NEMT Mileage Billing in 2027: Loaded Miles, Rounding, and Map Checks

Mileage is often the bigger half of a NEMT claim. On an Arizona fee-for-service wheelchair round trip of 30 loaded miles, at the urban rates effective October 1, 2026, the two base rates pay $22.30 and the mileage pays $46.20, about two thirds of the claim. Miles are also easy to inflate and easy to measure, so payers check them closely.

Which miles you can bill

Medicaid pays for loaded miles, the miles with the rider on board. CMS’s Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023) says miles driven with no Medicaid member in the vehicle, including the trip back after a no-show, generally cannot be paid. States may build their cost into the rate instead. Since that guide, a state may also pay unloaded miles when the most economical provider would face extraordinary costs to pick up or drop off a member, but only through a state plan amendment filed with CMS.

States write the same rule in their own words:

Program	What counts as a billable mile
New York	Miles during which an enrollee occupies the vehicle
Arizona	Distance traveled, in statute miles, with a member on board and being transported to covered services
Ohio	Distance traveled to or from a Medicaid-coverable service with a Medicaid-eligible individual in the vehicle
South Dakota	Mileage driven while a patient is being transported

Empty miles are rarely paid. Arizona bars any claim for unloaded miles, including a trip to pick up a member’s prescription. Ohio does not cover transports with no Medicaid member in the vehicle. South Dakota is the exception for community transportation. It pays empty miles outside city limits on trips of 21 miles or more one way, when the driver is heading back to the starting point after a drop-off or going to a hospital or nursing facility to pick up a discharged rider. Every other empty mile is a cost you carry: see deadhead miles.

Mileage codes and how units work

Mileage goes on its own claim line, with a per-mile code. The code descriptions below come from the CMS HCPCS file for October 2026.

Code	Description	Where it is used
S0209	Wheelchair van, mileage, per mile	Arizona and South Dakota, among others
S0215	Non-emergency transportation; mileage, per mile	Arizona, and South Dakota community transportation. Indiana does not pay it.
T2049	Non-emergency transportation; stretcher van, mileage; per mile	Arizona stretcher van miles
A0425	Ground mileage, per statute mile	Indiana van miles with U3 (walk-on) or U5 (wheelchair)
A0380	BLS mileage (per mile)	Medi-Cal wheelchair van and litter van miles

One unit is one mile. How you put the miles on the claim still varies:

• Arizona wants every trip for one member on one date on a single claim: total trips on line 1, total loaded miles on line 2, and wait time, if billed, on line 3. Any extra lines deny. A base-only claim followed by a mileage-only claim is denied as split billing.
• Indiana puts both runs of a round trip on one line with 2 units, and all the miles for the round trip on one mileage line. It tells providers not to fragment mileage.
• Medi-Cal wants the total miles from pickup to destination, plus the return miles on a round trip, in box 24G. The full pickup and drop-off addresses, with city and ZIP code, go in box 19.
• New York wants the miles in Field 27 of its claim (loop 2400 SV104 in the 837P), and a charge equal to your charge per mile times the miles.

NUCC’s instructions for box 24G allow a decimal point for a fraction of a unit. Use one only where your payer accepts fractions, as the next sections show. For the full code list and five states’ rates, see NEMT billing codes.

How payers measure billable miles

Payers pay the miles you drove, as long as you drove a direct route. They differ on how you prove it.

Program	Route standard	How you document the miles
Indiana	The shortest, most efficient route	Odometer readings on the driver’s ticket, or mapping software that shows the shortest route
Minnesota	The most direct route	Odometer readings at pickup and drop-off, the mileage of the most direct route, and the method used to find that route. The driver signs for the actual miles driven.
Ohio	Only the distance actually traveled. Extra miles from unnecessarily indirect routes are not covered.	Documentation that justifies any trip longer than 50 miles from the pickup point
Arizona	Odometer miles. On shared rides, each member’s most direct route.	Daily Trip Report: pickup and drop-off odometer readings, with trip miles equal to drop-off minus pickup
New York	Loaded miles that match the trip’s prior authorization	GPS start point, end point, and all points along the trip, sent to the broker since April 3, 2023
Medi-Cal	Total miles from pickup to destination	Full origin and destination addresses on the claim

