NEMT trip documentation requirements

Last reviewed October 9, 2026

If you bill Medicaid for rides, your trip records are what get you paid and what an auditor checks. Federal rules set a floor. Your state and your broker or managed care plan set the details.

This guide covers what NEMT providers are generally expected to keep and where to confirm the rules that apply to you.

This is general information, not legal advice. Requirements differ by state, by program, and by broker or managed care contract. Confirm what applies to you with your state Medicaid agency or your broker.

Why trip records matter

Every Medicaid provider signs an agreement to keep the records needed to show the extent of the services it provides, and to hand them over on request to the state Medicaid agency, HHS, or the state Medicaid Fraud Control Unit (42 CFR 431.107). For a transportation provider, those records are your trip logs.

CMS puts it plainly in its booklet for NEMT providers: if a service is not documented, there is no point in submitting a claim for it. The same booklet says a provider must return any payment it received for an improper claim (CMS NEMT booklet).

This is where audits find problems. In a 2020 audit of Indiana's NEMT program, the HHS Office of Inspector General found that for 17 of 120 sampled claims, the provider could not produce records showing the trip happened (HHS OIG, A-05-18-00043).

Who sets the rules

Federal regulations require each state to make sure Medicaid members can get to and from their providers, and to describe how it will do that (42 CFR 431.53). States can run NEMT themselves, contract with a transportation broker, or include it in managed care plans (42 CFR 440.170, CMS NEMT booklet).

The documentation rules mostly come from the state. CMS says each state decides what must be documented, that brokers and transportation companies often add their own requirements on top, and that providers are responsible for knowing the rules in every state where they operate. Most states publish a transportation provider manual (CMS NEMT booklet).

Where to look:

Your state Medicaid agency's transportation provider manual.
Your contract with the broker or managed care plan that sends you trips.
Your state's Medicaid agency, found through the Medicaid.gov state profiles.

What to record on every trip

The minimum

According to CMS, all states require providers to document at least the following (CMS NEMT booklet):

The rider's name and Medicaid ID.
The pickup and drop-off locations.
The date and time of the trip.
The miles driven with the rider in the vehicle (loaded miles).

Commonly required on top of that

These depend on your state and broker. Check which ones apply to you.

An authorization or trip number. Many states require trips to be authorized before the ride, and each state sets its own process (CMS NEMT booklet).
The rider's signature. Some states and brokers require the rider to sign the trip record at the end of the trip (CMS NEMT booklet).
The level of service. Ambulatory, wheelchair, or stretcher. Billing a more expensive mode than the rider needed is one of the fraud patterns CMS describes (CMS NEMT booklet).
Which driver and vehicle did the trip. Auditors check that the driver and vehicle met state requirements; OIG's Indiana audit asked providers for trip logs, driver's licenses, vehicle registrations, and vehicle insurance (HHS OIG, A-05-18-00043).
No-shows and cancellations. A no-show is not billable. CMS names billing loaded miles for a rider who didn't show up as a common form of NEMT fraud (CMS NEMT booklet). Record it as a no-show instead of leaving a gap.
Destination. Medicaid covers trips to and from covered medical services. CMS says a trip to a store or a friend's house is not covered and should not be billed (CMS NEMT booklet).

Want a sheet that covers these? Use the free NEMT trip log template.

Driver and vehicle records

Since the Consolidated Appropriations Act, 2021, federal law requires states to have a way (which can be an attestation) to make sure that every NEMT provider and driver meets these minimums (CMS Transportation Coverage Guide):

The provider and each driver are not excluded from federal health care programs and are not on the HHS OIG exclusion list.
Each driver has a valid driver's license.
The provider has a process to address any violation of a state drug law.
The provider has a process to disclose each driver's driving history, including traffic violations, to the state Medicaid program.

Beyond those, CMS says driver and vehicle standards are set by the states. Examples CMS gives include a chauffeur's license for taxis and vans, limits on license points, driver health certification, vehicle liability insurance, safety inspections, and background checks (CMS Transportation Coverage Guide). States may also ask for proof that each vehicle belongs to your business, that its VIN matches the ownership papers, that it is registered and insured, and that it is maintained (CMS NEMT booklet).

Exclusion checks

CMS has told states they should require providers to check employees and contractors against the HHS OIG exclusion list (LEIE) every month (SMDL #09-001). The CMS NEMT booklet recommends checking before you hire and monthly after that, and checking SAM.gov exclusions too. Keep a record of each check: the date, who you checked, and the result.

How long to keep records

It depends on your state and your contract. There isn't one federal NEMT retention period to point to. As one example, Indiana requires Medicaid providers to keep supporting records for 7 years from the date of service (cited in HHS OIG, A-05-18-00043). Your state or broker may require a different period, so check your provider manual and contract.

Keep the records even if your business changes. In the Indiana audit, providers lost records because they closed the business, left the NEMT program, moved locations, or simply couldn't find them. OIG counted each of those trips as unsupported.

Paper or electronic

There is no federal rule requiring ink, but CMS notes that some states require paper trip records to be in ink. If your drivers write on printed computer sheets, put that process in your written policy so an auditor understands why there is handwriting on a printed form (CMS NEMT booklet).

Whether your state or broker accepts electronic trip records, GPS data, or electronic signatures is up to them. Ask before you drop paper.

Check before you bill

CMS says that even when the rider signs, it is the owner's or manager's job to verify that trips happened as recorded. It suggests random calls to riders on the log and to staff at the medical facility to confirm the rider arrived. Bill only once the trip is verified, and bill what actually happened (CMS NEMT booklet).

A simple routine for a small fleet:

End of each shift: collect logs and check every row is complete, signed, or has a reason.
Each week: call a few riders or facilities from last week's log.
Each month: run exclusion checks on every driver and save the results.
Always: file records by date so you can pull any trip in minutes.

For the full list of what to have ready, read how to prepare for a Medicaid NEMT audit.

How Beridy handles trip records

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. 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 or create your account.