NEMT GPS Tracking in 2027: What Brokers Require and What the Data Proves

GPS tracking turns each ride into a record of where the vehicle went and when. Brokers and states use that record to decide whether to pay a trip, and you can use it to win a no-show dispute or a mileage cut. It also collects data about your drivers and riders, so it comes with notice and privacy rules.

What GPS tracking records on a NEMT trip

A GPS system logs the vehicle’s position over and over as it moves, each point with a time stamp. Joined together, those points are the trail, which New York calls “breadcrumb data.” On top of the trail, the driver or the system marks the trip events.

Event	What it shows
En route	When the driver started toward the pickup
Arrived at pickup	When the vehicle reached the pickup address, and how long it waited
Picked up	When the rider boarded, and where the loaded miles start
Arrived and dropped off	When and where the ride ended
Signature	That the rider or an allowed signer confirmed the ride, where the broker collects it in the app

MTM Health’s standard agreement, in the January 1, 2023 version Pennsylvania posts, sets the minimum: an internet-connected device that sends the vehicle’s location, the trip events, and member signatures in real time (section 4.B). New York’s broker MAS tells providers to record every event as it happens, by hand or with a geofence, a boundary around an address that marks arrival automatically.

Colorado’s HB26-1328, in effect since July 1, 2026, lists the full set. State rules must require digital dispatch that records pickup and drop-off addresses, GPS coordinates, pickup and drop-off times, routes and miles driven, and the driver and vehicle for each trip (C.R.S. 25.5-1-802(10)(k)). That list is a good target in any state. For the app side, see what a NEMT driver app should do.

Which states and brokers require GPS

No federal rule makes every NEMT provider use GPS. States write it into laws, manuals, and broker contracts, and brokers add their own rules on top.

State rules

State	What it requires	In effect
New York	Every transportation provider sends the start point, end point, and all GPS coordinates along each trip to the broker. Every vehicle must have GPS that transmits coordinates. Only the Department of Health can grant an exemption.	Since April 3, 2023
Massachusetts	Every vehicle you use under a human service transportation broker subcontract, which covers MassHealth rides, must have GPS that shares its location with the broker and the state in real or near real time and reports actual arrival times at pickup and drop-off	Provider performance standards effective July 1, 2022
Idaho	The state’s NEMT contract with MTM Health requires GPS tracking for every provider. Riders can follow their ride live.	Contract live since September 1, 2023, per the state’s December 1, 2024 report
Kentucky	A GPS device in every vehicle used for Medicaid NEMT, so the regional broker can see its exact location during trips. The broker pays for it, not the state. It does not apply to rides a Medicaid health plan covers.	HB 2, law since April 14, 2026
Colorado	State rules must require digital dispatch that records GPS coordinates for every trip, and that data may be given to the state or the broker only in digital form. MediDrive, the state’s broker, asks that GPS work on every trip.	HB26-1328, July 1, 2026
Arkansas	A working video camera in every vehicle, with GPS on the camera, HD 720p video, an interior view of every passenger, and 45 days of playback. A vehicle whose camera is down carries no Medicaid riders.	The state’s broker solicitation 710-25-049, Revision 2 (June 2025), section 2.21 M

Minnesota is next. Laws 2026, chapter 121, signed May 27, 2026, makes enrolled NEMT providers follow the state’s electronic visit verification law, Minnesota Statutes 256B.073, starting January 1, 2027, or on federal approval if later. See EVV for NEMT for what that will mean for trip records.

