HCPCS vs CPT: Why NEMT Billing Codes Are HCPCS Level II, Not CPT

What HCPCS and CPT mean

HCPCS, the Healthcare Common Procedure Coding System, is the national system of billing codes that Medicare, Medicaid, and private insurers use to process claims. CMS describes it as two main levels.

• Level I is CPT, Current Procedural Terminology. The American Medical Association keeps it. The AMA says CPT codes describe medical services and procedures performed by physicians and other qualified health care professionals.
• Level II is the national alpha-numeric set. CMS keeps it, including decisions to add, revise, or delete codes. CMS says it covers products, supplies, and services that CPT does not include, such as ambulance services and medical equipment used outside a doctor’s office.

CMS’s coding procedures (November 30, 2018) explain the split: the HHS Secretary has delegated authority under HIPAA to the AMA to keep Level I and to CMS to keep Level II.

The two levels side by side

Question	HCPCS Level I (CPT)	HCPCS Level II
Who keeps it	The AMA, through its CPT Editorial Panel	CMS
What a code looks like	Five characters. Category I codes are numbers from 00100 to 99499.	One letter and four digits, such as A0130
What it covers	Services by doctors and other clinicians	Ambulance and transportation, equipment, supplies, and other services outside CPT
How it changes	The AMA updates it every year, and its panel meets three times a year	CMS posts a new file every quarter
Its modifiers	Numbers, such as 59 and 76	Letters, or a letter and a number, such as TK, U3, and XE

The AMA facts are from its code set overview, updated January 23, 2026, and CMS’s HCPCS page, which says the AMA republishes CPT every year. The same coding procedures describe Level II modifiers as either alpha-numeric or two letters.

Why every NEMT code is HCPCS Level II

CMS names ambulance services as one of the things Level II exists for, because CPT does not include them. The HIPAA code set rule covers transportation too. 45 CFR 162.1002 adopts the combination of HCPCS, kept by HHS, and CPT, kept by the AMA, as the standard code set for physician and other health care services, and lists “transportation services including ambulance” among them. Diagnoses use a third set, ICD-10-CM, which goes in box 21 of the CMS-1500.

The first letter of a NEMT code tells you which part of Level II it comes from:

• A codes. In the October 2026 HCPCS file, the A0 codes from A0021 to A0999 all cover ambulance or non-emergency transportation. The non-emergency codes run from A0080 to A0210, such as A0130 for a wheelchair van, and the ambulance codes include A0425 for ground mileage.
• T codes. CMS’s 2015 coding procedures say T codes are for use primarily by Medicaid state agencies, to meet a national Medicaid need no permanent code covers. Private insurers may use them too. The NEMT T codes are T2001 to T2005, T2007, and T2049, such as T2003, one trip.
• S codes. The HCPCS file’s processing note 0088 says S codes are temporary codes created by the Blue Cross and Blue Shield Association and the Health Insurance Association of America for private payers, and not valid for Medicare. The 2015 procedures add that Medicaid programs may also use them. S0209 and S0215 are the NEMT S codes.

A code in the file is not a promise of payment. CMS’s Level II page (last modified June 2, 2026) says HCPCS identifies items and services and is not a system for coverage or payment decisions. In the October 2026 file, every non-emergency transportation code carries coverage code I, not payable by Medicare. Your state Medicaid program, health plan, or broker decides which codes it pays and what one unit means. See NEMT billing codes for the full list.

States no longer use their own local codes. CMS’s 2018 procedures explain that Medicaid agencies, Medicare contractors, and private insurers once used local Level III codes. The HIPAA rule of August 17, 2000 provided for ending them, and section 532(a) of the Medicare, Medicaid, and SCHIP Benefits Improvement and Protection Act of 2000 kept them in use through December 31, 2003. Today a state gives a national code its local meaning with modifiers, such as the U modifiers each state defines.

CPT modifiers on NEMT claims

A NEMT line is all Level II except, sometimes, the modifier. A few states borrow CPT modifiers to mark a second trip on the same day:

• South Dakota, 59. Its community transportation manual (updated August 2026) lists 59 for multiple trips on the same day. Its modifier list (effective July 1, 2026) pays 59 at 100 percent of the fee.
• Medi-Cal, 76. Its ground transportation manual (page updated June 2023) lets you add 76 to each code for later trips on the same day, with the time of day and the destinations in box 19, so they are not denied as duplicates.
• Indiana, XE instead of 76. Bulletin BT2025119 (August 19, 2025) says 76 is not appropriate for transportation claims, because it marks a repeat procedure by the same physician or other health care professional. Indiana wants the Level II modifier XE, separate encounter, on each extra trip, and not on legs where the driver waited.

CMS’s Medicaid NCCI manual (revision date January 1, 2026) quotes the CPT codebook’s definition of 59, distinct procedural service, and names 76 as a repeat procedure or service by the same physician or other qualified health care professional. It says XE took effect January 1, 2015, and may be used in place of 59 whenever possible. Use only the modifiers your own state manual lists. See the TK modifier and origin and destination modifiers for the Level II modifiers most trips carry.

Where HCPCS codes go on the claim

Box 24D of the CMS-1500 takes either kind of code. The NUCC instructions (version 13.0, July 2025) say to enter the CPT or HCPCS code and modifiers from the code set in effect on the date of service, with up to four two-character modifiers and no written description. Units go in box 24G, and you may use a decimal for a fraction of a unit. The same fields on the electronic claim are covered in 837P, and the full form in CMS-1500 for NEMT.

Example: two round trips in one day in South Dakota

A rider goes from home to a clinic and back in the morning, then from home to a second provider and back in the afternoon, all inside city limits. South Dakota’s manual bills it on one claim:

Line	Box 24D	Box 24G	Paid at July 1, 2026 rates
1	A0120	2	2 x $5.20 = $10.40
2	A0120 59	2	2 x $5.20 = $10.40
Total			$20.80

A0120, mini-bus or other transportation system, is a HCPCS Level II code. Modifier 59 is the only CPT piece on the claim. A form that asks for “the CPT codes you bill” for this work wants A0120 and its modifiers.