How to prepare for a Medicaid NEMT audit

Last reviewed October 9, 2026

An audit asks one question about every trip you billed: can you prove it happened, the way you billed it, with a qualified driver and vehicle? This checklist helps you answer yes before anyone asks.

This is general information, not legal advice. What an auditor asks for depends on your state, your program, and your broker or managed care contract. Confirm the requirements with your state Medicaid agency or your broker.

Who can audit you

Your state Medicaid agency. Your provider agreement requires you to give the agency, HHS, and the state Medicaid Fraud Control Unit your records on request (42 CFR 431.107). CMS expects states to run regular audits of their transportation programs (CMS Transportation Coverage Guide).
Your broker or managed care plan. Brokers are subject to regular auditing by the state (42 CFR 440.170). Your contract may also let them review your records, so check what it says.
The HHS Office of Inspector General. OIG has audited NEMT claims in many states and has repeatedly flagged NEMT as vulnerable to fraud, waste, and abuse (HHS OIG, A-05-18-00043).

What auditors check

In its 2020 audit of Indiana's NEMT program, OIG checked five things for each sampled claim (HHS OIG, A-05-18-00043):

The rider received a Medicaid-covered service on the date of the trip.
The transportation provider met the state's qualifications.
The vehicle met state rules.
Paperwork such as certificates, provider agreements, prior authorizations, and insurance was on file.
The provider kept records supporting every service it billed.

To check those, OIG asked providers for trip logs, driver's licenses, vehicle registrations, vehicle insurance, and surety bonds. Your audit may cover different ground, but this is a good picture of what to have ready.

The checklist

Trip records

Every billed trip has a record with the rider's name and Medicaid ID, pickup and drop-off locations, date and time, and loaded miles. CMS says all states require at least these.
Every trip that needed prior authorization has its authorization number on the record.
Signatures are on the record if your state or broker requires them, or a written reason if the rider couldn't sign.
The level of service billed (ambulatory, wheelchair, stretcher) matches what the rider needed.
No-shows and cancellations are recorded and were not billed.
Miles billed are loaded miles only.
Every trip went to or from a covered medical service.

Sources: CMS NEMT booklet. For what each field means, see NEMT trip documentation requirements.

Driver files

A copy of each driver's valid license, of the class your state requires for the vehicle.
Proof you checked each driver against the HHS OIG exclusion list (LEIE) and SAM.gov, with dates. CMS guidance points to monthly checks.
Your process for disclosing each driver's driving history to the state Medicaid program.
Your process for handling a driver's violation of a state drug law.
Anything else your state requires, such as background checks, training, or health certification.

Sources: CMS Transportation Coverage Guide, SMDL #09-001, CMS NEMT booklet.

Vehicle files

Registration for each vehicle, with the VIN matching the ownership papers and the plate on the right vehicle.
Proof of the liability insurance your state requires, current for the dates you billed.
Inspection and maintenance records, if your state requires them.
Any vehicle certification or permit your state requires.

Sources: CMS NEMT booklet, CMS Transportation Coverage Guide.

Business records

Your signed Medicaid provider agreement and your broker or managed care contract. CMS says Medicaid won't pay for trips run without a contract in place.
Your enrollment, certifications, and any surety bond your state requires.
A written documentation policy that drivers are trained on, including consequences for falsifying records.
A written process for verifying trips before you bill.
Records kept for as long as your state and contract require. This varies; Indiana, for example, requires 7 years from the date of service.

Sources: CMS NEMT booklet, HHS OIG, A-05-18-00043.

Run your own audit first

CMS recommends owners verify trips themselves, for example by calling riders on the log and staff at the medical facility (CMS NEMT booklet). A simple version for a small fleet:

Pick 10 to 20 billed trips at random from a past month.
For each one, pull the trip record, the driver's file, and the vehicle's file.
Check each against the checklist above, and against the claim you submitted.
Call a few of the riders or facilities to confirm the trip.
Fix the process behind anything you find, not just the one record.

If you find you were paid for a trip you can't support, don't sit on it. CMS says a provider must return payment for an improper claim (CMS NEMT booklet). Ask your state agency or broker how they want it reported.

Keep records safe through changes

In the Indiana audit, every one of the 17 trips without records came from a provider that had closed, left the NEMT program, moved, or couldn't find the files (HHS OIG, A-05-18-00043). Indiana's retention period runs 7 years from the date of service, so leaving the program didn't end it. Keep a copy somewhere that survives a move, a lost phone, or a closed office.

When the audit notice arrives

Read the request closely: which trips, which dates, which documents, and the deadline.
Send exactly what was asked for, on time. Ask the auditor if anything is unclear.
Keep a copy of everything you send and a log of when you sent it.
Never create, change, or backdate a record after the fact. CMS lists falsifying trip records among the fraud cases it has seen prosecuted (CMS NEMT booklet).
If the audit alleges fraud or a large overpayment, talk to a healthcare attorney.

Keeping the trip record without the paperwork

Beridy's driver app records the GPS location and time at pickup and at drop-off on every ride, and collects the rider's signature or the reason there isn't one, so each trip has a record you can pull up by date. The record is self-verified by Beridy, not a certified state EVV submission, and Beridy does not submit Medicaid claims, so check with your state or broker that it meets their requirements. It costs $0 a month and $0.50 per completed ride. See Beridy for NEMT, start with the free NEMT trip log template, or create your account.