Broker rules

Broker	What it requires	In effect
MAS, New York’s statewide broker	GPS data must be on every trip invoice before you can attest to it. Routing records that do not show the vehicle’s real location and time are treated as possible fraud and reported to the state and the Office of the Medicaid Inspector General.	Manual version 2023-1, October 1, 2023
MTM Health, standard agreement	GPS on an internet-connected device in every vehicle, using MTM’s own app or software MTM approves. If you use your own software and MTM does not get all the data, MTM can suspend trips, end the agreement, or charge liquidated damages.	January 1, 2023 version
MTM Health, Virginia	Tracking active for the full ride, capturing arrival, pickup, the drive, and drop-off. GPS compliance standard above 90.01% of trips.	Handbook approved August 10, 2026
MTM Health, Rhode Island	GPS compliance is graded green above 90.01% of trips, yellow from 75% to 90%, and red below 75%	Handbook updated July 1, 2026
WellTrans	May use vehicle location data, when available, to review mileage, service, or performance issues	Agreement revised October 16, 2025
Modivcare, Mississippi	Each vehicle needs a working GPS system or a current map of the area. Modivcare may use vehicle location data, when available, to review mileage, service, or performance issues.	Provider manual, February 2024

Brokers without a tracking rule can still use location data to check your trips, as the WellTrans and Modivcare rows show. New York’s rule followed federal audits. In its September 2022 audit of New York City NEMT payments for 2018 and 2019 (A-02-21-01001), the HHS Office of Inspector General found 41 of 100 sampled payments unallowable and estimated at least $84.3 million in improper federal claims. The state answered that trip start and end times and locations would become trackable through GPS data.

If your broker is not on this list, read the vehicle, technology, and performance sections of its manual and contract. Look for the words GPS, AVL (automated vehicle location), or tracking. See the MTM Health, MAS, MART, WellTrans, Modivcare, and MediDrive broker pages, the New York, Massachusetts, Idaho, Arkansas, and Colorado state guides, and the Kentucky HB 2 report.

What GPS data proves in an audit or dispute

GPS evidence is time-stamped and made by a machine at the moment of the ride. That is what auditors want. New York accepts an electronic driver confirmation only if it records the pickup and drop-off coordinates with a system-generated time stamp that cannot be changed, kept for six years.

Dispute	What the GPS record shows	What else to keep with it
The rider says you never came	Arrival at the pickup address and how long the vehicle stayed	Your call or text attempts before leaving, and the no-show you reported to the broker
A late pickup complaint	Arrival time against the scheduled time. MTM Virginia counts 15 minutes before to 15 minutes after as on time.	Your calls telling the member or facility, and the broker, about the delay. MTM Virginia requires both.
The broker cuts your miles	The route and the loaded miles driven	Odometer readings where your state requires them
An auditor says the trip never happened	The trail from pickup to drop-off	The rider’s signature and the trip approval
Two trips at the same time	Which vehicle and which driver ran each trip	Your driver and vehicle rosters for that day

Brokers run these checks on their own. MTM Health’s Virginia handbook grades providers on two of them, each held under 0.99% of trips:

• Miles versus minutes. On trips of 50 miles or less, a trip is flagged when the trip miles exceed the recorded minutes plus 7. On longer trips, it is flagged when the speed implied by the pickup and drop-off times tops 85 miles an hour.
• Overlapping claims. One driver in two vehicles, or two drivers in one vehicle, at the same time.

Miles need the most care. New York has required loaded miles billed to the tenth of a mile for dates of service since August 1, 2019. Rounding up can be treated as fraud. WellTrans pays the shortest distance from pickup to drop-off as its mapping software measures it, rounded to the nearest whole mile, and running the trip counts as accepting that mileage. Raise a mileage error before you run the trip. WellTrans may review it with other mapping software or with vehicle location data. If you disagree with its decision, you may reroute the trip, which means handing it back. See NEMT mileage billing and loaded miles.

For no-shows, the GPS arrival and departure times are the core of your proof. The no-show policy template has a place for them, and NEMT broker penalties covers how to contest a fine.

What GPS cannot prove

A trail shows that a vehicle drove from one address to another. It does not show who was inside, or why.

