Trip Verification with Our Facility Partners

MTM, Inc. is contracted with state Medicaid and Managed Medicaid to provide non-emergency medical transportation (NEMT) for their members. This contractual arrangement includes a Business Associate Agreement, which permits us to receive certain member Protected Health Information (PHI).

Our clients (Medicaid and Managed Medicaid) require us to ensure that covered members are attending appointments when they receive transportation. In order to do this, we need the help of our facility partners. We will never ask for covered PHI – we have all that information. We will only ask if the covered member that we have/will be transporting has/had an appointment at your facility at a time that corresponds to their transportation.

Within your organization, your compliance officer or legal counsel can confirm the appropriateness of helping us to validate information relative to covered services. Additional regulatory information that explains our ability to access such information is provided below. We appreciate our partnership with the facilities that serve the same populations as MTM.

Regulations

The Federal law that governs how a member’s PHI can be used is 45 CFR 164.506. It says, in part:

A covered entity may disclose protected health information to another covered entity for certain health care operation activities of the entity that receives the information if:

• Each entity either has or had a relationship with the individual who is the subject of the information, and the protected health information pertains to the relationship; and
• The disclosure is for a quality-related health care operations activity (i.e., the activities listed in paragraphs (1) and (2) of the definition of “health care operations” at 45 CFR 164.501) or for the purpose of health care fraud and abuse detection or compliance. For example: A health care provider may disclose protected health information to a health plan for the plan’s Health Plan Employer Data and Information Set (HEDIS) purposes, provided that the health plan has or had a relationship with the individual who is the subject of the information.