What does fee-for-service mean in Medicaid NEMT?
Fee-for-service (FFS) is the Medicaid payment model where the state pays an enrolled provider directly for each covered service it bills, at rates in the state fee schedule. In FFS NEMT, the fleet enrolls with the state Medicaid program, gets each trip approved as the state requires, and submits a claim for the base rate and loaded miles.
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How fee-for-service NEMT works
In fee-for-service, no plan or broker stands between you and the state’s payment. The state Medicaid program pays you for each trip you bill. When a state covers transportation as a medical service, 42 CFR 440.170(a)(2) requires that payment go straight to the provider, and riders keep their free choice of qualified providers.
The work generally follows five steps:
- Enroll with the state Medicaid program under its transportation provider type, using your NPI or the atypical provider ID some states issue instead.
- Get the trip approved the way the state requires. That can mean prior authorization for every trip or only for long trips.
- Drive and document the trip: times, addresses, riders, and odometer or GPS miles.
- Bill the state’s claims system with the right billing codes, usually a base rate plus loaded miles.
- Get paid at the fee schedule rate, with a remittance showing what was paid or denied.
FFS rules differ by state
| State | Trip approval | Where claims go | Rule to know |
|---|---|---|---|
| Texas | HHSC’s Medical Transportation Program prior-authorizes every trip | TMHP | File within 95 days of service (365 for out-of-state providers) |
| Arizona | Prior authorization only for trips over 100 miles in a day | AHCCCS, by web portal, 837P, or CMS-1500 | All same-day trips for one member go on one claim, with the AHCCCS Daily Trip Report |
| New York | The state broker, MAS, issues a prior authorization after the provider attests the trip | eMedNY | Claims are due within 90 days of the date of service |
| Colorado | Providers in the 55 counties outside the Denver metro broker area verify trip requests themselves | HCPF, directly | Direct billing ends when MediDrive takes over statewide on January 1, 2027 |
New York shows that FFS and brokers can mix. MAS approves trips and negotiates provider rates, but the state claims system still pays each claim.
An Arizona example
An AHCCCS fee-for-service member rides 22 loaded miles to a clinic and 22 miles home the same day. The day totals 44 miles, under the 100-mile line, so no prior authorization is needed. The provider bills both legs on one claim: two base-rate trips on the first line and 44 loaded miles on the second, with the Daily Trip Report attached. A claim with only the base code and a second claim with only the mileage would both be denied as split billing.
FFS vs nearby terms
- Managed care: the state pays a health plan a monthly capitation rate, and the plan, often through a broker, pays you at contract rates.
- Broker payment: in most broker programs, the broker pays you under its provider agreement, not the state.
- Fee schedule: the list of rates FFS pays. CMS lets states adopt Medicare rates, set their own, or pay interim rates reconciled to cost.
For billing steps, see how to bill Medicaid for NEMT and the Texas, Arizona, and New York guides.
HealthRide’s trip log in reports lists every leg with scheduled and actual times, addresses, driver, vehicle, and GPS-verified miles, and it exports to a spreadsheet or PDF.
Frequently asked questions
- Where do I find my state's fee-for-service NEMT rates?
- In the state Medicaid fee schedule or the transportation chapter of the provider manual. States can adopt Medicare rates, set their own fee schedule, or pay interim rates reconciled to actual costs. Managed care and broker rates are different and are set in each contract.
- Can I take fee-for-service and broker trips at the same time?
- Yes, in states that run both. In Texas, HHSC's Medical Transportation Program handles fee-for-service clients, and providers enrolled with TMHP bill those trips to TMHP. Managed care plans approve rides for their own members, often through a broker such as Modivcare, and those trips need a separate contract with that broker.
- Does fee-for-service Medicaid pay for deadhead miles?
- Generally not as a separate charge. CMS says miles driven without the rider on board usually cannot be paid directly, but states may build their cost into the base rate. Since September 2023, a state may also pay unloaded miles when a pickup would cost the provider an extraordinary amount, but it must first submit a state plan amendment to CMS.