Federal auditors spelled out the gap. In its January 2021 Massachusetts audit (A-01-19-00004), the HHS Office of Inspector General suggested GPS as a control to confirm riders reached their destination. It also suggested separate ways to confirm the rider was in the vehicle, such as a signed log. The state agreed GPS would help but noted it would only show that transportation happened. It would not show there was a valid medical appointment that day.

In the same audit, 48 of 100 sampled rides had no qualifying medical service. A clean GPS trail would not have saved those claims. Keep these with every trip, whatever your GPS shows:

• The broker’s trip number or approval
• The rider’s signature, or your state’s approved fallback
• Any practitioner form the level of service needs
• A note when a facility cancels, so the ride is not billed

NEMT trip documentation lists every field a trip record needs, and NEMT broker audits shows how auditors test them.

Driver app, your own software, or a tracker in the van

There are three ways to meet a broker’s GPS rule. Many providers combine them.

Option	How it works	What to check first
The broker’s free driver app	The driver runs the broker’s app on a phone. MTM’s free driver app meets its rule, and MAS points providers to a free app that meets New York’s minimum.	You need one app per broker, and the trail is only as good as the phone’s battery and signal
Your own dispatch software	Your software sends trips, events, and GPS to each broker through an API	MTM must review your software first and can refuse the connection. In New York, the software company registers with MAS, signs a business associate agreement with it, and gets a data key. A billing company must also enroll in New York Medicaid as a service bureau.
A tracker wired into the vehicle	The device reports the vehicle’s location whenever it runs, even if the phone dies	A tracker alone does not record trip events or signatures, which MTM’s agreement also requires

Under MTM’s agreement, if you use your own software, you are the one responsible for getting all the GPS data to MTM. The same is true in New York: the transportation company is always responsible for the accuracy of what it, or its software or billing company, sends to MAS. A vehicle tracker is part of fleet telematics, which can also report speed, idling, and maintenance alerts.

Who pays for it

Meeting a GPS rule does not have to cost you software fees. MTM’s Virginia handbook (approved August 10, 2026) says its driver app is free and meets the tracking rule, and that MTM connects with more than 20 outside dispatch programs. Idaho’s December 2024 report to its Legislature says the same of MTM’s free app there. MAS offers New York providers a free app that meets the minimum. Kentucky’s HB 2 puts the cost of each vehicle’s GPS device on the regional broker, not on the state. The devices that run the apps are usually yours. MTM’s standard agreement makes you keep working hardware, software, and internet service (section 2.D), so budget for a phone, a data plan, a mount, and a charger in every vehicle, plus any dispatch software you choose.

Dead zones happen, especially on rural routes. MAS says GPS data can be sent during or after the trip when something outside your control blocked it, such as a dead zone or a dead battery, but it expects that to be rare. CMS’s Medicaid Transportation Coverage Guide (September 28, 2023) also notes that drivers can use GPS coordinates to find and measure trips to homes with no street address. See rural NEMT and how to choose NEMT software.

Driver privacy: what the law allows

Tracking a van your company owns, during work, is what the broker and state rules above expect. The limits come from notice laws and from vehicles or phones your company does not own.

State	Rule	Penalty
New Jersey	An employer that knowingly uses a tracking device in a vehicle an employee uses must give the employee written notice (N.J.S.A. 34:6B-22, effective April 2022). A tracking device here is one built or meant only to track a vehicle, person, or device. Devices used to document expense reimbursement are excluded.	Up to $1,000 for a first violation and $2,500 for each later one
Connecticut	An employer that collects information about employees’ activities by electronic means on its premises must give prior written notice of the types of monitoring. A posted notice counts (section 31-48d).	Up to $500, $1,000, then $3,000 per offense
New York	An employer that monitors employees’ phone calls, email, or internet use must give written notice at hiring, get it acknowledged, and post it (Civil Rights Law section 52-c). This matters when your driver app or company phones also monitor those.	Up to $500, $1,000, then $3,000 per offense
California	Using an electronic tracking device to find a person’s location is a misdemeanor unless the vehicle’s registered owner, lessor, or lessee consents (Penal Code 637.7)	Misdemeanor

