# What Are Deadhead Miles in NEMT? Why Empty Miles Go Unpaid and What They Cost

Canonical URL: https://nemtguide.com/glossary/deadhead-miles/ · Updated 2026-09-28

Deadhead miles in NEMT are the miles a vehicle drives with no rider on board: from the garage to the first pickup, from each drop-off to the next pickup, and back after a no-show. Medicaid generally does not pay for them. CMS lets states build their cost into trip rates instead, so you recover deadhead through the base rate and by keeping it low.

- A deadhead mile is any mile driven with no rider on board, including the drive back after a no-show.
- CMS guidance says empty miles generally cannot be paid, so the base rate for each trip has to cover them.
- Deadhead miles are the odometer miles for the day minus the loaded miles on your trip records.
- Each empty mile costs the vehicle cost per mile plus driver time, and hourly drivers are paid for that time.
- Cut deadhead by grouping trips by area, chaining each drop-off to a nearby pickup, and pricing far pickups before you accept them.

## What deadhead miles are

Deadhead miles are the miles your vehicle drives with no rider on board. CMS calls them "no load miles" or "unloaded miles" in its Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023). The opposite is [loaded miles](https://nemtguide.com/glossary/loaded-miles/). New York's Medicaid transportation manual defines loaded miles as "those miles during which an enrollee occupies the vehicle."

A normal day has deadhead in several places:

- **Garage to the first pickup.** The drive out in the morning.
- **Drop-off to the next pickup.** Every gap between one [trip leg](https://nemtguide.com/glossary/trip-leg/) and the next.
- **After a no-show.** CMS counts the driver's return trip after a rider fails to appear as unloaded miles. See [no-show](https://nemtguide.com/glossary/no-show/).
- **Back to base during an appointment.** The drive away from the clinic, and the drive back for the ride home.
- **Errands without the rider.** Arizona's fee-for-service manual (revised July 31, 2026) says picking up a prescription for a member is unloaded mileage and cannot be billed.
- **The drive home.** From the last drop-off to where the van parks at night.

## Why deadhead miles are unpaid in most programs

CMS sets the rule in SMD 23-006. Generally, no load miles "cannot be paid as a direct service or administrative activity." CMS also says empty miles are a significant cost, and that ignoring them would make providers less willing to carry Medicaid riders. So it lets states build the cost of no load miles and rider no-shows into their payment rates.

So a trip usually pays a base rate plus loaded miles, and the base rate has to carry the empty driving. The rules in five programs show the pattern:

| Program | How empty miles are treated |
|---|---|
| CMS guidance (September 28, 2023) | Generally not payable. States may build the cost into their rates. |
| New York Medicaid (manual effective August 25, 2023) | Pays loaded miles only. Since August 1, 2019, miles are reported to the tenth of a mile, and claims rounded up may be treated as fraud. |
| Arizona AHCCCS fee-for-service (revised July 31, 2026) | A provider "may not submit any claim for unloaded mileage," including a prescription pickup. |
| Louisiana Medicaid (fee schedule effective October 1, 2025) | A base rate per trip leg plus mileage from mile zero of the ride. A wheelchair van leg is $21.50 plus $1.30 a mile. |
| Indiana Medicaid (module version 6.1, published August 19, 2025) | Pays loaded mileage on commercial ambulatory and non-ambulatory trips only when the trip is more than 10 miles one way, and deducts the first 10 miles of each one-way trip. |

Indiana's rule leaves some loaded miles unpaid too. There, the base rate has to cover even more of the day's driving.

Since September 28, 2023, a state may pay unloaded miles separately in limited cases. The most appropriate and economical provider must face extraordinary costs to reach the rider, costs the usual rate does not cover. The state must first submit a state plan amendment to CMS that covers these payments. Ask your state Medicaid agency whether it has one before you count on it.

If you drive for a broker, the rate sheet in your agreement sets how miles are paid. Some states set a floor. Louisiana's Medicaid manual (Chapter 10, issued July 14, 2025) says brokers pay at least the published fee-for-service rate on the date of service, unless you and the broker agree otherwise in the provider agreement. See [how to bill NEMT brokers](https://nemtguide.com/guides/how-to-bill-nemt-brokers/).

## How to measure deadhead miles

You need two numbers for each vehicle each day: total miles driven and loaded miles.

1. **Read the odometer at the start and end of each shift.** Write both on the daily vehicle log, or use GPS miles if your tracking covers the whole day. The difference is total miles driven.
2. **Add up the loaded miles.** Take them from each trip record, pickup to drop-off. Arizona's Daily Trip Report already asks for odometer readings, and a trip with several stops needs them for each segment.
3. **Subtract.** Deadhead miles = total miles driven minus loaded miles.
4. **Work out the share.** Deadhead share = deadhead miles ÷ total miles driven.
5. **Track it by van and by weekday.** A rising share points to a route, a zone, or a standing order that no longer fits.

Here is one example day for a wheelchair van. The numbers are made up to show the math.

| Measure | Example day |
|---|---|
| Odometer at the start of the shift | 40,112 |
| Odometer at the end of the shift | 40,216 |
| Total miles driven | 104 |
| Loaded miles from 6 trip records | 54 |
| Deadhead miles | 50 |
| Deadhead share | 48 percent |

The free [trip log template](https://nemtguide.com/templates/nemt-trip-log-template/) records the odometer at the start and end of the shift and at each pickup and drop-off, so both numbers come from the same records.

