EVV for NEMT: What Trip Verification Rules Mean for Your Operation

By Nick H., Head of Marketing at Bambi · November 5, 2026 · 6 min read

Medicaid spent $4.65 billion on non-emergency medical transportation in 2024, and lawmakers have started asking a blunt question: how do you prove the ride happened?

That question is turning into law. If you run Medicaid NEMT trips, here's what's on the table, what's already on the books, and what to fix in your recordkeeping before anyone makes you.

What EVV is, and why NEMT is next

Electronic visit verification (EVV) is a system that electronically records that a Medicaid service was actually delivered: who provided it, to whom, where and when. Federal law already requires EVV for personal care and home health visits.

NEMT has been outside that rule. That's changing. CMS classifies NEMT as a high-risk service, and a September 2026 House Energy and Commerce staff report named NEMT among the Medicaid services with high fraud rates, according to a KFF analysis published Nov. 2, 2026.

What's proposed in Congress

H.R. 10618, the Strengthening Tools for Oversight to Prevent Medicaid Fraud Act of 2026, was introduced on Sept. 28, 2026 and sent to the House Energy and Commerce Committee. As introduced, it would:

• Require state Medicaid programs to use an electronic verification system for NEMT trips (and ABA therapy) starting Jan. 1, 2027
• Model that system on the existing EVV rules for home care
• Exempt states that already require electronic verification for these services
• Give a state found out of compliance 90 days to submit a corrective plan and one year to comply

Most introduced bills never get a vote. But the direction is clear, and some states aren't waiting for Congress. If the bill does pass, states that already have their own trip verification rules would be exempt, so operators there would follow the state rules instead.

What states are doing

Minnesota: it's already law. The state Senate passed SF 4400 67-0 in May 2026, and its EVV language was folded into the state's health and human services bill (SF 4476), which the governor signed on May 27, 2026. Starting Jan. 1, 2027, or once federal approval comes through if that's later, enrolled NEMT providers must meet the state's EVV requirements under Minn. Stat. 256B.073. Public transit, volunteer drivers and not-for-hire vehicles are exempt. The same law requires Minnesota's managed care plans to have EVV data working with their claims systems by Jan. 1, 2027, so expect your plan or broker to ask about it soon.

Ohio: GPS verification is coming. A new section of Ohio law (ORC 5164.401, from Senate Bill 315, effective Oct. 6, 2026) directs Ohio Medicaid to set up GPS verification for NEMT. The system has to:

• Track when the provider arrives at pickup, starts the trip, arrives at drop-off and completes the trip
• Record timestamps, route data and total distance
• Send that data to the state as a condition of payment

Ohio has six months to set technical standards, twelve months to run a pilot and eighteen months to have every NEMT provider on the system. If you run trips in Ohio, the clock is already running. (New to the state? Start with our Ohio NEMT guide.)

Others are flagging NEMT. CMS letters and state reviews have labeled NEMT providers high-risk in Colorado, Minnesota and New York, per KFF.

If you contract with a broker, expect them to push these requirements down to you, whether or not your state passes its own law.

What a verified trip record looks like

Whatever the final rules say, they'll ask for the same core facts EVV already asks for in home care, and Ohio's law spells most of them out:

1. Who drove: the driver's identity, tied to the trip
2. Who rode: the member, matched to the authorized trip
3. Where: GPS location at pickup and drop-off
4. When: timestamps at each step
5. Proof of service: a signature or equivalent confirmation
6. Miles: distance per leg, ideally split into loaded and unloaded miles

The operators who'll feel this most are the ones still running on paper manifests and phone calls. Rebuilding proof after the fact is slow, and in an audit, "we did the trip" without records reads the same as "we didn't."

How to get ready now

• Make every trip produce its own record. Pickup and drop-off should be captured on the driver's phone when they happen, not typed in at the end of the shift.
• Tie drivers to trips. Shared logins and "whoever's free" assignments are the first thing an auditor pulls on.
• Keep the miles honest. Logged mileage that doesn't match the route is a red flag. Track it per leg and spot-check it.
• Ask your broker, in writing, what trip data they'll need and in what format.
• Store records where you can find them, and keep them secure. If a state or broker asks for six months of trips, you should be able to pull them in minutes. (Our guide to HIPAA-compliant recordkeeping covers the storage side.)

Where Bambi fits

Bambi already records the facts these rules ask for, as part of running the trip:

• Where and when: the driver app logs GPS coordinates and a timestamp each time the driver updates the trip status, including pickup and drop-off. You can download a GPS audit log for any trip.
• Who drove: every trip is assigned to a driver, and that assignment is part of the trip record.
• Proof of service: you can require passenger signatures at pickup, drop-off or both, and set that rule by payer or by organization. Signature logs download with the signatures included.
• Miles: Bambi tracks loaded and unloaded miles, from driver odometer readings or calculated automatically.
• Exports: trip data, GPS logs, signatures, times and mileage export to CSV for broker billing and provider audits.

Whatever the final rules require, the habit that matters is the same: let the trip create its own record, then check it before you bill.

Want to see what your trip records would look like? Talk to our team.

The bigger picture

More than 3.8 million working-age adults on Medicaid missed appointments, work or daily needs in 2024 because of unreliable transportation, per KFF. Fraud rules matter, but so does keeping honest providers in business. Good trip records do both: they prove the ride happened, and that it was worth paying for.

Sources

1. KFF, Medicaid's Transportation Benefit and the People Who Use It (Nov. 2, 2026).
2. Ohio Revised Code, Section 5164.401 (effective Oct. 6, 2026).
3. H.R. 10618, Strengthening Tools for Oversight to Prevent Medicaid Fraud Act of 2026 (119th Congress), bill summary and status.
4. Minnesota Session Laws 2026, Chapter 121 (SF 4476), Article 10: Electronic Visit Verification (signed May 27, 2026).
5. Minnesota Statutes, Section 256B.073, Electronic Visit Verification.