NEMT Trip Documentation Requirements in 2027: What Every Trip Record Needs

A trip record is your proof that a ride happened the way you billed it. When a state auditor, a broker, or a federal reviewer asks for it, the record has to show who rode, from where to where, when, how far, in which vehicle, with which driver, and that someone confirmed the ride. If a piece is missing, the payment for that ride can be taken back.

What the federal rules require

Federal law sets the duty to keep records. States and brokers decide which fields go on them.

• Keep records and hand them over. Under 42 CFR 431.107(b), every Medicaid provider agrees to keep the records needed to show the extent of the services it gives. It must produce them on request for the state Medicaid agency, the HHS Secretary, or the state Medicaid fraud control unit.
• Tie the ride to medical care. Under 42 CFR 440.170(a)(1), Medicaid transportation covers travel the state finds necessary to get medical examinations and treatment. A record that cannot show the medical visit cannot show the ride was covered.
• Make the record accurate and complete. CMS’s Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023) says trip documentation exists to show that each claim was for necessary transportation to or from covered services.
• Screen every driver. Section 1902(a)(87) of the Social Security Act, added by the Consolidated Appropriations Act, 2021, requires each state to have a way to confirm that every NEMT provider and driver is not excluded from federal health programs, that each driver holds a valid license, and that each provider has a process for state drug law violations. Each provider also needs a process to report each driver’s driving history to the state. The state may accept your attestation.

Federal reviewers use the same standard. When HHS’s Office of Inspector General (OIG) announced a new series of state NEMT payment audits on May 28, 2026, it noted that NEMT providers must keep records supporting the services they provide.

What every trip record needs

A trip leg is one ride from A to B, so a round trip to dialysis needs two records. The table groups each field by what it proves, with the states and brokers that name it in writing.

What the record must prove	Fields to capture	Where it is required
Who rode	Rider’s full name and Medicaid ID; escort or attendant name and relationship	New York manual; Minnesota statute; Arizona (name, AHCCCS ID, date of birth, mailing address); Indiana
That the ride was approved	Trip ID or authorization number; level of service approved	MTM Health Virginia (no ride without the trip ID); New York (prior authorization number on the claim)
When it happened	Date; pickup time; drop-off time; scheduled and actual pickup times for broker trips	New York; Minnesota; Arizona (clock time with a.m. or p.m.); MTM Health Virginia
Where it went	Full pickup and drop-off addresses, or coordinates or a landmark when there is no address	New York; Minnesota; Arizona; Indiana (street, city, county, state, and ZIP)
How far it went	Odometer at pickup and drop-off, or GPS or mapping data; method used to find the direct route	Minnesota (odometer both ends and the route method); Arizona (odometer); Indiana (odometer or mapping software showing the shortest route); New York (GPS data)
Who drove, in what	Driver’s printed name; driver’s license number; plate number; vehicle type	New York (license and plate numbers); Minnesota (plate and mode); Arizona (plate or fleet number, make, color, and type)
What level of service	Ambulatory, wheelchair, stretcher, or your state’s mode names	Minnesota (mode of transportation); Indiana (ambulatory or non-ambulatory); Arizona (vehicle type)
That it really happened	Driver’s signature and attestation; rider’s signature or the approved fallback	New York (driver attestation); Minnesota (driver and rider); Arizona (driver and member); MTM Health Virginia (member signature)

Minnesota’s list is the most complete in statute. Minnesota Statutes 256B.0625, subdivision 17b (2025), requires 14 elements, written in English and legible to a reasonable person. It also requires records that can tell individual trips apart by vehicle and driver. The NEMT trip log template turns these fields into a printable form, one record per leg.

Arizona’s fee-for-service program is the exception to using your own form. As of its manual revised July 31, 2026, every NEMT claim must come with the AHCCCS Daily Trip Report, and providers may not make their own version. Claims without it are denied.

The papers behind each trip record

The trip log proves the ride. An auditor also checks that the ride was approved, that the rider needed that level of service, and that a covered visit took place.

The approval

Brokers issue a trip number for each ride. MTM Health’s Virginia handbook (approved August 10, 2026) says never to transport a member without the unique trip ID, and MTM does not guarantee payment for trips run without prior authorization. Keep the trip assignment with the record. See prior authorization for NEMT.

The order for the level of service

Some rides need a practitioner’s form. In New York, every request for ambulette or non-emergency ambulance transportation must include a written form verifying the rider’s transportation abilities, and the ordering practitioner documents the medical reason in the patient’s record. Medi-Cal fee-for-service needs an approved Treatment Authorization Request with a legible prescription (ground transportation manual, updated June 2023). See NEMT medical necessity forms and NEMT level of service.

Dates matter. In OIG’s review of 100 payments to New York City providers for 2018 and 2019 (report A-02-21-01001, September 2022), 22 lacked a valid practitioner’s order. For 6 of those, the order was dated after the ride, by 2 to 33 months. One payment was for an ambulette ride when the order and the approval were for a taxi.

