T2004: Commercial carrier multi-pass billing code
T2004 is the HCPCS code for non-emergency transport on a commercial carrier with a multi-pass, such as a pass good for several rides. Medicare does not pay it. States use it in different ways: Colorado bills waiver public conveyance under T2004 in dollar units, while Oregon uses it for train travel. In those two states it pays for carrier fares, not for a van company's own trips.
On this page
The descriptor, word for word
The CMS HCPCS file for October 2026 lists T2004 as “Non-emergency transport; commercial carrier, multi-pass.” Note the wording: “transport,” not “transportation,” unlike its neighbors. The short descriptor is “N-et; commerc carrier pass.” T2004 was added in April 2002 and carries Medicare coverage code I, not payable by Medicare.
What T2004 covers
The descriptor points to a member riding a commercial carrier, such as a bus line or a train, on a pass good for more than one ride. It does not name a unit, so the state picks one. Colorado counts dollars, and New York sets flat county rates.
How four states use T2004
Colorado (HCBS waivers). The billing manual for Colorado’s waivers for people with intellectual and developmental disabilities, revised August 25, 2026, lists “Other (Public Conveyance)” under non-medical transportation as T2004. The unit is a dollar, so the claim carries the cost of the fare. Distance-based waiver trips bill under T2003 instead. On the state’s regular NEMT side, bus travel stays on A0110.
Oregon. OHA’s Medical Transportation Services Provider Guide, updated December 22, 2025, maps train travel to T2004. Airline tickets go under A0140, commercial bus under A0110, and city bus passes under A0120.
North Dakota. The July 1, 2026 HCBS fee schedule lists T2004 as a covered HCBS service, with a general rate of $0 and no service authorization required. The schedule notes that listing a code does not by itself imply coverage or payment.
New York. The Medicaid transportation fee schedule dated April 5, 2026 defines T2004 as “commercial carrier” and lists it under the ambulette category in a few places, such as New York City with modifier TN at $64.60 (rate effective May 30, 2024). The schedule itself warns that its fees apply to the fee-for-service broker, may reflect network negotiations, and should not be read as service definitions by other payers.
T2004 pitfalls
- Using T2004 for your own van. In Colorado and Oregon, it pays for commercial carrier fares and passes or waiver conveyance, not a NEMT company’s trip.
- Billing a flat amount where the unit is dollars. Colorado’s waiver line counts dollars.
- Mixing up the train and bus codes. Oregon splits train (T2004), commercial bus (A0110), and city transit (A0120).
- Reading another state’s schedule as yours. New York tells other payers not to assume what its codes mean.
The state or broker sets the code, the unit, and who may bill. For every code in one place, see NEMT billing codes, and for the claim steps, see how to bill Medicaid for NEMT.
Frequently asked questions
- What is the difference between T2004 and A0110?
- A0110 describes bus travel on an intrastate or interstate carrier. T2004 describes a commercial carrier multi-pass. In practice the line blurs, and each state decides. Arizona and Louisiana bill bus passes under A0110, while Colorado's waivers bill public conveyance under T2004.
- How is T2004 priced?
- It varies. Colorado's HCBS waiver manual bills T2004 in dollar units, so the units equal the cost of the fare or pass. North Dakota's HCBS fee schedule lists T2004 as covered with a general rate of $0. New York lists fixed county rates under its ambulette category.
- Can a NEMT company bill T2004?
- Only where the payer enrolls it for that service. In Colorado and Oregon, T2004 pays for carrier fares, passes, or waiver conveyance, not for a company's own van trips. New York is the exception here, because its schedule lists T2004 under the ambulette category in a few counties.
