For millions of Medicaid members, a ride is the difference between making a dialysis appointment and missing it. Non-emergency medical transportation (NEMT) is one of the few benefits that decides whether other benefits get used at all. So when federal regulators describe NEMT as a high-risk program for fraud, waste, and abuse, the stakes are not only financial. Every dollar that leaks out of the program is a dollar that makes the benefit harder to defend and harder to sustain for the members who depend on it.
Healthcare often pays first and verifies later. In NEMT, that practice no longer holds up.
NEMT is now a program integrity priority
Federal oversight has caught up with what operators have known for years. In its fiscal years 2024-2028 Comprehensive Medicaid Integrity Plan, the Centers for Medicare & Medicaid Services (CMS) identified NEMT as one of a small set of program areas with high-risk integrity vulnerabilities, alongside managed care, dental benefits, nursing facilities, and home and community-based services. The Government Accountability Office (GAO) reached the same conclusion, noting that CMS has flagged NEMT as a program area at risk for fraud and documenting nearly 200 criminal convictions, civil settlements, and judgments against transportation providers across 25 states between fiscal years 2015 and 2020. Those cases included billing for trips that never happened and the use of unauthorized drivers or vehicles.
The momentum is still building. In early 2026, CMS issued a Request for Information for its Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative, signaling a broad push to strengthen program integrity across federal health programs. For health plans, this is no longer a distant compliance question. It is an active audit focus that will shape contract requirements and oversight expectations.
Here is the problem. Retrospective audits, the traditional tool for catching improper payments, are poorly suited to a benefit like NEMT. The transaction volume is enormous, the average claim value is low, and execution is spread across plans, brokers, transportation providers, and dispatch systems. By the time an auditor reconstructs a single trip months later, the money is gone and the trail is cold.
The problem is architecture, not intent
It is tempting to read enforcement headlines as a story about bad actors. The more useful reading is structural. In most legacy NEMT programs, authorization lives in one system, scheduling in another, dispatch in a third, and billing somewhere else entirely. No single record follows the trip from request to payment. The claim becomes the first moment all of that information is consolidated, and a claim is an assertion, not proof.
That design produces error long before it produces fraud. Nationally, most Medicaid improper payments are not evidence of theft. In 2024, the Medicaid improper payment rate was 5.1%, and roughly 79% of those improper payments stemmed from insufficient documentation or missing administrative steps rather than payments for ineligible members or services. GAO has been explicit that improper payments and fraud are related but distinct, and that the improper payment estimate is not a measure of fraud. In other words, the central payment integrity problem in NEMT is not that people are lying. It is that the system cannot reliably prove what happened at the point of service.
Ambiguity is the real enemy. When stakeholders act in good faith but the data cannot confirm a trip occurred, that ambiguity still produces waste, still erodes trust, and still shows up as a finding.
What payment integrity actually requires in NEMT
Closing the gap does not require more auditors. It requires moving proof to the moment of service. GAO’s review of state NEMT programs found that the states making real progress relied on a consistent set of controls: screening providers, drivers, and vehicles; verifying eligibility before a trip is scheduled; and validating completed trips through trip logs, GPS data, and claims review. Read together, those controls describe four checkpoints any credible NEMT integrity model should incorporate.
- Eligibility belongs before the trip, not after the claim. A member’s eligibility and the medical necessity of the trip should be confirmed at the point of request, so an ineligible trip never enters the program in the first place.
- Trip completion has to be a provable event. GPS data, driver attestation, and member confirmation turn “we say it happened” into a verifiable record that it happened. A trip that cannot be verified should not be able to generate a claim.
- Level of service has to match what was authorized. One of the most common documented abuse patterns is billing a higher-cost level of service than the member’s need required. Aligning the delivered service to the authorized service closes that gap.
- Mileage has to tie to the actual route. Inflated mileage is only possible when the billed distance is disconnected from the route the vehicle actually traveled. When mileage derives from route data, there is nothing to inflate.
From pay-and-chase to verify-and-pay
Transforming NEMT payment integrity is not just a Kinetik idea. It is the direction CMS itself is moving. CMS is committed to identifying and intercepting fraud before the funds leave its accounts, moving from a “pay and chase” recovery toward “caught and stopped” approach. Home health and personal care services have operated under Electronic Visit Verification for years, building real-time proof of service into the payment process. NEMT has lagged behind, and that gap is exactly what regulators are now moving to close.
The payoff of getting this right is not just fewer findings. When a verified trip event becomes the source of truth, the claim becomes a byproduct of validated activity rather than a separate assertion that has to be checked later. Most clean trips can flow through automatically, and human review can focus only on the genuine exceptions. That is tighter integrity with less administrative burden, not more.
What this means for health plans
For health plans, the practical question is where this proof should live. It cannot live in disconnected systems that each hold one piece of the trip. It has to live in a single, connected environment that follows the trip from request through verification to payment, and that the plan can see into directly.
This is the gap Kinetik was built to close. Kinetik is a tech-enabled services company that operates a closed-loop NEMT infrastructure, where the data captured at trip request is the same verified data that generates the claim. Eligibility checks, location controls, GPS verification, driver and vehicle credentialing, and anomaly detection are built into day-to-day operations rather than bolted on as an after-the-fact audit. Health plans get program transparency across every trip, provider, and cost, with no black boxes, regardless of how they choose to own, share, or delegate their NEMT operations.
The results are measurable. In its work with a regional health plan in California, Kinetik documented a 48% reduction in average cost per completed ride and a 99% reduction in ghost rides. In New Mexico, a national plan and its transportation network benefitted from more than 99% of claims being accepted on first submission while 100% of clean claims are paid within 30 days. The infrastructure is HITRUST r2 certified and SOC 2 Type II attested, with audit-ready documentation behind every trip.
There is a balance to hold here. Strong integrity controls should stop improper payments without standing between members and the care they need. The goal is not to make trips harder to get. It is to make every approved trip verifiable.
Payment accuracy is an access strategy
This is ultimately why it matters. Waste in NEMT is not only a budget line. It is political pressure that puts the entire benefit at risk, which means it puts member access at risk. Building payment integrity into the trip itself, rather than chasing it after the fact, is how the program stays defensible and how members keep getting to care. Removing transportation as a barrier to care depends on it.
To see how Kinetik modernizes NEMT program integrity, reach us at connect@kinetik.care.
Authored by: Elizabeth Jepsen
