NEMT documentation requirements: what to record on every trip and how long to keep it

Where NEMT documentation rules come from

Three layers of rules decide what you must record. They stack, and the strictest one wins.

1. Federal Medicaid rules. Under 42 CFR 431.107(b), every Medicaid provider agrees to keep any records necessary to disclose the extent of its services and to hand them to the state, HHS, or the state’s Medicaid Fraud Control Unit on request. CMS’s 2023 transportation guide adds that the goal of documentation is to show each claim represents necessary transportation to or from a covered service, and that “records should be accurate and complete.”
2. Your state Medicaid manual. States spell out the exact fields for each trip, the forms, and the retention period.
3. Your broker or plan contract. Brokers add their own requirements, such as timestamps and driver and vehicle details on every billed trip, and they audit against them.

The stakes are money you already received. New York says transportation providers are paid only when “contemporaneous, complete, acceptable, verifiable records” are available, and that incomplete or false records lead to recoupment. Texas says payment may be recouped when the record does not show the level of service billed.

What every trip record should include

Most state lists overlap. This table compares three current state manuals. A blank means that manual does not name the item.

Colorado uses a form instead of a list. Every NEMT provider must use the state’s Standard Trip Log for all rides, effective October 1, 2024, keep the completed logs on file, and submit them with claims. Colorado also requires the names of any additional passengers in the trip log. North Dakota adds a privacy rule: the record should show the facility name and address, not the name of the provider the rider is seeing.

Our free NEMT trip log template covers the combined list.

Signatures, electronic records, and GPS

Paper logs are not required. Electronic records are accepted when they are trustworthy. New York’s manual, citing a January 2019 Medicaid Update, lets providers:

• replace the driver’s written signature with a unique electronic signature, and
• have the driver tap to confirm completion, as long as the system records the pickup and drop-off coordinates.

The condition is strict. The provider must be able to produce “an accurate, system-generated, unmodifiable date and time stamp for each leg” for the full six-year retention period.

Mileage rules are similar across states. Indiana accepts odometer readings or mapping software and requires the mapped route to be the shortest. Colorado pays for the shortest trip length shown by an internet map, a trip planner, or GPS. CMS’s transportation guide notes that drivers can use odometer readings or GPS coordinates to calculate mileage where there is no street address.

Arizona goes further on electronic claims. Its Medicaid program requires pickup and drop-off addresses on every NEMT encounter and treats missing data as a hard edit.

What does not count as proof

A dispatch record is not a trip record. New York lists four documents that are not acceptable as the only evidence of a trip:

• a driver or vehicle manifest or dispatch sheet,
• a prior authorization with checkmarks added,
• a prior authorization roster, and
• an attendance log from a day program.

They can support a trip record, but they cannot replace one. The record has to show what happened on that leg, captured at the time it happened.

Driver and vehicle records

Trip records prove the ride. Driver and vehicle files prove the ride was allowed. Federal law, through section 1902(a)(87) of the Social Security Act, requires states to make sure every NEMT provider and driver:

• is not excluded from federal health care programs,
• holds a valid driver’s license (for each driver),
• has a process to address violations of state drug laws, and
• has a process to disclose each driver’s driving history, including traffic violations, to the state.

States and brokers add more. North Dakota requires commercial providers to keep a copy of every driver’s valid license in the personnel file and to show proof of vehicle registration and insurance on request. SafeRide Health asks for each driver’s license, background and sex offender registry checks, motor vehicle reports, drug screens, and wheelchair securement training, and bars drivers with expired documents until they renew. The driver file checklist lists the common items.

How long to keep records

Retention periods vary, so plan for the longest one you are under.

North Dakota also says records must be kept even after a provider stops providing transportation. If you close or sell the business, the records still have to exist.

Audits: how the records get tested

Payers test documentation before and after they pay. CareOregon verifies 5 percent of NEMT trips both before and after the ride, and its audits review claims data, the level of transport, and pickup and drop-off times. If an audit finds an overpayment, the broker can take it back from a future invoice. A monthly self-check helps: pull a handful of paid trips and confirm each record has every item your state and broker list. Our guide to passing a broker audit covers how to prepare, and the claim denials guide covers what happens when records fall short.

Capturing it as the trip happens

The best record is the one the driver creates during the trip, not the one rebuilt at the end of the week. In the HealthRide driver app, signatures are captured on screen at pickup or drop-off and saved to the trip automatically, and each leg records its times and GPS-recorded miles. The app keeps working without cell service and sends everything once coverage returns. The trip log report exports every leg with scheduled and actual times, addresses, driver, vehicle, and miles as a spreadsheet or print-ready PDF.