A0110: Bus and transit pass billing code
A0110 is the HCPCS code for non-emergency transportation by bus, on an intrastate or interstate carrier. Medicaid programs use it for bus tickets and transit passes. Arizona, Colorado, and Louisiana pay the actual cost of the fare or pass rather than a flat rate. Medicare does not pay it. Arizona caps a pass claim at the cost of a 30-day pass.
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A0110 in the HCPCS file
The CMS HCPCS file for October 2026 lists A0110 as “Non-emergency transportation and bus, intra or inter state carrier.” The code dates to 1984 and carries Medicare coverage code I, not payable by Medicare. The descriptor covers local and long-distance bus travel, and it sets no unit.
What A0110 covers
In practice, A0110 pays for bus fare: single tickets, day passes, and monthly transit passes for members who can ride public transportation. Colorado covers public transit when it is the least costly mode that fits the member’s condition. A transit pass may be issued when the cumulative cost of bus trips exceeds the cost of the pass.
Because fares differ by transit system, Arizona, Colorado, and Louisiana price A0110 by the actual cost, not by a statewide rate. In Arizona, the claim carries the net cost of the pass.
How four states use A0110
Arizona (AHCCCS). Since October 1, 2021, eligible fee-for-service providers can issue public transportation passes and bill A0110 for the net cost, up to the cost of a 30-day pass. A pass can last up to one month. Replacement or duplicate passes are not reimbursable. The claim needs a copy of the pass, an itemized receipt, pricing for the area where it was issued, and a completed Public Transportation Pass form (Chapter 14, revised July 31, 2026).
Colorado. A0110 is manually priced per trip on the July 1, 2026 fee schedule. Colorado also gives the code different meanings through modifiers:
| A0110 modifiers | Colorado meaning |
|---|---|
| TN | Fixed route, one-way, local |
| SC, SE, TN | Fixed route, one-way, regional |
| SE | Paratransit, one-way |
| None | Public or mass transportation, bus service |
Colorado counts one unit per one-way ticket. Its paper claim instructions single out A0110 as the NEMT code that may need one of these modifiers.
Louisiana. The October 1, 2025 NEMT fee schedule pays A0110 for either a daily or a monthly pass. The rate is based on geographic location and the usual and customary cost.
Oregon. OHA’s provider guide, updated December 22, 2025, maps commercial bus travel to A0110. City bus transit, bus tickets, and passes go under A0120 instead.
Where A0110 claims go wrong
- Billing a flat rate where the state pays cost. In Arizona, Colorado, and Louisiana, A0110 follows the actual fare. Keep the receipt.
- Buying more pass than the care plan needs. Arizona expects the pass length to match the member’s upcoming appointments.
- Replacing a lost pass on Medicaid’s dime. Arizona will not pay for replacements.
- Assuming the code means the same thing everywhere. Oregon’s split between A0110 and A0120 is the clearest example.
Multi-ride passes on commercial carriers can also appear under T2004 in some programs. For the full code list, see NEMT billing codes. For claim basics, read how to bill Medicaid for NEMT.
Frequently asked questions
- Who bills A0110?
- Whoever the program allows to buy the ticket or pass. In Arizona, fee-for-service providers in eligible provider types bill A0110 for the net cost of a public transportation pass they issue. In Colorado, bus pass reimbursement can be denied when the member does not give the broker proper documentation within the filing deadline.
- How much does Medicaid pay for A0110?
- Usually the cost of the fare. Colorado lists A0110 as manually priced per trip. Louisiana pays for a daily or monthly pass at the usual and customary cost for the area. Arizona pays the net cost of the pass, up to the price of a 30-day pass. New York is different. Its fee schedule lists fixed amounts for A0110 county by county.
- Is a city bus pass always billed under A0110?
- No. Oregon's provider guide puts city bus transit tickets and passes under A0120 and keeps A0110 for commercial bus travel. Always check the state's code list before you bill a pass.
