NEMT Broker Audits in 2027: What Brokers Check and How to Pass

A broker audit is not a state Medicaid audit, but it can still cost you money and trips. The broker pays your claims, holds your contract, and decides how many trips you get. When its auditors find a gap, the money usually comes out of your next payment.

Why brokers audit their providers

Federal rules require brokers to police their networks. A state may run NEMT through a broker only if the broker has procedures to make sure transportation is timely and that transport staff are licensed, qualified, competent, and courteous. The broker is also subject to regular auditing by the state (42 CFR 440.170(a)(4)). Section 1902(a)(87) of the Social Security Act also requires every state to make sure that NEMT providers and drivers are not excluded from federal health programs, that each driver has a valid license, and that each provider has a process for drug law violations and for disclosing each driver’s driving history (CMS SMD 23-006).

Federal auditors test brokers too. In an audit released in January 2021 (A-01-19-00004), the HHS Office of Inspector General reviewed 100 paid NEMT claim lines from two Massachusetts brokers:

What the OIG found	Sample items
No qualifying medical service on the date of the ride	48 of 100
Not enough documentation to show the ride happened	62 of 100, including 38 where the broker could not produce the driver’s trip sheet
Ride billed but not given	2 of 100
Driver qualifications and vehicle records not adequately documented	All 100

Missing elements included pickup and drop-off addresses, the date, the rider’s name, the driver’s name, and the vehicle. The OIG told the state to work with its brokers to verify documentation, consider GPS to confirm trips happened, confirm riders were in the vehicle, and trace every driver and vehicle to its records. On May 28, 2026, the OIG announced new audits of whether selected states complied with Medicaid payment rules for NEMT, with completion estimated in fiscal year 2028. Expect brokers to check the same things with you.

Your broker agreement is what makes the audit possible. MTM Health’s standard agreement (January 1, 2023 version) requires you to allow access to your premises, inspections, audits, monitoring, and copying of records at no charge, during normal business hours, and says they may be unannounced. MTM does not return records you send, so keep copies. WellTrans’s Indiana agreement (revised October 16, 2025) lets its client or a representative ride on trips and inspect your vehicles at any time.

The kinds of broker audits

Type	What happens	Published examples
Credential review	You keep company, driver, and vehicle documents current in the broker’s system, and it checks each date	MTM Virginia tracks license, background check, drug screen, driving record review, and training dates for every driver
Vehicle inspection	An inspector checks each vehicle before it carries riders, then on a schedule	MTM Virginia: before first use and every six months. Louisiana: before first use and every year, with digital photos. Kentucky: the Transportation Cabinet inspects vehicles.
Unannounced field check	A monitor stops a van, watches pickups, or rides along	Louisiana allows unannounced reviews of manifests, signature pages, licenses, registration, insurance cards, and safety equipment, and providers cannot refuse. Modivcare’s provider page (September 2026) says it does field visits to confirm vehicles meet contract standards.
Trip and claim sample	The broker traces a sample of paid trips to your records	Washington’s sample broker contract: at least 10 randomly selected trips in each provider’s desk audit, checked for documentation, timeliness, coding, and medical justification
Attendance check	The broker asks the clinic whether the rider came	WellTrans compares facility attendance records with invoices and pays only when the rider attended a covered service
Data review	Data checks flag unusual patterns	Modivcare’s program integrity page (September 2026) lists duplicate or overlapping trips, improbable mileage, unusual trip frequency, and level-of-service mismatches
Office visit	Staff visit your office	Washington’s sample contract: a site visit every other year to check that client files and manifests are kept secure

Washington’s sample contract, with an amendment term of July 1, 2023 to June 30, 2025, shows how a state can write these rules. The broker inspects 10% of each provider’s vehicles on site every other year, half planned and half unannounced, and runs desk audits in the other years. If more than 5% of the inspected vehicles fail, it inspects the whole fleet. Multiple complaints about one provider within 60 days also start a desk audit. Driver checks follow the same pattern and include face-to-face contact and a check of billings against qualified drivers.

