TL;DR
- NEMT accreditation is a voluntary, independent review of how a transportation provider runs its business.
- Federal Medicaid law sets four minimum rules for NEMT providers and drivers.
- NEMTAC accreditation reviews seven areas, including driver training, vehicle upkeep, billing, and call center and dispatch operations.
- The review takes about 90 days and costs $3,000 to $3,600 for a three-year term.
About 3 to 4 million Medicaid members used non-emergency medical transportation (NEMT) each year from 2018 to 2021, according to a CMS report to Congress. That is 4 to 5 percent of all Medicaid members. Members who qualify for Medicaid because of age or disability use the benefit at higher rates than average.
Each of those rides depends on a qualified driver and a safe vehicle. Accreditation is one way a provider can show an outside reviewer that both are in place, along with the records to prove it.
What NEMT Accreditation Is
NEMT accreditation is an independent review that checks whether a transportation provider meets a written set of national standards. In the US, the accreditation program built for NEMT providers is run by NEMTAC, a nonprofit that has been an ANSI-Accredited Standards Developer since 2018. ANSI is the American National Standards Institute, the group that oversees how voluntary national standards are developed in the US.
Accreditation is voluntary. No federal law requires it. NEMTAC says its review often goes beyond what state and local rules require. A provider that passes holds accreditation for three years.
Why Accreditation Exists
Accreditation exists because federal law only sets a minimum for NEMT providers, and federal audits have found NEMT records that could not show whether drivers and vehicles met state rules. Accreditation gives providers a way to prove they meet a higher, written standard.
What Federal Law Requires
Federal rules have long required state Medicaid programs to arrange rides to and from medical care. This requirement sits in 42 CFR 431.53. In December 2020, Congress wrote it into law through Section 209 of the Consolidated Appropriations Act, 2021.
Section 209 also added minimum rules for NEMT providers and drivers paid by Medicaid. According to a CMS bulletin to states, these rules apply to services provided on or after December 27, 2021. Each state must have a way to confirm the following:
- The provider and every driver are not excluded from federal health care programs or listed on the HHS Office of Inspector General (OIG) exclusion list.
- Every driver has a valid driver’s license.
- The provider has a process to address any violation of a state drug law.
- The provider has a process to share each driver’s driving history, including traffic violations, with the state Medicaid program.
CMS allows states to meet this requirement through an attestation, which is a signed statement from the provider. The federal list does not cover vehicle inspections, driver training, or how trips are booked and billed. States, brokers, and health plans set those rules in their own contracts and regulations.
What Federal Audits Found
OIG has stated that its prior audit reports have consistently identified NEMT services as vulnerable to fraud, waste, and abuse. Two recent audits show the kinds of problems reviewers found.
In Massachusetts, OIG reviewed a sample of 100 NEMT service lines. Of those, 86 did not meet certain federal and state requirements. For all 100, records of driver qualifications and vehicle inspection, registration, and maintenance were not adequately documented. OIG estimated at least $14.1 million in improper payments. (OIG report A-01-19-00004)
In New York City, OIG reviewed 100 sampled NEMT payments from 2018 and 2019. Only 17 fully met federal and state requirements. Another 41 did not, and OIG could not tell for the remaining 42. OIG estimated that New York improperly claimed at least $84.3 million in federal reimbursement, plus $112 million that may not have met the rules. Its recommendations included making sure providers document that drivers and vehicles meet state requirements and bill for the level of service that was authorized. (OIG report A-02-21-01001)
Both audits found gaps in records. NEMTAC’s standard asks providers to submit written policies along with proof that staff follow them, such as training rosters, inspection logs, and screening records.
Federal Minimum Compared With the NEMTAC Review
| Area | Federal minimum | NEMTAC Review |
|---|---|---|
| Exclusion checks | Provider and drivers must not be on federal exclusion lists. | Written policy on who is screened, which databases are checked (OIG, SAM, OFAC), how often, and what happens after a match. |
| Driver records | Valid license, plus a process to share driving history with the state. | Motor vehicle record checks before hire and on a set schedule, plus a yearly management review of driving records. |
| Drug policy | A process to address state drug law violations. | At least a 5-panel drug screen before hire, after incidents, on reasonable suspicion, and at random. |
| Training | Not in the federal list. | Defensive driving, first aid, CPR/AED, and securement training, each with renewal dates. |
| Vehicles | Not in the federal list. | Daily vehicle checks, maintenance records, and equipment checklists. |
| Call center and dispatch | Not in the federal list. | Set hours, minimum staffing, backup plans, defined roles, training, and quality monitoring. |
Sources: CMS Informational Bulletin, July 12, 2021; NEMTAC Accreditation Standard, Version 1.0.
