Service levels and vehicles
What Does Ambulatory Mean in NEMT? Riders, Vehicles, and Billing Codes
Ambulatory transportation means rides for people who can walk to and from the vehicle and sit in a regular seat, with little or no help. It is the basic level of NEMT service, usually run in sedans and minivans. No billing code is named for it: Arizona bills A0120 plus S0215 mileage (October 1, 2026 rates), and Indiana bills T2003 plus A0425 (2026 rates).
- An ambulatory rider walks from the door to the vehicle and rides in a regular seat. A rider who cannot walk that far, even with help, needs a wheelchair or stretcher trip.
- Ambulatory trips run in sedans, minivans, and sometimes taxis or rideshare cars, and they pay the least of any NEMT level.
- Each state picks its own codes: A0120 and S0215 in Arizona, T2003 and A0425 in Indiana, and A0120 and A0390 in Medi-Cal's non-medical program.
- Bill the level the rider needed, not the vehicle you sent: a walking rider in a wheelchair van is still an ambulatory trip in Indiana.
- Medicare pays none of these codes, so the rules come from your state Medicaid program, its health plans, and its brokers.
What ambulatory means in NEMT
Ambulatory means able to walk. In NEMT, an ambulatory rider walks to the vehicle, gets in, and rides in a regular seat, with little or no help from the driver. It is the most basic level of service and the least costly one.
Programs describe it much the same way:
- Virginia. MTM Health’s handbook (approved August 10, 2026) sends sedans, passenger vehicles, and minivans for members who are ambulatory and need no special assistance: people who can get in and out of the vehicle on their own and do not use mobility devices.
- Georgia. The NEMT manual (version July 1, 2026), in its dialysis transport rules, describes ambulatory curb-to-curb service for a member who can walk to and from the vehicle without assistance.
- Indiana. The transportation module (version 6.1, August 19, 2025) calls it commercial or common ambulatory service, or CAS, for ambulatory (walking) members.
Other programs name it after the vehicle. Illinois bills a service car trip, for a customer who needs neither an ambulance nor a medicar (the state’s wheelchair van). New York bills taxi trips and, in New York City, livery trips, both curb-to-curb services. California treats rides by car or taxi as non-medical transportation (NMT) rather than NEMT. See NEMT vs NMT.
Who qualifies for an ambulatory ride
The dividing line is how far the rider can walk and how much help they need.
| The rider | Level of service |
|---|---|
| Walks to the vehicle and gets in without help | Ambulatory, curb to curb |
| Walks, but needs a hand between the building door and the vehicle | Ambulatory, door to door |
| Walks, but must be handed to a caregiver or facility staff, as some riders with dementia must | Ambulatory, hand to hand |
| Cannot walk from the door to the vehicle, even with help | Wheelchair or stretcher |
| Cannot sit up for the length of the trip | Stretcher |
The three levels of help come from MTM Health’s Virginia handbook, which makes curb to curb the default. Curb-to-curb help includes opening doors, helping the rider in and out, and folding and storing a wheelchair or other mobility device. It never includes lifting the rider, and the driver stays at or near the vehicle. See curb to curb, door to door, and level of service.
The last two rows follow Georgia’s manual, which says members who cannot walk from their door to the vehicle, even with assistance, must travel by wheelchair or stretcher. Georgia also lets its broker assign a higher level to a rider who uses a walker, cane, crutches, or brace and cannot use a minibus, taxi, or public transit.
Ambulatory riders are the ones most often sent to cheaper options first. CMS requires states to use the least costly mode that suits the rider’s physical and emotional condition (SMD 23-006, September 28, 2023). Georgia’s broker may require public transit for ambulatory members who understand common signs and know the system, but never for a pregnant member or one traveling with more than two children under age 6. See least costly mode.
Vehicles used for ambulatory rides
| Program | What it allows or bars |
|---|---|
| MTM Health, Virginia (August 10, 2026) | Sedans, passenger vehicles, and minivans. Approved rideshare companies and volunteer drivers only when they meet every Medicaid and MTM credentialing, screening, insurance, and training rule. |
| Louisiana (Medicaid manual section issued July 14, 2025) | No two-door vehicles, pickup trucks, or salvage-title vehicles. The company must own or lease each vehicle, registered in its name. |
| Indiana (module version 6.1) | Ambulatory trips may run in any type of vehicle, but are billed by the level of service given |
| Georgia (July 1, 2026) | Rideshare cars only for ambulatory members who need no physical help, and only in listed cases such as a backup when the assigned provider does not show |
| New York (policy manual effective August 25, 2023) | Ambulette companies may use sedans and minivans for livery trips. The state transportation department does not inspect those cars. |
Every vehicle still needs working seat belts, heat and air, signage, and the broker’s inspection. The NEMT vehicle requirements guide covers the common list. If you plan to start with your own car, read can I use my personal vehicle for NEMT first.