What auditors check

Driver files

MTM’s standard agreement lists what each driver and attendant file must hold, owner-drivers included:

Item	How often (MTM standard agreement)
Driver’s license	Current at all times
Criminal background check	Before hire and every year
Motor vehicle record covering the past three years	Every year
Drug and alcohol tests	Before hire, after an accident, on reasonable suspicion, and at random
Training certificates	As required
Exclusion checks against the OIG list and federal debarment lists	No excluded person may drive

Brokers add their own training. MTM Virginia requires PASS, HIPAA, defensive driving, and, where needed, first aid and wheelchair securement before a driver carries riders, plus yearly fraud, waste, and abuse training. Modivcare (September 2026) asks owners and drivers to review compliance training within 30 days of its request each year and to sign a compliance attestation. Louisiana has the broker search the OIG list, the federal System for Award Management, and the state’s adverse actions list every month, and report any match to the state within three business days. The driver file checklist covers each item, and the OIG exclusion list page explains the monthly check.

Vehicle files and equipment

Inspectors check the paperwork and the van itself. MTM Virginia requires these on board: registration, insurance card, incident and accident procedures, a stocked first aid kit, GPS or current maps, a fire extinguisher within reach, a spill kit, a seat belt cutter within the driver’s reach, and at least two belt extensions. Its broker phone numbers and complaint procedures must be posted inside. A vehicle out of compliance may be removed from service until it is fixed.

Louisiana’s broker photographs each inspection: every side of the vehicle, the state inspection sticker and VIN, the plate and registration, the seat belt cutter and the fire extinguisher’s pressure gauge, a thermometer reading at the air vents, the seat belts, and, on wheelchair vans, a secured wheelchair. The vehicle inspection checklist and vehicle requirements guide help you prepare.

Trip records and signatures

Every paid trip needs a record that proves it. Louisiana’s manual has the broker collect a daily trip log from each provider with the trip ID, the rider’s name, Medicaid ID, address, and signature, the destination, the facility name, departure and arrival dates and times, the driver’s name, and the VIN. Before it pays, the broker must match each claim to a trip log entry. MTM Virginia denies any claim missing the trip ID, the scheduled and actual pickup times, the departure and arrival times, or the rider’s signature.

WellTrans’s agreement is strict on signatures. A driver or attendant may never sign for the rider. When the rider cannot sign, a household member, caregiver, or facility staff member signs their own name and writes their relationship. Initials, blank lines, and notes that the rider could not sign are rejected. Corrections are a single line through the original, dated and initialed by the driver. See NEMT trip documentation and the trip log template.

GPS, video, and data checks

Tracking data is now part of the record. MTM Virginia requires vehicle location tracking to stay on for the whole ride, grades providers on tracking more than 90.01% of trips, and flags two patterns as possible fraud, waste, or abuse:

• Miles versus minutes. Trips where the miles billed do not fit the recorded trip time. The standard is under 0.99% of trips.
• Overlapping claims. One driver on two vehicles, or two drivers on one vehicle, at the same time. The standard is under 0.99%.

Kentucky’s HB 2 (April 2026) requires a GPS device in every vehicle on Medicaid trips, paid for by the regional broker. In Colorado, a law in effect July 1, 2026 requires providers with more than five vehicles to use two-way video dash cameras. The video may be used for audits, and the state may request recordings for a program integrity review without advance notice, limited to the issue under review.

Policies and reporting

Auditors also ask for your written policies. MTM’s agreement requires a substance-free workplace policy with pre-employment and random testing, provided on request. WellTrans requires a way for staff to report possible fraud, including anonymously. MTM Virginia assigns 3 points for failing to report an incident or accident. See NEMT policies and procedures.

What happens after a broker audit

Results range from a note in your file to losing the contract.

Result	What the documents say
No pay for unapproved drivers or vans	MTM will not pay for trips by uncredentialed drivers or in uncredentialed vehicles. Colorado law says trips by noncompliant or noncredentialed drivers or vehicles are not eligible for reimbursement.
Money taken back	MTM and WellTrans can recover overpayments by subtracting them from future payments. In Louisiana, the state may recoup every payment for trips run while a provider’s insurance was below the minimum.
Payments held	WellTrans may hold money owed to you while it audits for suspected fraud, waste, or abuse. When the agreement is ending, MTM holds unpaid claims until it audits your records.
Corrective action plan	MTM and WellTrans both require you to help build and follow a corrective action plan. Colorado allows trip caps only as part of such a plan, after written notice and a chance to fix the problem.
Points and suspension	MTM Virginia: points last one year. 3 points suspend your marketplace access, 5 bring a 5-day suspension, 8 a 10-day suspension and loss of recurring trips, and 10 removal from the network.
Referral	Modivcare lists education, corrective action plans, claim denial or recovery, payment suspension, network action, and referral to regulators, Medicaid Fraud Control Units, or Offices of Inspector General.

