Operations
NEMT Route Planning in 2027: How to Cut Empty Miles on Every Run

NEMT route planning is deciding where each van starts, which trips it runs, and in what order, so every drop-off leads to a nearby pickup. Medicaid generally pays only for miles with a rider on board, so empty miles are pure cost. Group trips into zones around busy clinics, chain each leg to the next, plan returns before the day starts, and park vans near their first pickups.
- Medicaid generally pays only for loaded miles, so every empty mile between trips is fuel, wear, and driver time with nothing to bill.
- Build zones around the clinics and dialysis centers your riders use, and give each van a home zone.
- Chain legs so each drop-off sits near the next pickup, and work a facility: drop one rider off and pick up another at the same door.
- A van kept overnight near its first pickups saves empty miles twice a day, but check the wage, tax, and broker rules first.
- States pay shared rides differently. New York pays the miles once, while Arizona fee-for-service pays each rider's direct-route miles.
Two vans can run the same eight trips and earn the same pay, and one of them can drive far more miles to do it. The difference is the route: where the van starts, which trips it takes, and the order it runs them in.
NEMT scheduling sets the times on each trip. Route planning decides where the vans go between those times. This guide covers the method for a small fleet, with the empty-mile math behind each step.
Why empty miles decide what a route earns
Medicaid pays for the miles a rider is on board. CMS says miles driven with no Medicaid member in the vehicle generally cannot be paid as a direct service, though states may build their cost into trip rates (SMD 23-006, September 28, 2023). New York pays loaded miles only, meaning miles during which an enrollee occupies the vehicle. Arizona’s fee-for-service manual (revised July 31, 2026) says a provider may not submit any claim for unloaded mileage.
So every mile to a pickup, between legs, and back to the lot at night is cost with nothing to bill. Those are your deadhead miles. The paid ones are loaded miles. Two numbers tell you how a route is doing:
Empty-mile share = empty miles ÷ total miles driven
Pay per mile driven = total pay for the day ÷ total miles driven
Fuel makes each empty mile cost more when prices rise. U.S. regular gasoline averaged $4.478 a gallon in the week of September 21, 2026, $1.305 more than a year earlier, and diesel averaged $6.529 (EIA, released September 22, 2026).
For comparison, the IRS business standard mileage rate is 72.5 cents a mile from January 1 to June 30, 2026 and 76 cents from July 1 to December 31, 2026. The IRS bases it on a yearly study of the fixed and variable costs of running a car. One more empty mile costs less than that, because the payment and insurance on the van do not change with it. Use your own running cost per mile.
The empty-mile math for one van
Here is one wheelchair van running eight one-way legs in a day, priced at Arizona’s urban fee-for-service rates effective October 1, 2026, for trips that start in the Phoenix or Tucson metro areas: $11.15 per trip (A0130) and $1.54 per loaded mile (S0209). The mileage, fuel economy, wear cost, driver pay, and speed are example numbers. Put in your own.
- Plan A: trips taken wherever they are offered. The van parks at a central lot 12 miles from where its riders live, and averages 6 empty miles between legs.
- Plan B: one zone, legs chained. The same eight trips, with the van kept overnight 2 miles from the first pickup and 2 empty miles between legs.
| One day, eight legs of 6 loaded miles each | Plan A: scattered | Plan B: zoned and chained |
|---|---|---|
| Loaded miles | 48 | 48 |
| Empty miles: morning, between legs, evening | 12 + 42 + 12 = 66 | 2 + 14 + 2 = 18 |
| Total miles driven | 114 | 66 |
| Empty-mile share | 58% | 27% |
| Pay: 8 × $11.15 + 48 × $1.54 | $163.12 | $163.12 |
| Pay per mile driven | $1.43 | $2.47 |
| Cost of the empty miles at $1.25 a mile | $82.50 | $22.50 |
| Pay left after the empty miles | $80.62 | $140.62 |
| Time spent driving empty at 25 mph | 2 hours 38 minutes | 43 minutes |
The $1.25 cost per empty mile comes from one formula:
Cost per empty mile = fuel per mile + wear per mile + (driver cost per hour ÷ empty driving speed)
- Fuel: $4.48 a gallon ÷ an example 15 miles per gallon = $0.30.
- Wear: an example $0.15 a mile for tires, brakes, oil, and repairs.