Two states also set a starting line for paid miles:

• Indiana pays walk-on and wheelchair van mileage only on trips longer than 10 miles one way. It deducts the first 10 miles of each one-way trip itself, so you bill every mile. If you bill mileage on a trip under 10 miles, the mileage line comes back denied.
• South Dakota pays community transportation mileage only outside city limits on trips of 21 miles or more one way, counting only the miles between two cities. For secure medical transportation (wheelchair and stretcher vans), it pays loaded miles only on trips that leave the city, counted from the point the trip leaves the city limits. It pays $2.61 per whole loaded mile on S0209 (fee schedule effective July 1, 2026).

Writing miles down at the curb matters more than any rule on this page. NEMT trip documentation lists what each state wants on the trip record, and NEMT GPS tracking covers location data.

Rounding rules for NEMT miles

Odometers and GPS records show tenths of a mile. Payers do not all accept them.

Payer	Rounding rule
New York Medicaid	Loaded miles to the tenth of a mile for dates of service on or after August 1, 2019. Under one mile, enter a 0 before the decimal point, such as 0.9. Rounding up to the next whole mile is not allowed. Providers whose software cannot report tenths may round down to the next lower whole mile until the state sets an end date.
Indiana Medicaid	Whole units only, rounded to the nearest whole mile. 15.0 to 15.4 miles is billed as 15, and 15.5 to 16.0 miles as 16.
South Dakota Medicaid	Whole numbers, no decimals, with standard rounding. The fee schedule prices S0209 per whole mile.

The same odometer readings, billed three ways:

Loaded miles recorded	New York	Indiana	South Dakota
12.4	12.4	12	12
15.5	15.5	16	16
27.8	27.8	28	28

This table shows rounding only. Indiana’s 10-mile deduction and South Dakota’s city-limit rules still decide how many of those miles are paid.

New York is blunt about rounding up. Its transportation manual says rounded-up claims may be deemed fraudulent and subject to recovery and penalties. The money adds up fast. Rounding 12.4 miles up to 13 bills 0.6 of a mile never driven. At Arizona’s $1.54 urban wheelchair van mileage rate, that is about $0.92 a leg, and $4,620 over 5,000 legs, an example volume for a few busy vans in a year. If you find a pattern like that in your own claims, fix it and return the overpayment. Federal law requires Medicaid overpayments to be reported and returned within 60 days after you identify them (42 U.S.C. 1320a-7k(d)). See the 60-day overpayment rule.

Set rounding per payer in your billing system, not once for the whole company. A brokered trip follows the broker’s billing rules, so read your broker contract and billing guide as well.

Shared rides: who gets the miles

When two or more members ride together, the shared miles are paid once in most programs. Where they are billed depends on the payer.

Program	How shared-ride miles are billed
New York	Only the actual miles from the first pickup to the last drop-off. The manual’s example: bill the base rate and 13 miles for the first rider picked up, and the base rate alone for the second rider, whose 7 miles overlap.
South Dakota	One mileage allowance per trip, whatever the number of passengers, billed on one recipient’s claim
Indiana	Full base rate, mileage, and wait time for the first member only. The second and later members from the same county to the same area get half the base rate and no mileage.
Ohio	The loaded miles must match the distance actually traveled, and the shared part is split in a reasonable, consistent way
Arizona	A separate Daily Trip Report for each member, with the odometer miles of that member’s own direct route from pickup to drop-off

Pick one method per payer and use it every time. A billing system that copies the full van miles onto every rider’s claim bills the same miles twice, and payers look for exactly that. See NEMT multiloading for how shared rides are scheduled and paid.

Distance limits and approvals

Some payers cap the miles they pay, or ask for approval above a set distance.