MTM Virginia’s point values show what brokers treat as serious. A driver seen without the MTM-issued name tag, or an in-person inspection result of “in process,” is 1 point. Each expired driver or vehicle credential used on a trip is 2 points. Using a driver, attendant, or vehicle that was never credentialed, failing to report an incident, or leaving a rider at the wrong place is 3 points. See NEMT broker penalties and Medicaid recoupment.

How to respond to a broker audit request

1. Read the request the day it arrives. Note what it asks for, which dates of service, and the deadline. WellTrans can ask for copies on three days’ notice.
2. Confirm receipt in writing. Reply by email with the date you will send the records.
3. Pull exactly what is asked. Send the trip logs, signatures, GPS reports, and driver and vehicle files for those dates. Keep a copy of everything, since MTM does not return records.
4. Never change a record. Do not rewrite, backdate, or create a record after the fact. If a record is missing, say so.
5. Protect rider information. Send records through the broker’s portal or another secure method. See HIPAA for NEMT.
6. Answer attendance questions in writing. When a clinic says a rider missed an appointment, send your proof: the signed log, GPS trail, and any note from the facility. At WellTrans, silence for 30 days means the trip is treated as not having happened.
7. Respond to the findings. Dispute a finding with evidence, or accept it and send a corrective action plan with dates.
8. Appeal denied claims on time. MTM Virginia gives 365 days from a denial to appeal in its claims portal. See how to appeal a denied NEMT claim.

If your own review turns up a claim you sent in error, report it. MTM Virginia tells providers to contact their field monitor right away so the claim can be voided. See the 60-day overpayment rule.

A monthly self-check to pass your next broker audit

Run this in the first week of each month. It is the same test an auditor will run.

1. Match your roster to the broker’s. Every driver and van you use must be approved in the broker’s system. Remove anyone who is not from the schedule today.
2. Check every expiration date. Licenses, background checks, driving records, drug tests, training, registrations, inspections, and insurance. Renew anything due within 60 days. The credentialing checklist lists them.
3. Run exclusion checks. Search every owner, manager, driver, and attendant on the OIG list, SAM.gov, and your state’s list, and save the results with the date.
4. Walk around each van. Check the onboard items your broker requires, the posted phone numbers, and the wheelchair securements.
5. Pull 10 random trips. For each one, check the trip log fields, the signature, the times, the GPS trail, the level of service on the manifest, and the claim. Washington’s sample contract uses the same number.
6. Look for overlaps. Make sure no driver appears on two vans at once and no van has two drivers at once.
7. Compare miles with time. Flag any trip where the miles billed do not fit the minutes between pickup and drop-off.
8. Review complaints and incidents. Every one should be logged, reported to the broker, and closed.
9. Test your retrieval. Pick one trip from a year ago and time how long it takes to produce its full record. MTM and WellTrans both require 10 years of records.

Broker audits and state Medicaid audits

A broker audit checks you against the broker’s contract. The state, federal contractors, and fraud units can audit you under Medicaid rules as well. Under federal rules, a provider with a Medicaid provider agreement must keep the records needed to show the extent of the services it gives, and hand them to the state agency, the HHS Secretary, or the state Medicaid fraud control unit on request (42 CFR 431.107). CMS also hires audit contractors to review Medicaid provider claims.

Some states now audit providers directly. Colorado’s law, in effect July 1, 2026, has the state audit transportation providers, as money allows, to make sure it pays only for trips by credentialed drivers in credentialed vehicles. It may review claims, policies, credentials, trip records, and grievances, and it may use data and member complaints to choose whom to audit. See how to prepare for a Medicaid audit, Medicaid site visits, and NEMT fraud for the state side.