Compliance & safety

Accountable transport, in writing

We work in a regulated space — Medicaid- and Medicare-funded non-emergency transportation. These are the obligations we carry, in plain language.

Privacy & HIPAA

Member health information is kept in strict confidence and used only as needed to perform transportation. We comply with HIPAA, including its Privacy, Security and Breach Notification rules, and we sign a business-associate agreement covering the handling of protected health information.

Administrative, physical and technical safeguards around PHI
Only the minimum necessary information is requested or disclosed
Any security incident or impermissible use or disclosure is reported within three business days
A breach of unsecured PHI is notified without unreasonable delay, and no later than 24 hours after discovery
PHI is returned or destroyed — with documentation — when the relationship ends

Driver screening & exclusions

Every driver and attendant is screened before serving and screened again at least annually.

A personal criminal background check passed before any member is carried
Screening against federal and state exclusion lists — no one on a Federal Exclusions List or otherwise debarred may drive
No one on a sex-offender registry, or convicted of a sexual, child-, elder-, domestic-abuse, drug, weapons or violence felony in the previous seven years
Suspected impairment: the driver is immediately removed from service

Fraud, waste & abuse (FWA)

We maintain a written FWA policy and distribute it to our officers, drivers, staff and subcontractors, as required under the Deficit Reduction Act.

We explain the Federal and State False Claims Acts and the administrative remedies under them
Whistleblower protections: no retaliation for good-faith reporting
An anonymous reporting channel for suspected violations
We only bill for trips actually performed, and cooperate with attendance verifications and audits

Members are held harmless

We never bill, charge or seek payment from a member for amounts that are the legal responsibility of a health plan — under any circumstance, including non-payment or a plan's later determination that a service was not medically necessary.

No balance billing of members or Medicare beneficiaries
Authorised co-payments may be collected as directed by the client
Dual-eligible members are not charged cost-sharing the state is responsible for

Insurance

Coverage in force, endorsements in place

We carry insurance at the levels required, at our own expense, with the endorsements the law and our clients require.

Commercial general liability

Occurrence form, covering our operations and products, personal and advertising injury, property damage and bodily injury.

Commercial auto liability

Covering bodily injury (including death) and property damage arising from the ownership, maintenance, operation or use of vehicles.

Workers' compensation

At state statutory limits, with a waiver of subrogation in favour of the broker and its affiliates.

Additional insureds

Required parties named as additional insureds, with primary and non-contributory, cross-liability/severability and waiver-of-subrogation endorsements.

Evidence on file

Certificates of insurance are furnished before services begin and kept current, uploaded to the credentialing portal.

Notice of cancellation

Policies carry at least 30 days' prior written notice of cancellation.

On the road

Safety rules our crews follow

No hand-held devices

Drivers never hold or use a mobile device while driving. Navigation devices must be securely mounted and handled only when safely parked.

Emergency procedures

A written emergency plan covers breakdowns, accidents and medical emergencies; drivers are trained and carry a device to report incidents immediately.

Securement training

All drivers are trained on proper securement of members travelling by wheelchair, mobility device or scooter in ADA-compliant vehicles.

No smoking signage

Each vehicle displays clear signage stating that smoking, vaping and e-cigarettes are prohibited for drivers and passengers at all times.

Safety first, always

If a passenger's behaviour or any condition threatens safe operation, the driver pulls over safely, notifies dispatch, and requests assistance.

Complaints handled

Driver conduct and service-quality complaints are investigated and addressed promptly. Two substantiated complaints in 90 days requires retraining; four in a year ends driving privileges.

Annual training

Training that never stops

Every principal, officer, director, agent, associate and employee — including drivers and attendants — is trained on HIPAA and Fraud, Waste and Abuse upon hire and at least annually thereafter. Documentation is available on request.

See the training program

Records & audits

Ready for review

We keep trip, vehicle, driver and billing records for ten years from final payment — longer where required — and produce requested records within three business days. If an audit or litigation is pending, relevant documents are retained until it is resolved.

Reporting a concern. Anyone — a member, a facility, a driver — can raise a compliance concern with us directly. Reports are taken seriously, investigated, and good-faith reporting is always protected from retaliation.