What is a transportation network company (TNC) in NEMT?
A transportation network company (TNC) is a rideshare business that connects passengers with drivers through an app or website. In NEMT, states and brokers can use TNCs for riders who can travel in an ordinary car. CMS treats TNCs as a type of transportation provider, so the least costly, most appropriate test and the federal driver requirements apply to them and their drivers.
On this page
What makes a company a TNC
A TNC matches passengers with drivers through its own app or website, and the drivers use their personal vehicles. Texas law is a clear example. Section 2402.001 of the Texas Occupations Code defines a TNC as an entity that, for pay, lets a passenger prearrange a ride with a driver exclusively through the company’s digital network. Street-hail taxis, limousines booked other ways, and shared-expense carpools are left out.
NUCC gave TNCs their own provider taxonomy code, 342000000X, on January 1, 2021. Its definition covers rideshare companies that provide prearranged or contracted NEMT through mobile or online technology.
How TNCs fit into Medicaid transportation
CMS treats a TNC as one more type of transportation provider. States decide whether and how to use them, within two federal limits:
- Least costly, most appropriate. The ride must still be the cheapest mode that meets the rider’s medical needs.
- Efficiency, economy, and quality. Payment must hold up on cost and care, which can include economies of scale from a contract with the TNC.
The federal minimum driver rules from 2021 name TNCs directly. Each TNC and each individual driver must be free of federal health program exclusions, and every driver needs a valid license. The TNC also needs processes for drug law violations and for reporting drivers’ driving history to the state.
How states handle TNCs
- Texas. TNCs enroll with TMHP as a type of demand response provider in the fee-for-service Medical Transportation Program. They bill with an Atypical Provider Identifier and taxonomy code 347C00000X. The recommended procedure code is T2003.
- California. Rideshare is one of the non-medical transportation modes in Health Net’s Medi-Cal manual, for ambulatory members, including those who use a walker or cane or can transfer from a folding wheelchair on their own. Mileage reimbursement is a separate benefit. A plan summary of All Plan Letter 22-008 limits it to a personal or family vehicle, not a vehicle tied to a business such as Uber or Lyft.
TNC vs taxi vs NEMT provider
| TNC | Taxi | NEMT provider | |
|---|---|---|---|
| How rides are booked | Only through the company’s app or website | Street hail or a dispatcher, under a local license | Broker, facility, or private booking, usually scheduled |
| Vehicle | The driver’s personal vehicle | A commercial vehicle that meets local taxi rules | Sedans, wheelchair vans, and stretcher vans |
| Best suited to | Riders who can use an ordinary car | Curb-to-curb riders, in New York’s definition | Riders who need a lift, securement, a stretcher, or hands-on help |
An example
Picture a broker with two open requests at 2 p.m. One is an ambulatory rider going to a pharmacy. The other is a wheelchair rider leaving dialysis. If the program allows TNCs, the first ride can go to one. The second needs a wheelchair-accessible vehicle and a driver trained in securement, which is where a NEMT fleet earns the trip. The broker’s level of service review decides which is which.
HealthRide sends riders a tracking link so they can follow their vehicle live, much like rideshare tracking (live map).
Frequently asked questions
- Can rideshare drivers do Medicaid trips?
- Yes, when the state or broker contracts with the TNC and the drivers meet the rules. Federal law requires each TNC and each driver to be free of federal health program exclusions, and every driver needs a valid license. The TNC also needs processes for drug law violations and for reporting driving history to the state.
- Does a TNC need a taxonomy code?
- NUCC added 342000000X, Transportation Network Company, on January 1, 2021. Some states ask for something else. Texas tells TNCs enrolled in its Medical Transportation Program to use 347C00000X, Private Vehicle, on claims, along with an Atypical Provider Identifier.
- Can a TNC take wheelchair riders?
- Usually not. CMS says a rider who uses a wheelchair must travel in a wheelchair-accessible vehicle, and a typical rideshare car is not one. Some plans draw a narrow line. Health Net's Medi-Cal manual allows rideshare for a member who can move from a folding wheelchair into the car without help. Riders who stay in their chair, and stretcher riders, go to NEMT fleets with the right vehicles and trained drivers.
