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PACE program transportation: the federal rules and how to win a PACE contract

Updated 7 min read

PACE organizations must provide transportation to the PACE center and to medical appointments as part of an all-inclusive benefit for people 55 and older who need a nursing home level of care. Under 42 CFR 460.76 the organization answers for every ride, even when a contractor drives it, so it hires contractors that maintain vehicles, train drivers, and keep complete staff records.

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What PACE is and why transportation matters so much

PACE, the Program of All-Inclusive Care for the Elderly, is a Medicare and Medicaid program that covers every medical and support service a participant needs. One organization provides the care, pays for it, and answers for it. Transportation is part of that package.

To enroll, a person must meet the rules in 42 CFR 460.150:

  • Be 55 or older.
  • Be certified by the state as needing a nursing home level of care.
  • Live in the PACE organization’s service area.
  • Be able to live safely in the community at the time of enrollment.

The benefit covers all Medicare and Medicaid services plus anything the care team decides the participant needs (42 CFR 460.92). Medicare.gov’s list of covered services includes rides to the PACE center and back, and to medical appointments.

The PACE center is why transportation is so central. Each center must provide primary care, nursing, social services, and restorative therapy on site. The care team decides how often each participant attends the center. Each visit is two rides, and each specialist appointment is two more.

The program count keeps rising. The National PACE Association counts 204 PACE programs serving more than 97,000 participants in 33 states and the District of Columbia. The 200th program opened in February 2026.

The federal transportation rules, in plain terms

The core rule is 42 CFR 460.76. It is short, and every line of it lands on a contractor.

RuleWhat it saysWhat it means for a contractor
460.76(a)Transportation must be safe, accessible, and equipped for the participant populationVehicles fit the riders: lifts or ramps, securements, room for walkers and oxygen
460.76(b)(2)If a contractor drives, the PACE organization must make sure vehicles are maintained to the manufacturer’s recommendationsKeep a maintenance record for every vehicle and expect to hand it over
460.76(c)Vehicles must be “equipped to communicate with the PACE center”Drivers need a working phone or radio link to the center on every run
460.76(d)The organization must train all transportation personnel, employees and contractors, in managing participants’ special needs and handling emergenciesThe PACE organization is responsible for training your drivers, so plan for its sessions and keep attendance records
460.76(e)Staff must tell transportation personnel about relevant changes in a participant’s care planSomeone on your side receives updates and gets them to the driver before the next ride

Transportation also shows up elsewhere in Part 460:

  • The care team includes the driver. The interdisciplinary team that plans each participant’s care must fill 11 roles, and one of them is “driver or his or her representative” (460.102(b)(11)).
  • Every plan of care covers transportation. It is one of the factors the plan must address, next to mobility and center attendance (460.106(c)).
  • Quality programs measure it. The organization’s quality improvement program must track nonclinical areas, and transportation services are named (460.134(a)(5)).
  • Drivers take grievances. A participant can file a grievance with any contractor who transports them (460.120), so drivers need to know how to pass a complaint to the program.

What a PACE organization will ask of you

A PACE organization cannot hand off responsibility. When it contracts transportation, it has to prove to CMS and the state that the contractor meets the same standards it would meet itself. Expect three layers of requirements.

The written contract

42 CFR 460.70 requires a written contract with every outside provider of care-related services. The contract must include:

  1. The contractor’s name.
  2. The services furnished, including the work schedule where it applies.
  3. The payment rate and method.
  4. Start and end dates, and how the contract is extended, renegotiated, or ended.
  5. The contractor’s agreement to furnish only services the care team authorized, accept the PACE payment as payment in full, hold CMS, the state, and participants harmless if the PACE organization does not pay, not assign the contract without written approval, and submit the reports the organization requires.

The contractor must also meet all federal and state requirements that apply to it, and must be located within or near the service area. The PACE organization names a liaison to coordinate with its contractors.

Personnel standards

Anyone on your team with direct participant contact is held to 42 CFR 460.64, 460.68, and 460.71. For drivers and attendants that means:

  • A valid license for the vehicle and any state credential the job requires.
  • One year of experience with a frail or elderly population, or training from the PACE organization at hire.
  • A competency check before working on their own, and orientation to the program.
  • Medical clearance for communicable diseases before first contact, through a physical exam or a documented risk assessment, plus a finding of no active tuberculosis.
  • Up-to-date immunizations.
  • No exclusion from Medicare or Medicaid, and no disqualifying criminal history.

What CMS checks during a PACE audit

CMS audits PACE organizations, and contracted drivers are inside the scope. The current PACE audit protocol tells the organization to list every contracted person who transported participants. CMS then samples up to 10 personnel records and looks for background checks, OIG exclusion checks, licenses, communicable disease clearance, tuberculosis screening, and completed competencies.

CMS also inspects at least one vehicle the organization uses. The protocol asks whether participants and equipment such as wheelchairs, oxygen, and walkers are secured, whether the vehicle can communicate with the center, and whether drivers were trained on special needs and emergencies.

A contractor who can produce those records the day they are requested is worth a lot to a PACE compliance team. Our driver file checklist covers the documents most programs ask for.