Minnesota pays by the rider’s assessed mode, not by the vehicle you send. Record the level of service the rider was approved for and the one you gave. If they differ, note why.

Proof the rider went to a covered visit

Ask where the rider is going when the trip is booked. Arizona requires the provider to get enough information at booking to know the ride is to a covered service. Indiana makes providers responsible for verifying that each ride goes to or from a covered service.

Auditors test this by matching each ride to a medical claim for the same day. In OIG’s Massachusetts audit (report A-01-19-00004, January 2021), the sample came from rides with no medical claim billed that day, and 48 of 100 had no qualifying medical service. In one, the clinic had canceled the group therapy the rider was going to. When a facility cancels, record the call and do not bill the ride unless your state or broker pays for it.

Times, odometer readings, and GPS

Miles are where auditors look hardest, because they drive the payment. Record them at the curb, not at the end of the shift.

• Minnesota requires the odometer reading at pickup and at drop-off, the mileage for the most direct route, and a record of the method used to find that route.
• Arizona figures trip miles as the drop-off odometer minus the pickup odometer. If the miles going and coming back differ, explain why on the Daily Trip Report, or AHCCCS may cut the difference.
• Indiana accepts odometer readings or mapping software, and mapping software must show the shortest route (transportation module, version 6.1, August 19, 2025).
• New York has required every transportation provider to be fully GPS compliant since April 3, 2023, unless the state grants an exemption. For each trip, the provider sends the broker the start point, the end point, and all GPS points along the way. For dates of service since August 1, 2019, loaded miles are billed to the tenth of a mile, and rounding up can be treated as fraud.
• MTM Health in Virginia requires vehicle location tracking for the full ride. Its standard is GPS tracking on more than 90.01 percent of trips.

Brokers also compare times with miles. MTM Health’s Virginia handbook scores the share of trips whose documented minutes and miles do not fit together. It also flags any time one driver was in two vehicles, or two drivers were in one vehicle, at the same time. Both must stay under 0.99 percent of trips.

For billing rules, see NEMT mileage billing. For what location data proves in an audit, see NEMT GPS tracking.

Signatures: who signs and what to do when no one can

Two people usually sign: the driver, who attests the record is true, and the rider, who confirms the ride.

The driver. Since March 1, 2016, New York has required the driver’s full printed name, signature, and attestation that the trip was completed, or a note that it was a no-show. Minnesota’s driver attestation states that the record shows the services given and the actual miles driven, and that misreporting can lead to civil or criminal action. Arizona does not accept initials, a stamp, or a typed name as the driver’s signature.

The rider. Minnesota, Arizona, Indiana, and MTM Health in Virginia all ask for the rider’s signature. When the rider cannot sign, the fallback depends on where you drive:

State	When the rider cannot sign
Arizona	A parent, guardian, caretaker, escort, or family member signs and writes the relationship, such as “by J Smith, daughter.” If the rider traveled alone, the medical provider may sign. A fingerprint also counts.
Indiana	The driver writes “the patient was unable to sign” and the reason. Any accompanying adult or attendant billed on the claim also signs.
Minnesota	An authorized party signs, or the medical provider certifies the rider arrived. If no one will sign, the driver records that signatures were requested and not given.

Arizona forbids the driver from signing for the rider in every case, even when the driver is a family member or a caregiver. For state and broker rules on how often signatures are needed, see NEMT signature requirements.

No-shows, cancellations, wait time, and shared rides

The rides that did not go as planned need the most careful records.

• No-shows. New York has drivers wait at least 15 minutes after the scheduled pickup time before marking a no-show, and has providers document every one. MTM Health in Virginia counts a pickup as on time from 15 minutes before to 15 minutes after the scheduled time. If the rider is not ready, the driver follows MTM’s no-show steps and tries the rider by phone or text before leaving.
• Cancellations. Mark the leg canceled right away so it never reaches a claim. In the Massachusetts audit, one sampled ride was billed after the rider canceled, and another was billed because the dispatcher never heard the rider was not transported.
• Wait time. Indiana wants the actual start and stop times of each wait, such as 1 p.m. to 3:20 p.m. Arizona does not pay wait time if the odometer reading changes between drop-off and pickup. See NEMT wait time billing.
• Shared rides. Arizona requires a separate Daily Trip Report for each member in the vehicle, with the odometer miles for that member’s own direct route. New York bills group ride miles once, from the first pickup to the last drop-off. See NEMT multiloading.
• Attendants. Minnesota requires the name of any extra attendant on the record. Indiana requires the name and relationship of any accompanying adult or attendant billed.

Driver and vehicle records that back up each ride

A trip record names a driver and a vehicle. The files behind those names must show both were qualified on that date.

