The Center for Medicaid and Medicare Services (CMS) is currently conducting four Listening Sessions related to the Medicaid non-emergency medical transportation benefit.
The sessions are specifically designed to receive direct input from industry stakeholders on program integrity and how it can be improved. The agenda for each 90-minute web-based video call addresses important policies to CMS and the NEMT providers that operate under the requirements every day.
In addition, CMS leadership seeks input and potential best practices that improve NEMT program integrity.
These stakeholder meetings are being held due to provisions detailed in the Consolidated Appropriations Act, 2021, Division CC, Title II, Section 209, concerning Medicaid coverage of specific medical transportation (section 209). This provision formally places in statute the longstanding regulatory interpretation of the Social Security Act (the Act) that generally requires states to assure necessary transportation for beneficiaries to and from covered services.
The Act further requires the state Medicaid plan to provide methods and procedures as may be necessary to assure that “payments are consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers so that care and services are available under the plan at least to the extent that such care and services are available to the general population in the geographic area. There is a lot to unpack in that paragraph, but I will leave that for a future article.
NEMT Listening Session 1 was held on March 10th, 2022. CMS was interested in hearing from the participants on provider enrollment requirements and eligibility determinations for Providers/Drivers. Many NEMT company owners and operators participated in the session, and each had an opportunity to share their ideas and best practices with CMS leadership.
Some of the topics included:
• Driver background screenings
• Patient abuse, neglect, and exploitation by drivers.
• Driver identification to the State Medicaid Agency (SMA)
• Subcontracted transportation company identification to the SMA?
NEMT Listening Session 2 covered topics related to program integrity, correct billing concerns, documentation, and data requirements for NEMT Providers. Providers were also able to weigh in on the Broker model and reimbursement for services rendered.
Other topics for this session included:
• No shows/payment for missed NEMT appointments
• No-shows for rides
• No-load trips and miles
• Trips for non-medical services
• Trips to nowhere
• Late pick-ups and driver no-shows
• Up-coded services and exaggerated miles
• Inappropriate/unapproved transportation for family members
• Patient brokering, kickbacks, etc.
NEMT Listening Session 3 was rescheduled for April 28th at 2: 00 pm ET and will cover the economic and cost containment challenges in NEMT. If you would like to listen to or participate, you can register for NEMT Listening Session 3 https://bit.ly/3uC1NB6
The session is sure to be interesting as providers weigh in on topics such as:
• Transportation-related expenses and direct payments
• Meals, lodging, and payment for an attendant
• Transportation for beneficiaries with challenging behaviors
• Direct payments to beneficiaries, family, and volunteer drivers
• Broker conflict of interest (COI)
• Broker prohibition on providing transportation
The fourth and final NEMT session will be held on April 13th at 2 pm ET and will cover Brokers, MCOs, Community Transportation, and Paratransit Services. CMS leadership will be seeking input on broker arrangements and usage of community transportation and paratransit services. You can register for this session here: NEMT Listening Session 4
Additional topics include:
• Access to services, timely arrival and drop off
• Rural issues
• Tribal land issues
• Coverage of transportation to services not provided by Medicaid.
As noted in previous articles, the NEMT industry is changing rapidly. The CMS Listening Sessions are a seminal event for the industry that could shape NEMT service delivery for years. States and other entities that administer NEMT benefits improve program administration, program integrity, and the beneficiary experience.
These changes create new opportunities for NEMT providers that embrace technology and have robust customer service and compliance policies in place.
As best practices emerge from the regulatory bodies and industry stakeholders, NEMTAC is uniquely positioned as the ANSI Accredited Standards Developer to advocate for all NEMT stakeholders and serve as a trusted source of information, and education, in the medical transportation industry.