What the Accreditation Review Covers
NEMTAC’s review covers seven areas, as listed in its published accreditation standard. For each area, the provider submits written policies and proof that staff follow them.
Organizational Management
This area checks how the business is set up. Reviewers look for a policy and procedure manual written for that specific organization, with policies for each level of service it offers, such as curb-to-curb or door-to-door. The provider must show its business licenses, Employer Identification Number (EIN), and National Provider Identifier (NPI).
Insurance must include at least $1 million in auto liability, general liability of $1 million per occurrence and $2 million total, sexual assault and molestation liability, and workers’ compensation where required. Insurers must hold an AM Best rating of A- or better. Hours of operation and contact information must be available to the public.
Human Resources
This area checks hiring and staff records. Reviewers look for a drug-free workplace policy and an exclusion screening policy that checks the OIG list, the federal System for Award Management (SAM), and the Treasury Department’s Office of Foreign Assets Control (OFAC) list. The provider must also show onboarding and training records, an ID badge policy, job descriptions that list lifting requirements, and a current roster of employees and contractors.
Driver Credentialing
This area checks that every driver, whether an employee or an independent contractor, is screened and trained. The standard requires:
- Criminal background checks before hire that cover at least 7 years and sexual offenses, done by a company that follows the Fair Credit Reporting Act.
- Drug screening before hire, after an incident or collision, on reasonable suspicion, and at random, using at least a 5-panel test.
- Motor vehicle record checks before hire and on a set schedule after that.
- A certified defensive driving course, renewed at least every three years.
- First aid and CPR/AED training, renewed every two years.
- Wheelchair, scooter, and stretcher securement training that includes a hands-on demonstration with the equipment used on real trips.
The drug policy covers every safety-sensitive role. The standard lists dispatchers, routers, and any staff member who deals with passengers as safety-sensitive, along with drivers.
Compliance Program and Ethical Business Practices
This area checks how the provider prevents fraud and protects riders. Reviewers look for a formal compliance program, a code of conduct, and a conflict of interest policy. Staff must complete fraud, waste, and abuse training.
The standard sets clear billing rules. Claims must show the correct level of service and correct coding, and they must match the service that was actually provided. Billing for services that did not happen is prohibited.
The provider must also show a HIPAA policy with a list of every organization covered by a Business Associate Agreement, an anti-kickback policy, and policies for complaints, critical incidents, contract compliance, and mandatory reporting of abuse, neglect, and exploitation.
Vehicle Maintenance and Inspections
This area checks the condition of the fleet. Records must show daily checks for damage and equipment problems, with fluid and tire pressure checks at least twice a week. Heating and cooling must be inspected and working.
Each company-owned vehicle must show a unique number that can be seen from three angles, along with the company logo. Vehicles not owned by the company can use magnetic signs or window clings. Providers must also keep equipment checklists and inspection logs for wheelchair securement, lifts and ramps, and stretchers where they apply.
Fleet Operations
This area checks how vehicles are driven and managed. The provider’s policy must cover accident reporting, a required drug test for the driver after any accident, and a plan for breakdowns. Vehicles must carry a flashlight and road markers such as cones, flares, or triangles.
The policy must also set driver on-duty and rest times, give drivers the authority to cancel a trip in unsafe weather, allow phone use only through hands-free systems, and ban texting while the vehicle is moving. Management must review driving records every year. The provider must keep a fleet list showing each vehicle’s year, make, model, VIN, and level of service.
Communications
This area checks how trips are tracked and how the call center and dispatch team work. Reviewers look for a trip tracking policy, a policy on GPS and camera use with sample data, and rules for radios and phones.
For call center, dispatch, and routing, the standard asks for:
- Set hours of operation, with advance notice of any changes.
- Minimum staffing levels that plan for peak demand and holidays.
- Backup plans for staffing shortages.
- Clear roles for answering calls, dispatching vehicles, and planning routes.
- Communication steps between call takers, dispatchers, and drivers.
- Training for each role and written procedures staff can refer to.
- Regular monitoring and quality checks.
As proof, providers submit staffing records and schedules, training records, performance reports, quality reviews, and records of how backup plans were used.
How the Accreditation Process Works
To apply, a provider needs its business licenses, an EIN, an NPI, and at least 12 months in operation offering NEMT, wheelchair, or stretcher van services. The process follows these steps:
- Complete NEMTAC’s readiness self-check to compare current operations with the standard.
- Submit the Seeking Accreditation Status application and pay the $600 non-refundable fee.
- Upload the required policies and documents to NEMTAC’s online review platform, ProCredEx.
