The Centers for Medicare and Medicaid Services (CMS) has recently unveiled a report titled “Expanded Report to Congress Non-Emergency Medical Transportation in Medicaid, 2018–2021.” The report expands on CMS’s initial 2022 Report to Congress on non-emergency medical transportation (NEMT), incorporating additional insights and extending the scope of data analysis.

The original report was developed as required by the Consolidated Appropriations Act of 2021, which also formally codified into statute the long-standing regulatory requirement for states to provide NEMT for beneficiaries (sometimes referred to as Medicaid’s assurance of transportation). The expanded report provides several material updates from the initial report, including an additional year of data (2021) and more information on the utilization of NEMT and telehealth services during the pandemic. It also includes analyses of utilization broken down by the NEMT delivery model. Specifically, some key findings from the new CMS report include:

  • Based on available data, approximately 3 – 4 million Medicaid beneficiaries used NEMT annually between 2018 and 2021. It is important to note that this estimate is likely undercounted because some types of NEMT utilization are not captured in the Transformed Medicaid Statistical Information System (T-MSIS) data.
  • Consistent with prior studies, including from MTAC and the Medicaid and CHIP Payment and Access Commission (MACPAC), CMS found that between 4 and 5 percent of Medicaid beneficiaries used NEMT each year, but subgroups of Medicaid beneficiaries with substantial health care needs used NEMT at higher rates than the average. These subgroups included Money Follows the Person (MFP) participants, participants receiving home- and community-based services through Section 1915(c) waivers, and dually eligible beneficiaries.
  • In all years and across most beneficiary subgroups, the volume of NEMT service use was highest in states that used a capitated broker model to deliver NEMT. Across all years and subgroups, beneficiaries in states that used an in-house delivery model had the lowest volume of NEMT service use. However, on average, states using an in-house NEMT delivery model claimed a relatively high percentage of NEMT expenditures as administrative expenditures, and NEMT administrative expenditures generally are not captured in the T-MSIS data. Therefore, NEMT service utilization measures may be underestimated for these states more so than for states using other delivery model types.
  • NEMT played a key role in enabling access to care for beneficiaries with certain types of physical health conditions, mental health conditions, and substance use disorders (SUDs), who used the benefit at substantially higher rates than the average. These include beneficiaries with chronic kidney disease (CKD), end stage renal disease (ESRD), opioid use disorder (OUD) and any SUD, and people with intellectual disabilities or other developmental delays (ID/DD); and beneficiaries with any mental health condition.
  • Overall, beneficiaries most often used NEMT to access preventive health care services, services related to the evaluation and management (E&M) of acute and chronic conditions, lab and imaging services, and behavioral health services.
  • The use of telehealth increased sharply at the onset of the COVID-19 Public Health Emergency (PHE) as NEMT use decreased; since April 2020, demand for telehealth has declined.
  • Throughout the COVID-19 PHE, the use of NEMT to access other service types remained strong. The average NEMT ride volume declined with the onset of the PHE for accessing lab and imaging services, dialysis, medication-assisted treatment (MAT) for OUD, care for heart disease and diabetes, cancer treatment services, physical therapy (PT) and occupational therapy (OT), and dental services. However, by the fourth quarter of 2021, NEMT service volume had outpaced telehealth service volume when accessing these service types.
  • Throughout the COVID-19 PHE, certain beneficiary subgroups have used telehealth more than NEMT. These groups included children; adults; adult expansion beneficiaries; pregnant and postpartum beneficiaries; and beneficiaries with CKD without ESRD, any mental health condition, any SUD, or OUD.

The report concludes with a set of recommendations aimed at improving Medicaid coverage of NEMT. First, CMS recommends states examine and find opportunities to improve operations between NEMT and public transit networks to better coordinate services for beneficiaries. Second, CMS recommends states expand upon the findings of the report and further examine the role NEMT may play to improve the use of timely preventive care. Finally, CMS recommends states, brokers, and local stakeholders analyze opportunities to increase beneficiary awareness of the NEMT benefit.