What is waiver transportation (HCBS non-medical transportation)?
Waiver transportation is a Medicaid home and community-based services (HCBS) waiver benefit that pays for rides to the jobs, day programs, and community activities in a participant's service plan. CMS calls it non-medical transportation. It is offered in addition to regular NEMT, never instead of it, and each state sets its own provider rules, rates, and paperwork.
On this page
Where waiver transportation comes from
HCBS waivers let states pay for long-term services at home and in the community instead of in an institution. Transportation is one service a state may add. It can come through a section 1915(c) waiver, a 1915(i), (j), or (k) state plan amendment, or a section 1115 demonstration.
CMS’s waiver technical guide sets the ground rules:
- Purpose. Rides help participants reach waiver services and other community services, activities, and resources named in their service plan.
- Never a substitute. It does not replace NEMT. Medical trips are billed as state plan transportation.
- Free help first. Family, neighbors, friends, or community agencies who can drive at no charge come first.
- No double billing. When another waiver service, such as adult day health, already includes transportation in its rate, the state must stop the ride from being billed twice.
- Children too. Participants under 21 can receive it.
How a waiver ride gets authorized
Waiver rides start with the service plan, not a phone call to a broker. The need is identified while the participant’s individual service plan is developed, and the plan documents whether the person needs a modified vehicle. Ohio’s case managers are called service and support administrators. In Ohio’s Individual Options waiver, the case manager also makes sure a budget limit is set for the service.
Ohio’s rule as an example
Ohio Administrative Code 5123-9-18, effective January 2, 2025, covers waiver transportation under the Individual Options, Level One, and SELF waivers. It shows the level of detail states write into these rules.
- Destinations. A job, adult day support, career planning, employment support, vocational habilitation, volunteer work, post-secondary education, an internship, or a transfer point on the way to one.
- Driving records. Drivers need a Bureau of Motor Vehicles record pulled within 14 days before hire. Six or more points disqualifies a driver. Agencies pull a new record at least every three years.
- Vehicles. Modified vehicles and vehicles for five or more passengers get a documented daily check by the first driver. They also need an inspection at least every 12 months by the State Highway Patrol or a certified mechanic.
- Records for every trip. The mode, date, license plate, rider’s name and Medicaid number, provider name and ID, origin and destination, start and stop times, the driver’s signature or initials, and the names of everyone in the vehicle. Per-mile trips add odometer or GPS miles.
- Rates. Per-trip rates are paid per person, whatever the number riding together, and vary by county cost category. Per-mile rates depend on the number of riders and whether the vehicle is modified.
An example
A participant rides to adult day support five mornings a week. In Ohio, the trip between home and the program is authorized at the per-trip rate. If three other participants ride in the same van, each person’s trip is billed at the per-person rate. The driver’s trip log records the plate, times, origin, destination, and every rider’s name.
Waiver transportation vs NEMT
| NEMT | Waiver transportation | |
|---|---|---|
| Goes to | Covered medical care | Community destinations in the service plan |
| Legal basis | 42 CFR 431.53 and 440.170 | A 1915(c) waiver or other HCBS authority |
| Who sets it up | A broker, plan, or state program | The participant’s case manager, through the service plan |
| Paid from | The Medicaid state plan | Waiver funds, within any budget the service plan sets |
The broader term is covered in non-medical transportation. For group routes to day programs, see adult day care transportation software. For Ohio’s state plan rides, see the Ohio NEMT guide.
Waiver rides to the same program every weekday fit recurring trips in HealthRide: schedule the series once and it keeps going.
Frequently asked questions
- Can waiver transportation be used for doctor visits?
- No. CMS says waiver transportation may not replace the transportation a state must provide under its Medicaid plan. A waiver participant's ride to a doctor is billed as regular NEMT or as an administrative expense, not as a waiver service.
- Can a NEMT company provide waiver transportation?
- Yes, if it meets that waiver's provider rules. In Ohio, an agency provider needs a Medicaid provider agreement, certification from the Department of Developmental Disabilities, driving records for every driver, and written policies on vehicle accessibility, maintenance, and driver requirements.
- Is waiver transportation billed per trip or per mile?
- It depends on the state. Ohio uses both. A ride between home and a job or day program is normally authorized at a per-trip rate. Other rides are authorized per mile, and the rate depends on how many people ride and whether the vehicle is modified.
