CMS Fact Sheet Offers Greater Insight on Providing NEMT Services

Sometimes a little simplification and clarification can go a long way in reaching intended goals. Therefore, the Department of Health and Human Services Centers for Medicare and Medicaid Services (CMS) recently issued a fact sheet addressing Medicaid transportation coverage and coordination, which includes frequently asked questions (FAQs) to assist in explaining the program’s mission.

The fact sheet was developed for state departments of transportation (DOTs), state Medicaid agencies and other transportation entities that are currently providing or are considering providing Medicaid-funded nonemergency medical transportation (NEMT). The document aims to help these providers better coordinate transportation for low-income individuals, people with disabilities, and older adults and foster partnerships between state agencies. CMS and the Federal Transit Administration (FTA) are collaborating to coordinate resources for NEMT and encourage partnerships between state-level counterparts. “Collaboration is fundamental to ensuring all providers have a shared understanding of what is allowed in their state,” according to the fact sheet.

CMS issued guidance last year on its current Medicaid transportation policy, which discusses state NEMT flexibilities. The fact sheet enhances the guidance by providing: (1) updated information addressing access to transportation services in more complex scenarios (including where beneficiaries may encounter extended wait times and need to make long-distance trips) and (2) references and greater context on certain overlapping requirements.

Among the FAQs, the fact sheet includes a question as to how a state DOT can support the delivery of Medicaid NEMT. CMS responds that FTA’s formula grant programs for rural/small urban areas are managed by state DOTs. When a state DOT serves as a public governmental broker. states may use public agencies to coordinate NEMT to provide the services more efficiently and cost effectively, as long as there is no conflict with the polices and rules of the Medicaid program. As such, public agencies must be selected through a competitive bidding process. Government entities (e.g., state DOT) are exempt from conflict of interest if subcontracting to another government provider (e.g., rural public transit) when the following requirements are met:

• payment does not exceed the actual costs calculated;
• accounting systems are maintained such that all funds allocated to the Medicaid brokerage program and all costs charged to the brokerage program are separate;
• the governmental provider was the most appropriate and lowest cost alternative for each individual trip, in consideration of the beneficiary’s specific needs; and
• the broker documents that Medicaid is paying for: (1) public fixed route transportation at a rate no more than charged to the general public; and (2) Americans with Disabilities Act paratransit and demand response at a rate no more than charged to any other state human services agencies for comparable services.

Hopefully this fact sheet will provide more information to service provider to aid in NEMT services across the country.

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