Across the nation, Medicaid fraud has become a critical focus for policymakers and stakeholders, as evidenced by recent congressional hearings and large-scale criminal cases. Fraudulent schemes drain resources from programs meant to serve vulnerable populations and threaten access for those who rely on vital services—including non-emergency medical transportation (NEMT). Challenges common to many Medicaid services, and that have been scrutinized, include phantom billing, double billing, kickbacks, and identity theft. There are also more targeted concerns, such as fraud in mileage reimbursement and high-utilization services like drug rehabilitation and methadone clinics. State and federal agencies are responding with new initiatives, stricter oversight, and increased use of data analytics to address fraud, waste, and abuse in Medicaid programs.
The Federal Government Recognizes NEMT is a Valuable Service
NEMT has been an important feature of Medicaid since the program’s inception, helping Medicaid beneficiaries access medically necessary services. For over 10 years, total Medicaid spending on NEMT has been estimated at approximately $3 billion—less than 1% of total Medicaid expenditures in 2021. NEMT’s role in overcoming transportation barriers is well established through published studies and the experiences of beneficiaries and program administrators. For example, in its 2021 Report to Congress, the Medicaid and CHIP Payment and Access Commission (MACPAC) found that NEMT plays a vital role in facilitating access to care. Focus group participants convened by MACPAC said the benefit is essential to maintaining their health and, in some cases, has been lifesaving—particularly for beneficiaries in remote areas and those with substantial health care needs. According to CMS’s 2023 Report to Congress, between 4 and 5 percent of Medicaid beneficiaries used NEMT from 2018 to 2021. However, certain subgroups of Medicaid beneficiaries with substantial health care needs used NEMT at higher rates than the average. Without NEMT, these beneficiaries may not have access to life-sustaining care.
Brokerage Model is a First Line of Defense to Preventing Fraud
The Medical Transportation Access Coalition (MTAC) recognizes that NEMT is essential for ensuring Medicaid beneficiaries can access medical care, pharmacies, and treatment. However, persistent program integrity issues—including inadequate ride documentation, over-billing, and service gaps—remain a disservice to both beneficiaries and the federal and state taxpayers who fund Medicaid. As a first line of defense, the majority of states use one or more brokers to administer their NEMT Medicaid benefit. Brokers assume full responsibility for managing a defined beneficiary population, ensuring access to the most appropriate means of transportation delivered by providers with strong safety records. Brokers also help prevent fraud and abuse through various program integrity measures. Researchers who study transportation programs have found that capabilities like computer-aided scheduling and tight controls on eligibility—all common among NEMT brokers—increase service capacity by reducing average trip length, transporting multiple passengers at once, and decreasing ineligible trips. These measures reduce average trip cost and allow the program to run efficiently.
MTAC’s Resources on Fraud Prevention
MTAC has been a leader in advocating for and optimizing the broker model through performance-based contracts, value-based incentives, and the use of technology like GPS and driver-tracking systems to improve service reliability and reduce fraud. We encourage robust complaint processes, transparent audits, and stakeholder collaboration to strengthen oversight and ensure consistent quality nationwide. Our coalition of brokers and partners actively shares best practices and provides technical assistance to state and federal agencies, positioning MTAC as a resource for the industry. For example, in 2019 we commissioned original research showcasing opportunities to improve NEMT program integrity, and in 2025 released a first-of-its-kind research study and toolkit to provide states with NEMT contracting insights, including best practice program integrity safeguards.
To further ensure good stewardship, MTAC supports strategies such as trip verification for a significant percentage of rides, member-facing mobile apps, and targeted education and training for medical facilities on verification requirements. We believe technology should be leveraged to simplify trip verification and protect against fraud, while facilitating easy access and reliable reimbursement for riders. MTAC also advocates for state intervention when fraudulent activity is identified. Together, these efforts help alleviate network challenges, improve service, and enhance the rider experience, ensuring that NEMT remains accessible and efficient for those who need it most.
As the Medicaid landscape evolves, MTAC remains committed to fostering communication across states and with NEMT stakeholders, evaluating the impact of new trends and strategies, and disseminating emerging best practices. We support ongoing policy discussion and innovation, and are dedicated to promoting integrity, access, and quality in Medicaid NEMT. By working together, providers, drivers, brokers, and policymakers can identify and deploy the tools, guidance, and resources necessary to navigate challenges, uphold program integrity, and serve both Medicaid beneficiaries and American taxpayers.