Program	Limit	What to do
Ohio (rule 5160-15-26)	Mileage payment on a wheelchair van or ambulance trip is limited to 50 miles from the pickup point	Keep documentation that justifies a longer trip. Trips to or from a state that is not Ohio or next to Ohio go to manual review.
Arizona fee-for-service	Prior authorization when one member’s NEMT miles top 100 in a day, one way, round trip, or several trips	Request it before the ride. Trips under 100 miles need none.
Minnesota	No more than 30 miles to a primary care provider or 60 miles to a specialty care provider	The member needs authorization to go farther. Approval moved from the local agency to the administrator the state contracts to run NEMT for fee-for-service on July 1, 2026, and moves for managed care on January 1, 2027.
Indiana	Van mileage paid only past the first 10 miles of each one-way trip	Bill every mile, and expect the first 10 to come off

A broker may set its own limits, so check your trip assignment before a long ride. For the economics of long trips, see rural NEMT.

The checks behind mileage cuts and denials

Payers and brokers test billed miles in the same few ways. Each one below comes from a state manual or broker handbook.

1. Against the authorization. New York pays only when the claim matches the prior authorization, and any change to the trip, such as a new location, needs approval before the ride.
2. Against the return leg. Arizona compares loaded miles going and coming back. Without a written reason on the Daily Trip Report, it may cut the difference.
3. Against the clock. MTM Health’s Virginia handbook (approved August 10, 2026) scores a fraud, waste, and abuse measure called Miles vs. Minutes. It compares each trip’s miles with its documented minutes, and for trips over 50 miles it tests whether the average speed tops 85 miles an hour. Flagged trips must stay under 0.99 percent.
4. Against the member’s home. Arizona may ask why a pickup or drop-off away from the member’s home produced more miles, and you must justify it.
5. Against the route. Indiana, Minnesota, and Ohio all measure miles against a direct route. A detour without a reason on the record reads as padding.
6. Against distance limits. Ohio’s 50 miles, Arizona’s 100-mile authorization line, and Minnesota’s 30 and 60 miles all trigger review or denial.
7. Against other riders. New York, South Dakota, and Indiana pay shared miles once, so the same miles on two claims stand out.
8. Against the rules for empty miles. Unloaded miles, such as a prescription pickup in Arizona, deny outright.

On a remittance, a mileage problem can show as reason code 16 with remark code M22, “Missing/incomplete/invalid number of miles traveled,” or as fewer units paid than you billed. See how to read remittance advice for a reduced mileage line worked through, and NEMT claim denials for the other reasons claims fail.

How to fix a mileage cut or denial

1. Read the codes. Note the reason code, the remark code, and the units billed and allowed.
2. Pull the trip record. Compare the billed miles with the odometer readings or GPS data for that leg, and with the authorized miles.
3. If your miles were right, add the missing reason, such as a road closure or a hospital entrance change, and send a corrected claim. In Arizona the reason goes in the additional information section of the Daily Trip Report. If the payer still refuses, appeal the denial inside its window. MTM Health’s Virginia handbook allows 365 calendar days.
4. If your miles were wrong, correct or void the claim, and return any overpayment.
5. Fix the cause. Check the rounding setting, the shared-ride setting, and the pickup address saved for the rider, so the same error does not repeat on the next claim.

How to set up mileage billing so it pays

• Save each payer’s rules in your billing setup: code, units format, rounding, shared-ride method, thresholds, and caps.
• Record miles at the curb: odometer readings or GPS data at pickup and drop-off for every leg. A NEMT mileage log works for vans without an app.
• Write down every detour with its reason, on the trip record, the day it happens.
• Bill one member’s day on one claim where the payer requires it.
• Read the mileage lines on every remittance, and track cuts by reason code. The same cut week after week points to a setup problem.

Arizona tells providers it will audit mileage after payment, and Minnesota lets the state recover payment for trips without the required records. A clean mileage record is what keeps a paid claim paid.