Independent Audit Report on a Transportation Company’s Billing Practices Under a VA Healthcare System Contract

VA asked the OIG to conduct an audit of a contractor whose billing practices were concerning. The contractor, which provided eligible veterans with wheelchair van and other nonemergency transportation services to and from medical appointments in a certain VA healthcare system, invoiced VA about $11.17 million between January 1, 2019, and December 31, 2021, under this contract.

The OIG conducted an assertion-based attestation examination and found the company may not have complied with contract terms related to billing for veteran transportation, resulting in an estimated $1.81 million in potential overbillings between January 1, 2019, and December 31, 2021. Of this amount, $1.34 million was related to unclear contract terms and the company’s methodology for billing remote trips with multiple stops as though each drop-off was a separate trip.

The OIG also found that the company used mileage estimates instead of miles traveled and may have misclassified trips, with those errors resulting in potentially overbilling VA by an additional $470,537. According to the contractor, VA did not object or instruct the company to bill differently. VA issued a contract modification in April 2022, addressing billing of remote trips. The OIG found that the vendor complied with the billing terms of the modification for trips identified as remote. Subsequently, VA set a flat fee for each pickup and drop-off, removing the requirement to calculate billings by trip.

Except for the potential overbillings giving rise to the qualified opinion, the OIG team found the company’s assertion that it billed in accordance with the terms and conditions of the contract was fairly stated in all material respects. The OIG recommended—and VA agreed—that VA should confer with its Office of General Counsel on whether any funds could or should be recouped.