How PACE work differs from broker trips

PACE transportation looks like NEMT from the driver’s seat. The business side is different.

Medicaid broker tripPACE contract trip
Who paysThe broker, per completed trip, at your contracted rateThe PACE organization, under your written contract
Who authorizes the rideThe broker issues a trip numberThe PACE care team approves the service
RidersAny eligible member in your areaThe same enrolled participants, week after week
ScheduleTrip by tripCenter days, appointment blocks, and recurring routes
Staff rulesBroker credentialingPACE personnel rules, including medical clearance and competencies
BillingBroker portalInvoice to the PACE organization as the contract describes

Two practical differences stand out. First, PACE riders are frail and familiar. St. Paul’s PACE describes drivers who greet participants at the front door and help them into the vehicle. PACE KC calls its service door-through-door. Plan for more time at each stop than a curb-to-curb broker trip.

Second, PACE schedules repeat. Center attendance follows each participant’s plan of care, so much of the work runs as standing orders. That makes staffing easier to plan than trip-by-trip broker work.

How to win a PACE transportation contract

  1. Find the programs near you. The National PACE Association’s program finder lists every program and its service area. Your state Medicaid agency lists the PACE organizations it contracts with.
  2. Learn how each program runs transport today. Some run their own fleets. Others contract all or part of it. Ask where the gaps are: specialist appointments, wheelchair or stretcher trips, early or late center shifts, or days when their own vehicles are out of service.
  3. Build a PACE-ready file before you pitch. Have driver records that match 460.64 and 460.71, vehicle maintenance logs, a training outline covering special needs and emergencies, and proof of insurance.
  4. Show how you handle care plan changes. Explain who receives updates from the care team and how a change reaches the driver before the next pickup.
  5. Offer the reports their quality program needs. On-time arrival at the center, incidents, and grievances are the obvious ones.
  6. Price the contract with your costs in hand. See the next section.

Pricing a PACE contract: a worked example

Federal rules only require the rate and method to be written into the contract. There is no standard PACE rate, so you evaluate every offer against your own costs. The numbers below are illustrative, not market rates.

Suppose a PACE organization offers either a per-trip price or an hourly price for one wheelchair van running a morning and afternoon center route five days a week.

InputMorning and afternoon route
Hours the van and driver are committed7 per day
One-way trips carried16 per day
Your fully loaded cost per van hour (driver, fuel, insurance, maintenance, overhead)$48
Your daily cost7 × $48 = $336

At $26 per one-way trip, the day pays 16 × $26 = $416, a margin of $80. At $55 per hour, it pays 7 × $55 = $385, a margin of $49.

The per-trip offer looks better until the center cuts attendance. If a program change drops the route to 11 trips while you still hold the van and driver for 7 hours, the per-trip day pays $286 and loses $50. The hourly day still pays $385.

The lesson is simple: per-trip pricing moves the attendance risk to you, and hourly pricing moves it to the PACE organization. Price each contract with that trade in mind. Our break-even calculator runs the same math on your own numbers.

Running PACE routes in HealthRide

PACE work repeats every week, so HealthRide lets you schedule center rides once as recurring trips and keeps them going. Wheelchair, stretcher, and oxygen needs are matched to the right vehicle when a trip is assigned. The trip log shows scheduled and actual times for every leg, which is the record a PACE quality team asks for. See PACE transportation software.

Frequently asked questions

Do PACE participants use the state Medicaid NEMT broker for rides?
No. Under 42 CFR 460.90, a participant receives Medicare and Medicaid benefits solely through the PACE organization while enrolled, and rides to the PACE center and to medical appointments are part of the benefit. The PACE organization arranges and pays for the ride. A contractor accepts the PACE organization's payment as payment in full and cannot bill the participant, CMS, the state Medicaid agency, or private insurers for it.
What training do PACE transportation contractors need?
Federal rules require the PACE organization to train all transportation personnel, including contractors, in managing the special needs of participants and handling emergencies. Contracted staff with direct participant contact also go through the organization's orientation and a competency evaluation before working on their own. Each program can add its own requirements on top.
Do contracted PACE drivers need a TB test?
They need to be medically cleared for communicable diseases before any direct contact with participants, and found free of active tuberculosis. The clearance comes from a physical exam by a physician, nurse practitioner, or physician assistant, unless the PACE organization uses a documented risk assessment that shows an exam is not needed. Immunizations must also be up to date.
How do PACE organizations pay transportation contractors?
However the written contract says. Federal rules require the contract to state the payment rate and method, but they do not set a rate or a structure. The contract can price per trip, per hour, or per route. Whatever the structure, the contractor accepts the PACE payment as payment in full.
How many PACE programs are there?
The National PACE Association counts 204 PACE programs serving more than 97,000 participants in 33 states and the District of Columbia. Its Find a PACE Program tool lists each program and its service area.
Can a small NEMT company get a PACE contract?
Yes, if it meets the federal and state requirements and can document them. Size matters less than location and paperwork. The contractor must be located within or near the PACE organization's service area, and it has to pass the same personnel and vehicle checks CMS applies during a PACE audit.

Official resources

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