How payers can close the NEMT accountability gap before an audit hits
In most non-emergency medical transportation programs, the claim is the first complete record of a trip — created before anyone independently verifies the trip happened.
This report highlights an accountability gap in NEMT that auditing after the fact cannot resolve. Drawing on Government Accountability Office enforcement data, and a federal Office of Inspector General audit that found over 72% of audited New York City NEMT reimbursement did not meet or may not have met Medicaid requirements, it makes the case for closed-loop infrastructure: a claim cannot be generated without a verified trip.
The stakes are direct. The health plan is the responsible party when an audit arrives, yet legacy broker models rarely give plans the real-time data access that responsibility requires. Inside is a framework to evaluate your program integrity — including five questions every plan should answer.
Takeaways:
This report highlights an accountability gap in NEMT that auditing after the fact cannot resolve. Drawing on Government Accountability Office enforcement data, and a federal Office of Inspector General audit that found over 72% of audited New York City NEMT reimbursement did not meet or may not have met Medicaid requirements, it makes the case for closed-loop infrastructure: a claim cannot be generated without a verified trip.
The stakes are direct. The health plan is the responsible party when an audit arrives, yet legacy broker models rarely give plans the real-time data access that responsibility requires. Inside is a framework to evaluate your program integrity — including five questions every plan should answer.
Takeaways:
- The accountability gap is structural, not behavioral — disconnected authorization, dispatch, execution and billing systems leave the claim unverified
- The health plan, not the broker, carries audit responsibility
- Closed-loop infrastructure makes verified trip execution a precondition for billing
- Program integrity and program efficiency rely on the same verified data chain
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