What are loaded miles in NEMT billing?
Loaded miles are the miles a NEMT vehicle travels with the rider on board, from pickup to drop-off. CMS guidance says they are the only miles Medicaid pays fee-for-service NEMT providers for. States measure them differently: Arizona bills odometer miles, while Colorado pays the shortest route on a map, so your contract decides the number you can bill.
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How loaded miles are defined
A loaded mile is a mile driven with the rider in the vehicle. Arizona’s AHCCCS manual defines loaded mileage as “the distance traveled, measured in statute miles, with a member on board the vehicle and being transported to receive medically necessary AHCCCS covered medical or behavioral health services.” CMS’s provider booklet gives a shorter version: the time a beneficiary is actually in the vehicle.
Loaded miles are billed separately from the base rate. Arizona wants the base rate on the first claim line, loaded miles on the second, and any wait time on the third. It denies claims that split the base rate and the mileage across two claims. Colorado bills ambulatory mileage with S0215, a change that took effect July 1, 2025, and wheelchair van mileage with S0209. It now keeps A0425 for ambulance mileage only.
How three states measure them
| Program | How loaded miles are measured |
|---|---|
| Arizona AHCCCS fee-for-service (manual revised July 31, 2026) | Actual loaded miles supported by odometer readings at pickup and drop-off. If the ride out and the ride home differ, you must justify the gap or the difference may be reduced. |
| Health First Colorado (manual revised July 17, 2026) | The shortest trip length in miles, determined by an internet-based map, trip planner, or GPS. |
| Minnesota Medical Assistance (Stat. 256B.0625, subd. 17b) | Mileage for the most direct route, plus odometer readings at pickup and drop-off and a note of the method used to find the route. |
Colorado also limits what it pays without review. A mileage claim over 52 miles, or over 125 round-trip miles a day for members in designated rural counties, is suspended for review and denied unless it carries the required trip attachment.
A worked example
Here is a hypothetical leg. The odometer reads 45,210.4 at pickup and 45,222.9 at drop-off, so the driver covered 12.5 miles with the rider aboard. A map’s shortest route is 11.8 miles, because the driver went around a closed ramp.
- Under a shortest-route rule like Colorado’s, you bill 11.8 miles.
- Under an odometer rule like Arizona’s, you bill 12.5 miles, and the payer may question it if the ride home comes in at 11.9.
Either way, write the detour on the trip log. Arizona may reduce an unexplained mileage difference, and a one-line reason is the justification it asks for.
What never counts as loaded
- The drive to the pickup. Those are deadhead miles.
- A no-show. CMS calls claiming loaded mileage for a rider who never boarded a common form of fraud.
- Errands without the rider, such as a prescription pickup on the member’s behalf in Arizona.
- Stops the reservation does not list. Virginia’s fee-for-service member handbook bars drivers from adding stops such as fast food or shopping.
On long trips, mileage can be most of what a leg pays. Our guide to how much Medicaid pays for NEMT covers per-mile rates, and the trip price calculator shows how base rate and mileage add up.
Recording every mile you bill
HealthRide records each trip’s GPS route automatically, and the live map compares the planned route with the path actually driven, with the verified mileage alongside.
Frequently asked questions
- Why is my billed mileage lower than my odometer reading?
- Some programs pay the shortest or most direct route, not the miles you drove. Colorado pays the shortest trip length from an internet map, trip planner, or GPS. Minnesota requires the mileage for the most direct route. A detour for traffic or a closed road can leave you with odometer miles you cannot bill, so write the reason on the trip log.
- Are loaded miles billed per rider or per vehicle?
- It depends on the program. Colorado says that when more than one member rides in the same vehicle to the same location, only one member ID may be used, and it will not pay multiple claims for the same vehicle's mileage. Arizona requires a separate trip report for each member showing the direct-route miles for that member's own pickup and drop-off.
- Can I bill miles for picking up a prescription for a rider?
- Not in Arizona. The AHCCCS manual bars any claim for unloaded mileage and names prescription pickup on the member's behalf as an example. A pharmacy stop with the rider aboard is a different case, and it still has to be authorized and documented on the trip report.
