# What Are Loaded Miles in NEMT? How Payers Measure, Round, and Pay Them

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

Loaded miles are the miles a vehicle travels with the rider on board, from pickup to drop-off. They are the miles you bill as mileage units, such as S0209 for a wheelchair van. Medicaid generally pays only loaded miles, so empty driving to and from riders is not paid as mileage. Payers measure them by odometer or mapped direct route, and each sets its own rounding rule.

- A loaded mile is a mile driven with the rider in the vehicle. Every mile with no rider on board is a deadhead mile.
- Medicaid generally pays mileage only for loaded miles, and CMS lets states build the cost of empty miles into their rates.
- Payers count loaded miles from odometer readings or a mapped direct route, and some cut miles from indirect routes.
- Rounding differs: tenths of a mile in New York, whole miles in Indiana and South Dakota. New York treats rounding up as possible fraud.
- On a shared ride, New York and South Dakota pay the shared miles once. Arizona instead bills each rider's own direct-route miles.

Every NEMT mileage payment starts with one number: how far the rider traveled in your vehicle. That number is the loaded miles. Get it right on every trip record and your mileage lines pay. Get it wrong, even by rounding, and payers cut it or ask for the money back.

## What loaded miles are

Loaded miles are the miles your vehicle travels while the rider is on board. New York's Medicaid transportation manual defines them as "those miles during which an enrollee occupies the vehicle." Arizona's manual (revised July 31, 2026) measures them in statute miles, with the member on board and on the way to covered care. Medicare uses the same idea for ambulances: federal rule [42 CFR 414.605](https://www.ecfr.gov/current/title-42/section-414.605) defines loaded mileage as the miles the patient is transported.

Every other mile is unloaded. CMS calls those "no load miles," and many owners call them [deadhead miles](https://nemtguide.com/glossary/deadhead-miles/).

| Part of the day | Loaded or deadhead? |
|---|---|
| Garage to the first pickup | Deadhead |
| Rider's home to the clinic | Loaded |
| Clinic back to base while the rider is in the appointment | Deadhead |
| Clinic back to the rider's home | Loaded |
| Drive out to a rider who does not show, and back | Deadhead |
| Picking up a prescription without the rider | Deadhead. Arizona bars billing it. |
| Stretch with two riders on board | Loaded, but some payers pay it only once |
| Last drop-off to where the van parks at night | Deadhead |

## Why only loaded miles are billable

CMS set the rule in its Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023). Miles driven without a Medicaid member in the vehicle, including the return after a no-show, generally cannot be paid as a service. CMS also said those empty miles are a real cost, and ignoring them would make providers less willing to carry Medicaid riders. So it lets states build that cost into their payment rates.

State rules follow the same line:

- **Ohio.** Rule 5160-15-26 (effective July 1, 2021) pays nothing for a transport with no Medicaid member in the vehicle. Travel to the pickup and from the drop-off is part of the service, is not paid separately, and cannot be billed to the rider.
- **Arizona.** A NEMT provider may not submit any claim for unloaded mileage, including a trip to pick up a member's prescription.
- **Nebraska.** Its NET fee schedule (rev. July 1, 2026) says the base rate already pays for unloaded mileage, usual waiting time, and the first five loaded miles.
- **Medicare ambulances.** CMS's claims manual says mileage charges are for loaded miles only, and it presumes unloaded costs are built into the base and mileage rates.

A few programs pay empty miles in narrow cases. South Dakota's community transportation manual (updated August 2026) pays unloaded miles outside city limits on trips of 21 miles or more one way, when the driver returns to the starting point or goes to pick up a rider being discharged from a hospital or nursing facility. Since September 28, 2023, a state may also choose to pay unloaded miles when the best-suited provider faces extraordinary costs to reach a rider, such as on a long-distance trip. The state must first submit a state plan amendment to CMS.

## How payers count loaded miles

Each payer sets where the count starts, how you measure it, and how you round. These rules are from the manuals and fee schedules in effect in 2026.

| Payer | What counts | How to measure | Rounding |
|---|---|---|---|
| New York Medicaid (manual effective August 25, 2023) | Miles with the rider in the vehicle | Fractional units on the claim | Tenths of a mile since August 1, 2019. Rounding up to a whole mile may be treated as fraud. |
| Arizona fee-for-service (July 31, 2026) | Pickup to drop-off | Drop-off odometer minus pickup odometer, written on the Daily Trip Report | The odometer difference as recorded |
| Indiana Medicaid (August 19, 2025) | Ambulatory and wheelchair van mileage pays only past the first 10 miles of a trip longer than 10 miles one way, but you bill every mile | Odometer readings, or mapping software that shows the shortest route | Whole miles to the nearest mile: 15.5 bills as 16, 15.4 as 15 |
| South Dakota Medicaid (July 1, 2026) | Secure van (the state's wheelchair van) and stretcher van miles only from where the trip leaves city limits | Loaded miles outside city limits | Whole miles, no decimals |
| Medicare ground ambulance (manual issued November 14, 2025) | Pickup to arrival at the destination | Loaded statute miles | Round up to the next tenth under 100 miles, and to the next whole mile at 100 or more |

Two more checks catch miles that look too high. Ohio does not pay excess miles from unnecessarily indirect routes, and it pays mileage on a non-emergency wheelchair van trip for no more than 50 miles from the pickup unless you keep documents that justify the distance. Arizona compares the loaded miles to the clinic with the loaded miles home, and it may reduce the difference if you give no reason for it. For codes, units, and how cuts are appealed, see [NEMT mileage billing](https://nemtguide.com/guides/nemt-mileage-billing/).

