For years, health plans could point to a legacy broker contract and call it NEMT governance. That's no longer enough.
The conversation has shifted. It's happening across every front simultaneously. CMS finalized new network adequacy reporting requirements. Federal regulation on broker oversight is drawing fresh scrutiny from HHS-OIG. And across the country, states are mid-transition in their managed care structures, discovering that the systems they delegated don't produce the data they're now required to show regulators.
At the same time, health plan leaders are asking harder questions about what they actually know about their transportation programs — and what they'd do if they had to prove it.
So far this quarter at Kinetik, the work connects back to one thread: you can't govern what you can't see, and you can't improve what you can't measure.
Here's what we've been thinking about…
The old way to demonstrate NEMT network adequacy was simple: count providers. If the roster was long enough, the box was checked.
That standard is no longer holding. CMS's updated Medicaid managed care regulations have moved network adequacy validation into the mandatory External Quality Review process, with results required in annual EQR technical reports. The NAAAR — the Network Adequacy and Access Assurances Report — now requires mandatory submission through the MDCT web portal for all rating periods beginning after July 9, 2025, with new payment analysis data fields phasing in for rating periods beginning July 9, 2026.
The shift is significant. Health plans that have delegated NEMT to a broker need to be able to show that their network actually delivers access, not just that providers appear on a list. If the data flowing from that broker isn't complete, reportable, and verifiable, the health plan carries the exposure.
What was once a best practice argument is now a regulatory requirement.
Read → From provider counts to performance: Redefining NEMT network adequacy
Read → Why NEMT can't afford to stay broken: Lessons from the frontlines of Medicaid transportation
Health plans have treated NEMT as a logistics problem. The reality: it's a data infrastructure problem, and the gap is showing up in compliance exposure. → Transportation Is the Missing Infrastructure Layer in Healthcare
What payment integrity actually requires in a delegated NEMT model, and why fragmented vendor oversight makes it structurally impossible. → From fragmented oversight to verifiable spend: Modernizing NEMT payment integrity
Digitizing a broken process doesn't fix it. The case for interoperability as the real bar for NEMT modernization. → Digital isn't enough: Why interoperability must be the new standard for NEMT
19 ways to make ESG and corporate responsibility messaging more credible — Stop chasing frameworks, anchor to values, and let the work speak for itself.
19 tips to turn trust into a measurable growth driver — Trust is an institutional behavior, not a survey score: regulators engaging earlier, partners making introductions, customers willing to pilot new models. In a compliance-heavy space, that distinction matters.
How to measure the credibility and long-term value of nontraditional media — Earned media in unconventional channels is harder to quantify and often undervalued. A framework for measuring what it actually returns over time.
Beyond the deal: BD's new role in long-term B2B partnerships — Why business development in healthcare can't stop at contract execution — and what it looks like when it doesn't.
Kinetik Co-Founder & CEO Sufian Chowdhury joined Andrew Peterson, CEO of UnitedHealthcare Community Plan of New Mexico, for a conversation moderated by Becca Geist, National Director of Government Programs at Kaiser Permanente. → Watch the recording
North Carolina is a useful lens on a pattern playing out across the country.
When the state transitioned to managed care in 2021, it carved NEMT into its MCO contracts, making health plans directly responsible for delivering transportation benefits. To manage day-to-day operations, the MCOs turned to transportation brokers. But like most legacy broker models, these arrangements weren’t designed to produce the level of data transparency, network accountability, or cost verifiability that regulators and health plans now require. The result is a familiar tension: a system that was built to process trips, now being asked to prove it’s actually serving members. A standard it was never designed to meet.
NC Medicaid's managed care plans are now navigating a landscape where network adequacy must be demonstrated, not assumed, and where the data flowing from transportation vendors has to be complete, reportable, and defensible. For plans that delegated NEMT without building in genuine oversight mechanisms, the data simply isn’t there to answer the questions being asked.