- Driver time: an example $20 an hour ÷ 25 miles an hour = $0.80. For hourly employees, travel from job site to job site during the workday counts as hours worked (29 CFR 785.38), so empty driving is paid time.
Plan B keeps $60 a day more. Over 22 working days that is $1,320 a month, or $15,840 a year, for one van. It also frees 1 hour and 55 minutes of driving. At an example 45 minutes per extra leg, that is room for two more trips, worth 2 × ($11.15 + 6 × $1.54) = $40.78 at the same rates.
Your numbers will differ, and broker rates are set by your contract. The shape does not: pay stays the same while the empty miles decide what is left. Try your own with the deadhead miles cost calculator.
Step 1: Map where your trips really start and end
Plan from last month’s records, not from memory.
- List every completed leg with its pickup ZIP code, destination, day of the week, and pickup time.
- Rank destinations by trip count. The dialysis centers, hospitals, and clinics at the top of the list become the anchors for your zones. Write down each one’s opening and closing hours.
- Mark standing orders. Recurring trips repeat, so they anchor the routes. See NEMT standing orders.
- Mark each van’s overnight spot and each driver’s home. They set where the day begins.
- Note the empty miles you drove for each van from the odometer at the start and end of each shift, minus the loaded miles on your trip records.
Step 2: Draw zones around your busiest destinations
A zone is an area one van can cover without long empty drives. Draw zones around destinations, not around town lines, because a dialysis center pulls riders from every direction at the same hours.
- Anchor each zone on one or two big destinations. Then group the riders who go there by where they live.
- Size each zone to your pickup window. MTM Health’s Virginia handbook (approved August 10, 2026) counts a pickup as on time from 15 minutes before to 15 minutes after the scheduled time, and its Rhode Island handbook (July 1, 2026) says a deviation of more than 15 minutes is not timely. A van must reach any pickup in its zone inside that window from its last drop-off.
- Give each van a home zone. The same van and driver in the same area learn the doors, the gate codes, and the regular riders. MTM Health’s Virginia handbook asks providers to make a best-faith effort to use the same driver for recurring trips.
- Decide who covers the border. Trips between zones go to whichever van ends nearest the pickup, checked each afternoon.
- Match your broker service area to your zones. MTM Health in Virginia sends trips to providers based on capacity, hours of operation, trip distance, and credentialing status, and its marketplace shows open trips within your authorized service area five days ahead. A service area far bigger than your zones fills your offers with long empty drives. See service area.
Step 3: Start each van where its first pickups are
The first and last empty drives of the day repeat every day. In the example, moving the van’s overnight spot from a lot 12 miles away to a spot 2 miles from the zone saves 20 empty miles a day, or $25 at $1.25 a mile.
Letting drivers take vans home is one way to do that. Check these rules before you do:
| Question | The rule | What it means |
|---|---|---|
| Is the drive from home paid time? | Ordinary travel from home to work is not work time (29 CFR 785.35). A commute in the employer’s vehicle is not a principal activity when it stays within the normal commuting area and is covered by an agreement with the employee (29 CFR 785.34). | Put the take-home arrangement in writing, and keep it within the normal commuting area |
| What if the driver must come to your lot first? | When an employee must report to a set place to get instructions, do other work there, or pick up tools, travel from there to the work site is part of the day’s work (29 CFR 785.38) | If drivers collect and check the van at a central lot, plan on the drive from the lot to the first pickup being paid time |
| When does the workday start? | Time between the first and last principal activities of the day counts as hours worked (29 CFR 790.6) | If you require work at home first, such as the pre-trip inspection, ask a wage and hour attorney whether the drive after it is paid |
| Is the commute taxable? | Under the IRS commuting rule, each one-way commute is valued at $1.50 and included in the employee’s wages unless the employee pays it back. You must require the commute for a business reason and have a written policy barring other personal use. The rule does not cover control employees, such as anyone who owns 1% or more of the business (Publication 15-B, 2026). | $3.00 a day added to the driver’s taxable wages. Ask your tax preparer about a van an owner takes home. |
| Do broker rules apply? | MTM Health’s Virginia handbook requires vehicles to be titled and licensed in Virginia and to meet state inspection rules, including vehicles garaged in neighboring states | Check your broker’s vehicle rules before a van sleeps across a state line |
State wage laws can be stricter than federal rules, so check yours. Ask your insurer before a van is kept at a driver’s home, so the policy lists the right location.
