program follows appropriate policies and practice in recruiting, training, and monitoring volunteer drivers; and that sufficient protocols are in place to verify volunteer drivers’ compliance with relevant laws (current automobile registrations, valid drivers’ licenses, automobiles in proper working order, etc.).

See O.C.G.A. 5-1-42 for information about potential liability issues. The law presumes heightened duty of care for motor vehicle passengers. To be driving in “good faith” and without “willful and wanton misconduct” the driver should follow all laws and safe driving practices, including driving below the posted speed limit, not running red lights or stop signs, car in appropriate working order and all lights functioning – in addition to a driver’s license in good standing.

DAS recommends all individuals utilizing consumer-directed transportation (including services such as Uber and Lyft) be responsible for:

Refer to MAN 5300 212 Consumer Directed Services for complete instructions on consumer direction.

DAS recommends that AAAs consult their legal counsel to develop local program policies. At a minimum:

Mobility Transition Counseling (MTC) is an intervention that strives to facilitate and implement a planned transition for optimal mobility (courtesy of MTC website). MTC works best when integrated into a comprehensive assessment and intervention process to assist older adults and their families to remain mobile, engaged, and productive. Individual screening is important when counseling older adults concerning the transition from driving to non-driving mobility. Mobility transition counseling will depend on the consumer’s level of awareness and concern about his/her mobility change. Any AAA or provider interested in providing MTC is encouraged to contact the Division for technical assistance.