## Loaded miles on a shared ride

When two riders share the vehicle, the same mile carries two people. Payers split it in different ways:

- **New York** bills the miles from the first pickup to the last drop-off on the first rider's claim, and only the base rate for the others. In the manual's example, a 13-mile rider and a 7-mile rider on the same route bill 13 miles in total.
- **South Dakota** pays one mileage allowance per trip, billed on one rider's claim.
- **Ohio** asks you to split the shared miles in a reasonable, consistent way, and says claimed miles must match the distance actually traveled.
- **Arizona** is the exception. Each member gets a separate Daily Trip Report, and each report shows the miles of the most direct route between that member's own pickup and drop-off.

## A loaded mile example

A wheelchair van picks up a rider at 40,112.0 on the odometer and drops her at dialysis at 40,124.6. That is 12.6 loaded miles, billed as units of a per-mile code such as [S0209](https://nemtguide.com/glossary/s0209/). The drive from the garage to her home does not count. Here is how three payers treat the same 12.6 miles.

| Payer | Mileage units you bill | Miles that pay |
|---|---|---|
| New York | 12.6 | 12.6 |
| Indiana, A0425 with the U5 modifier for a non-ambulatory van | 13 | 3, after the first 10 are deducted |
| South Dakota secure (wheelchair) van, trip entirely inside city limits | None | None |

The same trip can pay very different mileage, so the rate per mile alone does not tell you what a trip pays. See [NEMT reimbursement rates](https://nemtguide.com/guides/nemt-reimbursement-rates/) for the base and mileage rates in each state.

## How to record loaded miles

1. **Write the odometer at pickup and at drop-off.** Put both readings on the trip record for every leg. The free [NEMT trip log template](https://nemtguide.com/templates/nemt-trip-log-template/) has a column for each.
2. **Record each stop.** Arizona wants each segment of a multi-stop trip, with the address, times, and odometer readings.
3. **Check against the direct route.** Indiana accepts mapping software as proof, as long as it shows the shortest route.
4. **Write down any detour.** A note such as a closed road explains miles that a map check would flag.
5. **Round the way your payer says.** Set your billing to tenths or whole miles for each payer, never up by habit.
6. **Track your loaded share.** Divide loaded miles by total odometer miles for each van each day. A falling share means more of your driving is unpaid. The [deadhead miles cost calculator](https://nemtguide.com/tools/nemt-deadhead-cost-calculator/) puts a dollar figure on it.

If a broker sends your trips, its agreement sets how miles are counted and paid, so read its rate exhibit next to your state's rules. The mileage codes themselves are listed in [NEMT billing codes](https://nemtguide.com/guides/nemt-billing-codes/).

## Frequently asked questions

### What is the difference between loaded and unloaded miles?

Loaded miles are driven with a rider in the vehicle. Unloaded miles, also called deadhead or no load miles, are driven empty: to the first pickup, between trips, and back after a no-show. CMS guidance of September 28, 2023 says no load miles generally cannot be paid, but states may build their cost into trip rates.

### Do loaded miles start at my garage?

No. Loaded miles start when the rider gets in and end at the drop-off. Ohio rule 5160-15-26 says travel to the pickup and from the drop-off is part of the service, is not paid separately, and cannot be billed to the rider. Arizona's manual measures trip miles as the drop-off odometer reading minus the pickup reading.

### Do I bill loaded miles in tenths or in whole miles?

Follow your payer. New York has required tenths of a mile since August 1, 2019, and says claims rounded up to a whole mile may be treated as fraud. Indiana and South Dakota want whole miles, rounded to the nearest mile. Medicare ground ambulance claims round up to the next tenth on trips under 100 miles.

### Who gets the loaded miles when two riders share the vehicle?

It depends on the payer. New York bills the miles from the first pickup to the last drop-off on the first rider's claim and only the base rate for the others. South Dakota pays one mileage allowance per trip. Ohio asks you to split the shared miles in a reasonable, consistent way. Arizona bills each rider's own direct-route miles on separate trip reports.

### Can I bill the extra miles from a detour?

Only when the detour was needed and you can show why. Ohio does not pay excessive mileage from unnecessarily indirect routes, and Indiana expects the shortest, most efficient route. Arizona reduces mileage when the trip to the clinic and the trip home differ and you give no reason. Write the reason for any detour, such as a road closure, on the trip record.

## Official resources

- [CMS: Medicaid Transportation Coverage Guide (SMD 23-006)](https://www.medicaid.gov/federal-policy-guidance/downloads/smd23006.pdf)
- [eMedNY: New York Medicaid Transportation Policy Manual](https://www.emedny.org/ProviderManuals/Transportation/PDFS/Transportation_Manual_Policy_Section.pdf)
- [AHCCCS: Transportation billing manual (Chapter 14) and Daily Trip Report](https://www.azahcccs.gov/PlansProviders/Downloads/FFSProviderManual/FFS_Chap14Transportation.pdf)
- [Indiana Health Coverage Programs: Transportation Services module](https://www.in.gov/medicaid/providers/files/modules/transportation-services.pdf)
- [Ohio Administrative Code 5160-15-26](https://codes.ohio.gov/ohio-administrative-code/rule-5160-15-26)