## What an empty mile costs

Every deadhead mile costs you fuel, wear, and driver time, with no pay behind it.

**Cost per empty mile = vehicle cost per mile + (driver cost per hour ÷ average empty speed)**

- **Vehicle cost per mile.** A month of fuel, tires, maintenance, and repairs, divided by the miles driven that month. As a point of comparison, the IRS business standard mileage rate is 72.5 cents a mile from January 1 to June 30, 2026 and 76 cents from July 1 to December 31, 2026. The IRS bases it on an annual study of the fixed and variable costs of operating an automobile. Your own van's number is the one to use.
- **Driver time.** For employees, federal wage rules count travel from job site to job site during the workday as hours worked (29 CFR 785.38). An hourly driver is paid for the time spent driving empty.

Continuing the example with round numbers: a vehicle cost of $0.60 a mile, a driver cost of $20 an hour, and 25 miles an hour when driving empty.

| Cost of the 50 empty miles | Math | Cost |
|---|---|---|
| Vehicle | 50 × $0.60 | $30.00 |
| Driver time | 50 ÷ 25 mph = 2 hours, × $20 | $40.00 |
| **Per day** | | **$70.00** |
| Per month, 22 working days | $70 × 22 | $1,540 |
| Per year | $1,540 × 12 | $18,480 |

For scale, at the rates on Louisiana's fee schedule effective October 1, 2025, the same six wheelchair van legs pay 6 × $21.50 plus 54 loaded miles × $1.30. That is $199.20 for the day, and the empty miles take $70 of it before any other cost. Put in your own numbers with the [deadhead miles cost calculator](https://nemtguide.com/tools/nemt-deadhead-cost-calculator/).

## How to cut deadhead miles

- **Group trips by area and time.** Take trips that start near where your vans already are. See NEMT route planning.
- **Chain each drop-off to the next pickup.** Check where each leg ends before you place the next one.
- **Fit your service area to your vans.** A far pickup costs empty miles both ways. See service area.
- **Decide wait or return for each long appointment.** Waiting saves two empty drives but ties up the van. Arizona pays wait time only when the distance makes returning to base impractical and the odometer does not move. See wait and return.
- **Plan will-call returns before the day starts.** A van far from the clinic when the rider calls drives empty, and it may arrive late. See [will-call trips](https://nemtguide.com/glossary/will-call-trip/).
- **Confirm rides the day before.** A cancellation the night before saves the empty drive a no-show costs. MTM Health's Wisconsin page tells providers to confirm pickup times with members the day before the trip.
- **Price private-pay pickups to cover the drive out.** See [how much to charge for NEMT](https://nemtguide.com/guides/how-much-to-charge-for-nemt/).
- **Know your cost before you accept a far trip.** A long empty drive to a short ride can lose money every time it runs. For long rural runs, see [rural NEMT](https://nemtguide.com/guides/rural-nemt/).

## Frequently asked questions

### Does Medicaid pay for deadhead miles?

Generally no. The CMS Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023) says miles with no rider on board generally cannot be paid, but states may build their cost into trip rates. A state may also pay unloaded miles in limited cases, when the provider faces extraordinary costs, but it must first submit a state plan amendment to CMS. Arizona's fee-for-service manual bars any claim for unloaded mileage.

### Is the drive back after a no-show a deadhead mile?

Yes. CMS names the driver's return trip after a rider fails to appear as unloaded miles. Federal Medicaid funds do not pay for a ride to a rider who does not show up, so the drive out and the drive back both count as deadhead in your records. CMS lets states build the cost of no-shows into their rates.

### How do I work out my deadhead percentage?

Divide deadhead miles by total miles driven. Take total miles from the odometer at the start and end of the shift, and loaded miles from your trip records. For example, 50 empty miles out of 104 driven is a deadhead share of 48 percent. Track it for each van every day to see which routes and zones cost you the most.

### Do I have to pay drivers for deadhead time?

If your drivers are hourly employees, yes. Federal wage rules count travel from job site to job site during the workday as hours worked (29 CFR 785.38). Driving empty from a drop-off to the next pickup is part of the day's work, even though Medicaid does not pay for those miles. Check your state's wage rules as well.

### Can I charge private-pay riders for deadhead miles?

Yes, for riders and payers outside Medicaid, if your price says so before the ride. One clear pickup fee that covers the drive out is easier for a rider to understand than a separate empty-mile charge. Medicaid members are different: a Medicaid provider accepts the Medicaid payment as payment in full under 42 CFR 447.15.

## Official resources

- [CMS: Medicaid Transportation Coverage Guide (SMD 23-006)](https://www.medicaid.gov/federal-policy-guidance/downloads/smd23006.pdf)
- [IRS: Standard mileage rates by year](https://www.irs.gov/tax-professionals/standard-mileage-rates)
- [AHCCCS: Transportation billing manual (Chapter 14)](https://www.azahcccs.gov/PlansProviders/Downloads/FFSProviderManual/FFS_Chap14Transportation.pdf)
- [eCFR: 29 CFR 785.38, travel time that counts as hours worked](https://www.ecfr.gov/current/title-29/section-785.38)