MTM Health’s standard agreement, in the January 1, 2023 version Pennsylvania posts, pays nothing for rides by uncredentialed drivers or attendants, or in uncredentialed vehicles. It also requires a yearly motor vehicle record covering the previous three years for each driver. In Minnesota, every driver must be individually enrolled with the state and reported on the claim as the person who gave the ride.

Auditors check these files. In the Massachusetts audit, driver qualifications and vehicle records were not adequately documented for all 100 sampled rides. In the New York City audit, 7 payments lacked driver qualification records, such as the medical exams and road tests ambulette drivers need.

Keep one file per driver and one per vehicle, with renewal dates. Use the NEMT driver file checklist and the vehicle inspection checklist. Check each driver against the OIG exclusion list before the first ride.

Paper or electronic records

Most programs accept either, as long as the record is complete and you can produce it.

• Minnesota allows paper or electronic systems, if you can produce the records on request. Starting January 1, 2027, or on federal approval if later, Minnesota NEMT providers must also follow the state’s electronic visit verification law. A record from that system can then serve as the trip record if it holds every required element (Session Laws 2026, chapter 121, signed May 27, 2026). See EVV for NEMT.
• New York accepts a unique electronic driver signature in place of a written one. The system must record the pickup and drop-off coordinates and keep a system-generated date and time stamp for each leg that cannot be changed.
• Arizona accepts a Daily Trip Report filled out on a tablet if the rider and driver sign with an electronic pen or a fingertip. A typed name never counts as a signature.
• Indiana says a copy of the claim form is not documentation. Records must be made when the service is given and before the claim is sent (provider enrollment module, version 7.1, September 8, 2026).

New York is also clear about what does not count. A manifest, a dispatch sheet, a prior authorization roster, or a day program attendance log cannot be the only evidence of a trip. Each can only support the trip record.

Trip records hold a rider’s name, Medicaid ID, and where they get care. Store them where only your staff can open them. See HIPAA for NEMT providers.

How long to keep trip records

Rule	How long
Minnesota Rules 9505.2190	At least 5 years after the first billing date
New York Medicaid Transportation Policy Manual (effective August 25, 2023)	6 years after the date of payment
Indiana provider enrollment module (version 7.1, September 8, 2026)	7 years from the date of service
MTM Health standard agreement (January 1, 2023 version posted by Pennsylvania)	10 years, or longer if law or MTM’s client requires

The longest period that applies to you wins. Leaving Medicaid does not end the duty. Minnesota requires a provider that withdraws or is terminated to keep its records and produce them on demand. Federal False Claims Act suits can generally be filed up to 6 years after a claim, and in some cases up to 10 (31 U.S.C. 3731). See the False Claims Act and NEMT record retention.

If a fire or flood destroys records in New York, report the loss to the Office of the Medicaid Inspector General with details of the event, the records lost, and the dates of service affected.

What auditors find missing

Three federal audits show where NEMT records fail.

Audit	Sample	What was missing
Massachusetts, A-01-19-00004 (January 2021)	100 ride lines from 2016 and 2017 with no medical claim billed the same day	For 38, no driver trip sheet could be produced. For 24, the sheet lacked details such as the pickup and drop-off address, date, and appointment time. 48 had no medical service that day.
New York City, A-02-21-01001 (September 2022)	100 payments for 2018 and 2019	11 lacked the date, pickup and drop-off locations, driver, and vehicle. 2 had no record at all. 22 lacked a valid practitioner’s order.
Indiana, A-05-18-00043 (August 2020)	120 claims from 2016 and 2017	17 had no records. The providers had closed, left the program, moved, or could not find them.

More reviews are underway. An OIG evaluation announced October 15, 2025 (OEI-02-25-00360) uses billing red flags to target NEMT services for review. The state audit series announced May 28, 2026 checks whether selected states met Medicaid payment rules for NEMT. See Medicaid audits for NEMT providers for what an audit request looks like.

How to set up trip documentation, step by step

1. Collect your rules. Pull your state’s NEMT provider manual and each broker’s manual and contract. Build one field list that meets the strictest rule.
2. Make one record per leg. Each leg gets its own times, odometer readings or GPS data, and signatures, even on a round trip.
3. Record at the curb. Capture pickup and drop-off times and odometer readings as they happen. Never fill them in from memory later.
4. Get the signature before the rider leaves. Train drivers on your state’s fallback when the rider cannot sign.
5. Attach the approval. Keep the trip number, the authorization, and any practitioner form with the record. Note any change to the level of service.
6. Close out every day. Match each record to the day’s manifest. Fix blank fields that day, and hold any incomplete leg back from billing.
7. Match the claim to the record. The date, level of service, and miles on the claim should match the trip record exactly. Mismatches cause many NEMT claim denials.
8. Keep driver and vehicle files current. Renew licenses, checks, and inspections before they expire.
9. Check yourself. Each month, pull a few paid legs at random and confirm every field and signature is there. Fix the habit behind any gap you find.