Why NEMT providers should check Medicaid eligibility before every trip from 2027

What changes for Medicaid members in 2027, and why does it reach the van?

From January 1, 2027, states must condition Medicaid expansion coverage on a community engagement requirement of at least 80 hours a month, and they must check it at renewal at least every six months^1,2. More frequent eligibility decisions mean more riders whose coverage ends, or pauses, between the day a trip was authorized and the day your driver arrives.

The 2025 federal budget reconciliation law set the deadline. KFF summarizes it: states must condition expansion eligibility and coverage on meeting work requirements by January 1, 2027, with an option to start sooner, and enrollees need at least 80 hours a month of work or qualifying activities¹. Every six months at redetermination, or more often if the state chooses, the state looks back at one or more months to confirm compliance or an exemption¹.

CMS’s interim final rule, CMS-2454-IFC, fills in the mechanics. States must implement by January 1, 2027, or earlier at state option². Compliance is assessed at each renewal, states may verify more often between renewals, and most people subject to the requirement also fall under the new six-month renewal cycle². Work, community service, a work program, half-time education or income of at least the federal minimum wage times 80 hours all count, which the deck works out as $580 a month².

The Congressional Budget Office expects the policy to bite: KFF reports its estimate that 18.5 million people will be subject to the requirements each year and that federal Medicaid coverage will fall by 5.2 million adults by 2034¹. Some of those adults are your riders, and their coverage is now a monthly question rather than a yearly one.

Does a broker authorization guarantee the member is eligible on the day of the trip?

No, a broker authorization does not guarantee eligibility on the day of the trip: it means the broker approved the trip, and payment still depends on the member being enrolled on the date of service. New York’s statewide transportation manager puts it bluntly: Medicaid only pays for Medicaid transportation when the enrollee is transported and receives Medicaid services³. The same FAQ tells providers to check an enrollee’s eligibility on the date of transportation, before the trip³.

That’s New York’s rule, and every state and broker contract reads a little differently. But the structure is the same everywhere. Federal regulation requires each state plan to say the Medicaid agency will ensure necessary transportation for beneficiaries to and from providers⁴, and CMS’s NEMT booklet defines an eligible beneficiary as someone determined eligible and currently receiving Medicaid⁵. The authorization is the broker doing its part; the eligibility check is you confirming the word “currently”.

So read your broker agreement for whether it warrants eligibility at authorization and what it says about ineligible members. The NEMT billing guide covers how broker contracts allocate that risk.

How do you run an eligibility check for a standing order?

Check the whole roster at the start of the month, then re-check anyone whose renewal date falls inside it. A standing order, dialysis three times a week for example, is authorized once and runs for weeks; the authorization doesn’t change when the member’s coverage does.

The mechanics are the same as for any Medicaid claim: a 270 inquiry goes out and a 271 response comes back showing whether the member is active, with which plan, and for which dates. The eligibility verification entry explains the fields. For NEMT the extra step is batching: export the active standing-order riders on the first business day of the month and check them all at once.

Record each rider’s renewal date where the state portal shows it. From 2027 those dates arrive twice a year for expansion adults², and the sweep should re-check every rider whose date has just passed.

What does the eligibility response tell a dispatcher?

Three things: whether the rider is active today, which plan or program covers them, and when the coverage period ends. A dispatcher doesn’t need the whole 271, just one line per rider: active with plan X through date Y, or inactive as of date Z.

The plan name matters more than it used to. A rider who moved to a different MCO at renewal has a trip authorized under the old plan’s broker; when the 271 plan differs from the trip record, the dispatcher holds the trip and the office calls the broker. The end date is the second flag: a segment that ends inside the month with nothing following it means a call before the next trip, not after.

What do you do with a completed trip for a member who was not eligible?

Don’t bill Medicaid for it, and don’t quietly bill the rider either. CMS’s booklet says claims must reflect the actual services furnished and that providers should bill only for services rendered⁵. A trip for someone who wasn’t enrolled on the date of service isn’t a Medicaid service, so there’s nothing to attest in the broker portal.

What you can do depends on the state. Some states grant retroactive eligibility when a late renewal is processed, which can make the date billable weeks later; your state’s rules say whether that happens and how long you then have to bill. Where the person wasn’t enrolled, the state’s private-pay rules apply. Ask before you invoice anyone.

Keep the trip record regardless. The booklet’s first tip is to document completely and keep the records, and its second is to verify services were furnished as documented, including by calling the facility to confirm the rider arrived⁵. If retroactive eligibility lands, the record becomes a billable trip; if it doesn’t, it’s your evidence of good faith. The trip attestation entry covers what the record should hold.

How do you build the check into intake and the day-before confirmation call?

Build the eligibility check into intake and the day-before confirmation call by making it a field on the trip record, not a task someone has to remember. At intake, whoever accepts a trip from the broker records the 271 status and coverage end date next to the authorization number. On the day-before confirmation call, the same person re-runs anyone whose end date falls before the next monthly sweep or whose renewal date has passed. Failed trips go to a hold list the owner or office lead clears before the next morning’s manifest.

That’s two checks per trip at most. Eligibility verification as a service is this routine run by a dedicated biller every day, with the hold list reported back to dispatch; the NEMT billing overview shows where it sits in the trip-to-payment cycle. In-house or handed off, nobody rolls on a date the file shows as inactive.

What to do this week

1. Pull your standing-order riders into one list and run a batch eligibility check on all of them.
2. Add two fields to your trip intake form: 271 status and coverage end or renewal date.
3. Read your broker agreement for what it says about trips completed for ineligible members, and note the clause.
4. Ask your state Medicaid agency whether it grants retroactive eligibility after a late renewal and how long you have to bill.
5. Put an eligibility sweep on the calendar for the first business day of every month, starting now rather than January 2027.