How ambulatory trips are billed
No HCPCS code is named “ambulatory.” Each program picks from the general transportation codes: one base code for the trip and one mileage code for the miles with the rider on board. The October 2026 CMS HCPCS file gives each of them coverage code I, which means Medicare does not pay them.
| Program | Base code and rate | Mileage code and rate | Effective |
|---|---|---|---|
| Arizona AHCCCS fee-for-service | A0120: $6.64 in the Phoenix and Tucson areas, $7.27 elsewhere with TN | S0215: $1.28, or $1.63 with TN | October 1, 2026 |
| Indiana fee-for-service | T2003: $12.71. Each added rider on the same trip bills T2004 at $6.36, with no mileage. | A0425 with U3: $1.67 per mile, paid only past the first 10 miles of a trip over 10 miles one way | January 1, 2026 |
| Illinois | A0120 service car: $20.00 | A0425: $1.03 in Cook, DuPage, Kane, Lake, McHenry, and Will counties, $1.61 in Madison and St. Clair, $0.80 in the rest of the state | January 1, 2026 |
| South Dakota | A0100 taxi, or A0120 in the city: $5.20. A0120 outside the city with TN: $7.80. | S0215: $1.04, only on trips outside the city of 21 miles or more one way | July 1, 2026 |
| Medi-Cal non-medical transportation | A0120: $17.65, or $23.78 at night with UJ | A0390: $1.30 | Rate page updated August 2020 |
Arizona’s April 2011 rate sheet named A0120 the “ambulatory van, base rate” and S0215 the ambulatory van and taxicab mileage code. Medi-Cal limits A0120 to eight units a month unless the claim documents that the rides were needed for covered care, and it requires a written or verbal attestation from the rider that they have an unmet transportation need and have used up the other options available to them. Illinois requires prior approval for all non-emergency transportation.
A worked example
A 10-mile ambulatory trip in the Phoenix area, at October 1, 2026 rates:
| Line | Code | Units | Amount |
|---|---|---|---|
| 1 | A0120 | 1 | $6.64 |
| 2 | S0215 | 10 | 10 × $1.28 = $12.80 |
| Total | $19.44 |
The same trip for a wheelchair rider, billed A0130 and S0209, pays $11.15 plus 10 × $1.54, or $26.55. In Indiana the same 10-mile trip pays the base rate only, because Indiana deducts the first 10 miles of each one-way trip: $12.71 on T2003 for an ambulatory rider, against $31.79 on A0130 for a wheelchair rider. On longer trips, bill every mile on A0425 with U3 or U5, and Indiana pays the miles past the tenth. See T2003, S0215, A0100, and A0130, and the full list in NEMT billing codes.
Bill the level the rider needed
The rider’s level of service sets the code, not the vehicle you happened to send.
- Indiana. The module says ambulatory members carried in a vehicle equipped for nonambulatory members are billed at the ambulatory level and rate. An ambulance that carries an ambulatory member with no medical need bills the ambulatory charges too.
- Virginia. MTM Health’s handbook bars changing the assigned mode without approval. Using an unapproved mode, swapping vehicles, or giving a different level of help than authorized can mean non-payment or corrective action.
- WellTrans, Indiana. Its agreement (revised October 16, 2025) asks providers to report a rider booked at the wrong level, such as an ambulatory rider booked on a wheelchair trip. It charges $200 each time a provider sends a vehicle of a lower class of service than the one requested.
If a rider booked as ambulatory cannot walk to your car, do not force it. Call the broker and have the level changed before the trip. The rider is safer and the claim is correct.
Starting with ambulatory rides
An ambulatory-only company needs no ramp, lift, or wheelchair securement, so it can start with a sedan or minivan. The trade-off is the lowest rate per trip of any level, as the tables above show, so profit depends on volume and on keeping empty miles short. The ambulatory transportation business guide covers the startup steps, and starting NEMT with one van covers the first-vehicle numbers. When you are ready to add wheelchair riders, see what is a WAV.
Frequently asked questions
What is the difference between ambulatory and non-ambulatory?
An ambulatory rider walks to the vehicle and rides in a seat. A non-ambulatory rider cannot, and rides in a wheelchair or lying down on a stretcher. Georgia's NEMT manual (July 1, 2026) says members who cannot walk from their door to the vehicle, even with help, must go by wheelchair or stretcher. Indiana names the two levels commercial ambulatory service (CAS) and nonambulatory service (NAS).
Can an ambulatory rider use a cane or walker?
It depends on the program. Georgia's NEMT manual (July 1, 2026) lists a walker, cane, crutches, or brace as a reason for a higher level only when the rider also cannot use a minibus, taxi, or public transit. MTM Health's Virginia handbook (approved August 10, 2026) sends sedans and minivans only for riders who get in and out on their own and use no mobility device. Check the level on each trip before you send a car.
Can I send a wheelchair van for an ambulatory rider?
Often, if the broker allows it, and you bill it as ambulatory. MTM Health's Virginia handbook (approved August 10, 2026) needs approval before you swap the assigned vehicle. Indiana's transportation module says ambulatory members carried in a vehicle equipped for nonambulatory members are billed at the ambulatory level and rate, not by vehicle type. The reverse is the costly mistake: WellTrans's Indiana agreement (October 16, 2025) charges $200 each time a provider sends a vehicle of a lower class of service than the one requested.
Does Medicare pay for ambulatory transportation?
No. In the October 2026 CMS HCPCS file, the codes used for ambulatory trips, including A0100, A0120, T2003, and S0215, all carry coverage code I, not payable by Medicare. Ambulatory rides are paid by state Medicaid programs and the health plans and brokers that work for them, or privately by the rider or a facility.
What does ambulatory mean outside of transportation?
In health care, ambulatory usually describes care that needs no hospital stay, such as a clinic visit or ambulatory surgery. In NEMT it describes the rider: someone who can walk. A rider leaving an ambulatory surgery center may still need a wheelchair van home, so book each trip by how the rider moves that day, not by where they are going.