What's happening in North Carolina isn't a North Carolina problem. It's a stress test that every MCO relying on traditional broker infrastructure will eventually face. The state may differ. The pressure is the same: demonstrate trip fulfillment, validate the full lifecycle of every trip, account for every dollar. That’s program integrity.
Read → North Carolina's NEMT hits an inflection point
A new recurring section covering the legislative and regulatory developments reshaping how health plans govern NEMT programs.
The regulatory pressure on NEMT isn't coming from one direction. This quarter, several converging developments are worth tracking together.
CMS Medicaid managed care access, finance, and quality final rule — Network adequacy validation is now a mandatory component of External Quality Review protocols, with results due in annual EQR technical reports. Health plans can no longer demonstrate NEMT compliance through rosters alone; they need data that shows providers are actually performing. Regulators have closed the gap between counting providers and proving access.
NAAAR reporting transition (Effective July 9, 2025 / July 9, 2026) — States must now submit Network Adequacy and Access Assurances Reports through the MDCT web portal for rating periods beginning on or after July 9, 2025. New payment analysis data fields are being added for rating periods beginning July 9, 2026. Health plans relying on brokers for NEMT data need to ensure that the data is complete and reportable in these formats, because if it isn't, the health plan owns the gap.
Broker oversight requirements (42 CFR § 431.53) — Federal regulation requires states to ensure transport personnel are licensed, qualified, and regularly audited. HHS-OIG has found persistent deficiencies in NEMT broker operations. Health plans that have delegated NEMT to a broker remain accountable for member access outcomes. Regulators are increasingly scrutinizing whether delegation is backed by genuine oversight or is simply a contract pass-through.
Medicaid financing environment — CMS finalized a rule effective April 2026, implementing provisions of the Working Families Tax Cut Act, including tighter oversight of provider tax arrangements. While not NEMT-specific, managed care plans in states relying on provider tax structures face unwinding requirements that will affect the overall Medicaid budget environment in which transportation programs operate.
The common thread: accountability is being required, not assumed. Programs that can document performance at the trip level, the claim level, and the network level are positioned for this environment. Programs that can't are exposed.
Agentic AI in NEMT: Why trust Is the only feature that matters — AI in NEMT is only as useful as the infrastructure it's built on. This piece examines what makes AI deployable and what makes it dangerous in a high-stakes access environment.
If you can't see it, you can't stop it — Bad actors don't need to be clever when the system isn't watching. What program fraud actually looks like, and what stops it.
3 Ways transportation supports rural health improvement — RHTP raised the bar for what access means in rural communities. Transportation is how you meet it.
This spring, we shipped updates across the Kinetik platform built around one goal: less friction for the teams managing programs and the members depending on them.
Trip Scheduler: Conflict checks at approval, coverage gap alerts before booking, and a built-in report builder — so teams can identify and resolve issues proactively, without leaving the platform.
Trip Assistant: Improved trip navigation with direct date filtering and a next-record button that keeps coordinators moving without extra clicks.
Health App: Draft-saving for in-progress bookings, cleaner trip notifications for recurring rides, and a redesigned invitation flow that gets more members to self-service from day one.
Together, these updates deliver smarter operations, faster workflows, and a better experience for members from the moment they book their trip to the moment they arrive at their destination.
Learn more → Spring product updates | Request a demo
This quarter, the industry's accountability gap moved from background concern and to front-line requirement. Regulatory standards are tightening, state programs are transitioning, and health plans that delegated NEMT without building defensible oversight mechanisms into the arrangement are discovering they own the exposure, not the broker.
The thread running through everything we covered: you can't govern what you can't see, and you can't improve what you can't measure. Whether that shows up in how you report network adequacy, how you structure your program, or how you pay your providers, the standard is moving, and it's moving toward proof.
We'll keep building infrastructure that makes accountability possible, at the trip level, the claim level, and the network level.
And as the market evolves, so are we. More to come from Kinetik soon.