Other states have their own rules, so ask a local employment lawyer before you track drivers’ own vehicles or phones. These habits keep you on safe ground everywhere:

1. Give written notice to every driver. Say what you track, when, and why, and get a signature. Keep it in the driver file.
2. Track the trip, not the person. The broker and state rules above cover the ride itself. Kentucky’s law covers the time a vehicle is being operated for NEMT. Turn app tracking off at the end of the shift.
3. Get consent for personal vehicles and phones. This applies most to contractors who drive their own cars. See 1099 or W-2 drivers.
4. Limit who can see the data. Dispatch and billing need it. Few others do.

Riders’ privacy matters too. HIPAA counts street addresses and their equivalent geocodes as identifiers (45 CFR 164.514), and a trail from a home to a dialysis center shows where a person lives and gets care. If your company is a HIPAA covered entity, or a business associate of your broker, a tracking vendor that stores trip data for you needs a business associate agreement (45 CFR 164.502(e)). See HIPAA for NEMT providers.

Video raises separate rules. Since July 1, 2026, Colorado has required two-way video dash cameras in providers’ vehicles, except for fleets of five or fewer, and Arkansas’s 2025 broker solicitation requires an interior camera in every vehicle. See the Colorado camera law and dash cameras in NEMT.

Do NEMT vans need an ELD?

Usually not. Under 49 CFR 395.8, an electronic logging device (ELD) records hours for drivers who must keep a federal record of duty status. The federal rules reach NEMT only in commercial motor vehicles on interstate trips. Under 49 CFR 390.5, that means a vehicle rated at 10,001 pounds or more, or one designed or used to carry 9 or more people, including the driver, for pay. Your state may set its own hours rules for trips that stay inside the state.

Even then, short-haul drivers are exempt from the record of duty status. Under 49 CFR 395.1(e)(1), a passenger-carrying driver who stays within 150 air miles of the work reporting location and is released within 14 hours, with 8 hours off between shifts, keeps simple time records instead. The carrier keeps those records for 6 months. A carrier that does need an ELD must use one on FMCSA’s registered list (49 CFR 395.22), so an ordinary GPS tracker does not count. See rural NEMT for hours of service and USDOT numbers for NEMT.

How long to keep GPS records

Keep GPS data as long as the trip record it supports, because it is part of that record. The longest rule that applies to you wins.

Rule	How long
New York electronic trip records	6 years
MTM Health standard agreement, section 2.S	10 years, or longer if law or MTM’s client requires
Arkansas camera video, which carries GPS	At least 45 days of playback, all of it retrievable for audits

Check how long your broker app or tracking vendor keeps trails. Export them and store them with your trip logs, or get the vendor’s promise in writing to keep them for the full period. See NEMT record retention.

How to set up GPS tracking, step by step

1. Read your rules. Pull the GPS, AVL, and technology sections from your state manual and every broker contract. Note each compliance target, such as MTM Virginia’s 90.01%.
2. Choose how you will track. Use each broker’s free app, or get written approval before connecting your own software.
3. Put a working device in every vehicle. Mount the phone, keep a charger in the van, and have a backup phone ready for each shift.
4. Tell your drivers in writing. Explain what is tracked and when, and get each driver’s signature. Get written consent for any personal vehicle.
5. Train the taps. Drivers mark en route, arrived, picked up, and dropped off at the curb, never later.
6. Check compliance every day. Pull the list of trips with missing or broken trails and fix the cause before billing.
7. Match GPS to the claim. Miles, times, and addresses on the claim should agree with the trail. Hold any trip that does not.
8. Store it with the trip record. Keep the trail as long as your longest retention rule, under a business associate agreement with any vendor.
9. Use it when you are challenged. Send the trail, the event times, and your call log with every no-show dispute, mileage appeal, and audit response.