A quality assurance program for NEMT: ride audits, callbacks, and complaint trends

Why run your own quality checks

Every Medicaid ride you run is already being checked by someone. Under the federal rule for state NEMT brokerage programs (42 CFR 440.170(a)(4)), each broker needs procedures to watch riders’ access to care and their complaints. They must also ensure timely rides and transport personnel who are “licensed, qualified, competent, and courteous.” In turn, the state audits and oversees the broker. Medicaid health plans have to run their own quality assessment and performance improvement programs (42 CFR 438.330), and they pass the monitoring down. CareOregon’s provider manual (February 2024) makes its brokerages responsible for monitoring providers and reporting findings to CareOregon.

That oversight lands on your company as audits, scorecards, and field checks:

• Under WellTrans’s provider agreement (revised October 2025), you join its quality assurance plan, assist with corrective action plans, and hand over the data it asks for to track their results.
• Louisiana’s Medi Trans manual (revised February 2025) describes monitoring providers, vehicles, and drivers at least weekly, and meeting with each provider quarterly.
• For trips on or after October 1, 2026, MTM Health arranges Virginia’s fee-for-service Medicaid rides. Its Virginia handbook (approved August 2026) assigns each provider a field monitor who reviews its performance measures on a regular schedule.

A quality assurance program is the same work done from your side, earlier. You find the late pattern, the missing signature, or the rude driver before it becomes a complaint, a penalty, or a lost contract.

What brokers measure

Start with the measures your brokers use, because those are the ones that cost money. MTM’s Virginia handbook lists these for providers:

Missing these standards can lead to liquidated damages under your service agreement, a performance improvement plan, or being dropped from the network. The handbook also sets out a point system for safety and service violations. MTM can assess points after an in-person field audit, a complaint, or monitoring by DMAS (the state Medicaid agency), and each point stays on your record for a year:

Small things earn points. One point each goes to a driver observed without an MTM-issued name tag, an unbuckled rider, a van that moves before the passenger is secure, and loading or unloading in an unsafe spot. Other brokers set different bars. Louisiana’s Medi Trans manual expects at least 90% on-time pickups and drop-offs, zero missed trips, and an overall complaint rate below 1%. It can take a credit of up to 10% of a month’s invoices when more than 10% of trips are unexcused late drop-offs. Our guides to on-time performance and broker penalties cover how those numbers are calculated and charged.

The monthly trip audit

A trip audit compares what your records say happened with what should have happened. Pull a sample of completed trips every month and check each one the same way.

Size the sample. CareOregon requires its brokerages to verify 5% of all NEMT trips before and after the trip, which makes 5% a reasonable starting point. As an example, a company running 2,000 trips a month would audit about 100. Spread the sample across every driver, every service level, weekdays and weekends, and every payer. Add extra trips for any driver who drew a complaint that month.

Check each trip against this list:

Signatures deserve a close look. Under WellTrans’s agreement, a rider who is unable to sign can have someone from the household, a designated caretaker, or a staff member at the drop-off facility sign instead, using that person’s own name and relationship to the rider. Drivers and attendants may not sign the rider’s name. Trips left unsigned or marked with initials are not paid. For a no-show, MTM’s Virginia handbook expects the driver to try calling or texting the rider before driving away.

Some brokers audit the trip’s purpose too. WellTrans checks that riders attended the appointments on their reservations. When a facility says a rider you billed never arrived, a written answer must reach WellTrans no more than 30 days after it asks, or WellTrans counts the trip as never run and recovers the payment.

Record each audited trip as pass or fail on every check, with a note on each failure. Our broker audit guide lists the records auditors ask for, and trip reconciliation catches billing errors the audit turns up.

Rider callbacks and field checks

Trip records tell you what happened, not how it felt to the rider. A short monthly round of calls fills that gap.

1. Pick the riders. Choose a set number each month, for example 20, mixing new riders, regulars, wheelchair riders, and riders from each facility you serve.
2. Confirm who you are talking to. Verify the rider or their representative before discussing any trip.
3. Ask the same five questions. Was the pickup on time? Did the driver help you the way you needed? Was your seat belt or wheelchair secured before the van moved? Was the vehicle clean and comfortable? Is there anything we should fix?
4. Write down the answers word for word. Paraphrased answers lose the detail you need. Call in the rider’s language, with an interpreter if needed, and let a family member or caregiver answer for a rider who cannot.
5. Treat any problem as a complaint. Log it, investigate it, and answer it on the same clock as any other complaint.

The seat belt and securement question matters because brokers watch for it. MTM Virginia gives a point for an unbuckled rider and more for a confirmed securement complaint. Keep your survey questions the same from month to month so the answers can be compared. A ready-made rider satisfaction survey gives you a starting set.

Brokers also check in person, so you should too. MTM Virginia assesses points from in-person field audits. Once a month, have a supervisor watch arrivals at a busy dialysis center or clinic. Check name tags, seat belts, safe loading spots, and whether drivers stay with riders who need hand-to-hand service.

Complaint tracking and trends

One complaint is a customer service problem. Ten complaints about the same route are a quality problem. Log every complaint in one place, whatever its source: a rider, a facility, a broker, a callback, a driver’s report, or an online review. Then count them.

• Use a rate, not a count. Take complaints, divide by completed trips, and multiply the result by 1,000. MTM Virginia’s standard of under 0.1% equals fewer than one substantiated complaint per 1,000 trips.
• Sort by type. Late pickup, missed trip, driver conduct, vehicle condition, securement or safety, billing.
• Sort by where it happens. By driver, by vehicle, by time of day, by pickup or drop-off location, and by payer.
• Look for clusters. Several late complaints from one facility at 2 p.m. point at the schedule, not the driver.
• Separate substantiated from unconfirmed. Brokers count substantiated complaints, and you need both lists to spot a driver with a pattern.

A complaint log template keeps the columns consistent, and our guide to answering broker complaints covers the reply when a broker forwards one.

Turning findings into corrective action

A finding without an owner is just a note. CareOregon’s provider manual names six parts that any corrective action plan or performance improvement plan needs, and the list works for internal plans too:

1. The factors that contributed to the problem
2. The person or people responsible for carrying out the plan
3. The specific actions that will fix it
4. A timeline that ends in a firm deadline
5. Any way the problem affects riders’ access to care
6. How performance will be checked afterward to keep it from happening again

Aim the action at the cause. OSHA’s guide to incident investigations warns that weak fixes, such as a note that employees must remember to follow a rule, are unlikely to prevent the next incident. If one driver misses pickup windows, look at the schedule you gave that driver before you write the driver up. Our guide to investigating an incident walks through finding the root cause, and the glossary explains how brokers use a corrective action plan.

Close each plan with proof. Re-audit the same driver, route, or process the following month, record the result, and keep the plan, the evidence, and the follow-up together in case a broker asks.

A month of quality work

A small company can run the whole program in a few hours a week.

Keep the meeting short: the numbers, the three biggest problems, who owns each fix, and last month’s results. Track the program’s own numbers alongside your other NEMT KPIs.

Running quality checks from HealthRide trip records

Every trip in HealthRide keeps its scheduled and actual times, GPS-recorded miles and the route driven, signatures, and recorded wait times on no-shows, so the monthly audit starts from complete records instead of paper. The reports include on-time performance overall and per driver, and a trip log that downloads as a print-ready PDF or a spreadsheet, ready for your audit sample or a broker’s request.