- Go through the standards review, which may include interviews or site visits.
- Receive the final decision from the NEMTAC Board of Directors.
NEMTAC says the process takes about 90 days after the application is submitted, and it approves up to five organizations per month. Its survey team does not offer coaching or consulting, so providers need their records in order before applying.
The total cost is $3,000 when paid up front, which includes the $600 application fee. Providers can also pay the $600 fee plus $83.33 per month, for a total of $3,600 over three years. Accreditation stays valid for three years as long as credentials are kept current in ProCredEx and payments are up to date. NEMTAC’s public list shows 21 organizations awarded accreditation since October 2020.
Where Accreditation Counts With States
Some states give accreditation a formal role. According to NEMTAC, Mississippi accepts NEMTAC Accreditation as an alternative to a state license. In Minnesota, brokers offer incentives to providers who earn accreditation before January 31 each year. NEMTAC says it is working with other states on similar programs.
Where Phone Agents and Dispatchers Fit In the Review
Two parts of the review apply directly to the phone and dispatch team. The Communications section reviews how calls, dispatch, and routing are staffed and run. The Compliance section reviews whether claims match the rides that were given.
Phone agents and dispatchers do different jobs. Agents answer calls, book trips, and collect trip details. Dispatchers work with drivers throughout the day. When a rider cancels or reschedules, the dispatcher assigns the driver a new ride so the vehicle does not travel empty. The standard asks providers to define these roles in writing and train staff for each one.
The details collected on each call also affect billing. The level of service, pickup and drop-off addresses, and appointment information need to be correct for a claim to match the ride. The New York audit recommended that providers bill for the level of service that was authorized, and NEMTAC’s billing rules require claims that match the service provided.
Some operators use an outside partner for calls or dispatch. In that case, the partner’s staffing schedules, training records, and quality reports become part of the evidence reviewers ask for. A partner that handles riders’ health information on the provider’s behalf typically signs a Business Associate Agreement, and the standard asks providers to list those agreements.
Trained NEMT Agents and Dispatchers for Your Operation
Pac Biz answers your phones with trained NEMT agents, so no call goes unanswered and no trip gets lost. We also provide dispatchers who coordinate with your drivers throughout the day.
What Accreditation Shows
Federal law sets four minimum rules for NEMT providers and drivers paid by Medicaid. NEMTAC accreditation reviews seven areas of the business, from driver screening and vehicle upkeep to billing and dispatch staffing. It is voluntary, it takes about 90 days, and it lasts three years. For riders, brokers, and states, it shows that an outside reviewer has checked the provider’s records against a written national standard.
Sources
- Centers for Medicare & Medicaid Services. Expanded Report to Congress: Non-Emergency Medical Transportation in Medicaid, 2018–2021. https://www.medicaid.gov/medicaid/benefits/downloads/nemt-rtc-2018-2021.pdf
- Centers for Medicare & Medicaid Services. CMCS Informational Bulletin: Medicaid Coverage of Certain Medical Transportation under the Consolidated Appropriations Act, 2021. July 12, 2021. https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/AID/cib071221.pdf
- Code of Federal Regulations. 42 CFR 431.53, Assurance of Transportation. https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-B/section-431.53
- HHS Office of Inspector General. Massachusetts Made at Least $14 Million in Improper Medicaid Payments for the Nonemergency Medical Transportation Program. Report A-01-19-00004. https://oig.hhs.gov/reports/all/2021/massachusetts-made-at-least-14-million-in-improper-medicaid-payments-for-the-nonemergency-medical-transportation-program/
- HHS Office of Inspector General. New York Claimed $196 Million, Over 72 Percent of the Audited Amount, in Federal Reimbursement for NEMT Payments to New York City Transportation Providers That Did Not Meet or May Not Have Met Medicaid Requirements. Report A-02-21-01001. September 12, 2022. https://oig.hhs.gov/reports/all/2022/new-york-claimed-196-million-over-72-percent-of-the-audited-amount-in-federal-reimbursement-for-nemt-payments-to-new-york-city-transportation-providers-that-did-not-meet-or-may-not-have-met-medicaid-requirements/
- Non-Emergency Medical Transportation Accreditation Commission. NEMTAC Accreditation Programs. https://nemtac.co/accreditation/
- Non-Emergency Medical Transportation Accreditation Commission. BSR/NEMTAC 2001-202X Non-Emergency Medical Transportation Accreditation Standard, Version 1.0. https://nemtac.co/wp-content/uploads/2024/09/NEMTAC-2001-202X-Non-Emergency-Medical-Transportation-Accreditation-Standard.pdf