Other ways to cut the first and last miles:
- Start the day’s first run from the zone, not from the office, when a driver can pick up the van near the zone.
- End each run near tomorrow’s first pickup when the last drop-off allows it.
- Stage a van near the busiest clinics between legs instead of driving back to base.
Step 4: Chain legs so each drop-off leads to the next pickup
A chain is a run where every drop-off sits close to the next pickup. Build it in this order:
- Place the fixed trips first. Dialysis chairs, first appointments of the day, and known discharges cannot move.
- Work the facility. When you drop a rider at a clinic, look for a rider leaving the same clinic about then. One door, no empty miles.
- Run outbound, then inbound. Morning runs carry riders from homes toward clinics. Late-morning and afternoon runs carry them back. A van that crosses town against that flow drives empty both ways.
- Keep the chain inside the time. Between legs, leave time for the drive at that hour, the full wait the broker allows at the next door, and boarding. The scheduling guide shows how to set that slack.
- Check the last leg. A run that ends far from base, with no trip back, adds its empty miles to the evening.
Step 5: Plan return legs before the day starts
A return leg nobody planned can pull a van across the zone in the middle of the day.
- Put scheduled returns on a run with the same care as the trip out.
- Hold room for will-call returns near the clinics that call. MTM Health’s Virginia handbook requires the van within 45 minutes of the call, and Texas Medicaid health plans within one hour of the request (UMCM 16.4, effective August 1, 2021). A van 30 minutes away has used most of that before it moves.
- Decide wait or return for each long appointment. Waiting saves two empty drives but ties up the van and driver. CMS says a second driver for the return can cost less than a long wait, but that sometimes the long wait is the most economical way home.
Waiting is paid in some programs and not others. Arizona fee-for-service pays $4.59 per half hour under T2007 (October 1, 2026 rates), only when the distance makes returning to base or the pickup site not feasible. It does not pay for waits under 30 minutes, one-way trips, round trips with two vehicles or drivers, trips of 10 miles or less, or waits where the odometer changes between drop-off and pickup. See NEMT wait time billing and managing will-call trips.
Step 6: Share rides where the payer pays for them
Two riders going the same way can share a van. How the miles are paid decides whether sharing adds money or only saves it.
| Program | How a shared ride’s miles are paid |
|---|---|
| New York (manual effective August 25, 2023) | Each rider’s base fee is paid, but the loaded miles are claimed once, from the first pickup to the last drop-off. Members of one household going to the same place are one trip with an additional rider. |
| Arizona fee-for-service (July 31, 2026) | A separate Daily Trip Report for each member. Each member’s miles are the most direct route between that member’s own pickup and drop-off. Wait time is paid for one member only. |
| South Dakota (fee schedule effective July 1, 2026) | Extra riders are billed with the TK modifier at a lower base: $5.20 for an in-city A0120 trip and $2.60 for each extra rider. Mileage is paid only outside city limits (community trips must be 21 miles or more one way), and only once per trip, however many ride. |
| MTM Health, Virginia (August 10, 2026) | Pay follows MTM’s Schedule A rate sheet and reflects mileage driven, mode, and multiloading |
New York’s manual gives an example. Two riders on the same route go to the same clinic, one 13 miles away and one 7. The provider claims the base fee and 13 miles for the first rider picked up, and only the base fee for the second. Under Arizona’s rule, each rider’s claim would instead carry that rider’s own direct-route miles, 13 and 7.
Keep shared rides inside the ride-time limits. MTM Health in Virginia allows no member to ride more than 45 minutes longer than the average direct trip unless authorized. Texas Medicaid health plans allow one hour. See NEMT multiloading and maximum ride time.
Step 7: Take the offers that fit your routes
Once your zones are drawn, judge each broker offer by where it starts and ends, not only by what it pays.
- Price the drive to the pickup. A long empty drive to a short trip can lose money every time it runs. The trip profit calculator does the math.
- Fill gaps from open trips. MTM Health’s Rhode Island handbook (July 1, 2026) points providers to marketplace trips in their area to fill gaps in their assignments. Those trips cannot be turned back once accepted, so take only the ones that fit a run.
- Hand back what does not fit, early. MTM Health in Virginia expects turnbacks at least 24 hours before the scheduled pickup. See broker trip offers.
- Keep the short trips. Louisiana’s manual (July 14, 2025) has the broker watch for providers who reject local trips in favor of long ones, and a pattern can bring trip reductions or other sanctions.
Check the plan against what the vans really drove
A route plan is a guess until you compare it with the odometer. Each week, pull these numbers for every van:
| Number | How to get it | What it tells you |
|---|---|---|
| Empty-mile share | Empty miles ÷ total miles, from start and end odometer readings and trip records | Whether your zones still fit |
| Morning and evening empty miles | Overnight spot to first pickup, last drop-off to overnight spot | Whether vans sleep in the right place |
| Empty miles per trip | Empty miles ÷ trips run | Which weekdays or standing orders cost the most |
| Pay per mile driven | Day’s pay ÷ total miles | Whether the day’s work was worth the driving |
| Trips per vehicle hour | Trips ÷ hours the van was on duty | Whether freed time is being filled. See trips per vehicle hour. |
Location records help. MTM Health’s Virginia handbook requires vehicle location tracking to stay active for the full ride. Compare those tracks with the planned run to see where the van actually went between legs.
Record loaded miles exactly. New York has required loaded miles to the tenth of a mile since August 1, 2019, and says rounded-up claims may be treated as fraud. Arizona asks for a reason when a rider’s miles out and back differ, or it may cut the mileage. When a route adds a detour, such as a second pickup, write down why on the trip record.
Change one thing at a time: a zone border, a van’s overnight spot, or a standing order moved to another van. Then watch the empty-mile share for two weeks. For long-distance runs where one trip can fill a day, see rural NEMT.
Frequently asked questions
What is the difference between NEMT scheduling and route planning?
Scheduling sets the times: when each rider is picked up and how much room sits between legs. Route planning decides the geography: which van runs which trips, in what order, and where each van starts and ends the day. You do both the day before, and they depend on each other. A pickup time only works if the van is already nearby when the previous leg ends.
Does Medicaid pay for the miles between trips?
Generally not. CMS says miles driven without a Medicaid member in the vehicle generally cannot be paid, though states may build their cost into trip rates (SMD 23-006, September 28, 2023). New York pays loaded miles only, and Arizona's fee-for-service manual (July 31, 2026) says a provider may not submit any claim for unloaded mileage. Your base rate has to carry the empty miles.
What share of my miles should be empty?
Track your own number rather than chase a target. Divide empty miles by all miles driven for each van, every day. In the example on this page, zoning and chaining one van cut its share from 58 percent to 27 percent. A share that rises week after week points to a zone, a standing order, or a broker whose trips no longer fit your routes.
Should drivers take NEMT vans home at night?
It can cut empty miles when drivers live near their first pickups, but check three things first. Federal wage rules treat a commute in a company vehicle as unpaid only within the normal commuting area and under an agreement with the driver (29 CFR 785.34). The IRS values the commute at $1.50 each way as taxable wages under its commuting rule, which does not cover anyone who owns 1% or more of the business (Publication 15-B, 2026). Broker rules may apply too, such as Virginia's rules for vans garaged out of state.
Should my driver wait at the clinic or leave and come back?
Compare the empty miles both ways with the pay for waiting, if any. CMS says a second driver for the return can cost less than a long wait, but sometimes the long wait is the most economical choice. Arizona fee-for-service pays $4.59 per half hour of wait (October 1, 2026 rates) only when returning to base is not feasible, and never for waits under 30 minutes or trips of 10 miles or less.
Can I turn down short trips to keep my routes efficient?
Be careful. Louisiana's manual (July 14, 2025) has the broker watch for providers who reject local trips in favor of long ones, and a pattern can bring trip reductions or other sanctions. Shape your routes through your broker profile instead. MTM Health in Virginia assigns trips by each provider's capacity, hours of operation, trip distance, and credentialing status (August 10, 2026).
Official resources
- CMS: Medicaid Transportation Coverage Guide (SMD 23-006)
- EIA: Weekly gasoline and diesel prices by region and state
- IRS: Standard mileage rates by year
- IRS: Publication 15-B, Employer's Tax Guide to Fringe Benefits
- eCFR: 29 CFR Part 785, Hours worked (travel time)
- AHCCCS: Ground transportation fee schedules by year