Minnesota Now Reviews Every Fee-for-Service NEMT Claim Before Paying It

Since late December 2025, the Minnesota Department of Human Services (DHS) has suspended every fee-for-service claim for nonemergency medical transportation (NEMT) and reviewed it before paying. Governor Tim Walz announced the prepayment review on October 29, 2025, for 14 services DHS calls high risk. A law signed May 27, 2026 writes the review into state statute from January 1, 2027, and requires DHS to review at least 65 percent of all fee-for-service claims starting April 1, 2027.

What changed

Item	Detail
Announced	October 29, 2025, by Governor Walz
Reviews began	Late December 2025. Suspended claims first showed on the December 30, 2025 remittance advice
Claims covered	All fee-for-service claims for 14 high-risk services, including NEMT
Claims not covered	Claims paid by health plans such as UCare, Blue Cross Blue Shield, and HealthPartners, which run their own prepayment review
Who runs the checks	Optum, a contractor, runs data checks and sends findings to DHS. DHS decides
How long it can take	DHS says 30 days to pay or deny clean claims and 90 days for complex claims, which include suspended claims
Temporary or permanent	Permanent. DHS says it may expand to all Medicaid services

NEMT is the only transportation service on the list. The other 13 are mostly home and community-based, behavioral health, and autism services, such as adult day services and Early Intensive Developmental and Behavioral Intervention.

The review is tied to the service on the claim, not to the type of provider. Any fee-for-service claim that bills NEMT is held, even if DHS paid your earlier claims without a problem.

How the review works

DHS’s frequently asked questions, updated January 30, 2026, describe each step.

1. You submit the claim as usual in MN-ITS or by batch. The suspension time counts from the date the claim enters the DHS system.
2. DHS suspends it. Your Provider Supplemental Data remittance advice (RA02) shows the claim as “suspended.” A claim status request in MN-ITS shows category P2 and status 46. The X12 835 file lists only paid or denied claims, so check the PDF remittance advice in the 835_PDF folder of your MN-ITS mailbox.
3. Optum runs its checks and shares findings with DHS.
4. Claims that pass are released in the following warrant cycle, two weeks later. A warrant cycle is the two weeks of claims that end at each claim cut-off date on DHS’s payment calendar.
5. Flagged claims get a closer look. If DHS needs records, it puts a request letter in your MN-ITS mailbox, in a PREPAYDOCREQUEST folder that appears only when you have a request. DHS said on February 13, 2026 that it may suspend future payments if you do not reply.
6. DHS pays or denies the claim.

You cannot ask DHS to speed up a review. If you bill NEMT and another service on the same claim, the whole claim suspends, so DHS suggests billing high-risk services on separate claims.

How long payment takes now

Before the review, DHS says, providers may have been paid right after each warrant cycle ended, about every 14 days. Now a flagged claim can take up to the full timeframe in state law.

	Before late December 2025	Since late December 2025
Claims with no problems	Paid after the warrant cycle ended	Released in the next warrant cycle, two weeks later
Flagged claims	Not applicable	Held for review. Complex and suspended claims can take up to 90 days
Faster review on request	Not applicable	Not available
Extra funding while you wait	Not applicable	None. DHS says it offers no extra funding

Federal rules set the outer limits. Under 42 CFR 447.45, a state must pay 90 percent of clean claims from practitioners in individual or group practice within 30 days of receipt and 99 percent within 90 days. It must pay all other claims within 12 months. A claim under review for medical necessity, or from a provider under investigation for fraud or abuse, is not a clean claim. The 12-month limit does not apply to a provider under investigation.

DHS also reminds providers that you cannot stop serving members while claims are held. State law requires enrolled providers to keep offering services, and DHS may end the enrollment of a provider that stops.

Prepayment review is not the same as a payment withhold. A withhold comes from the DHS Office of Inspector General, which notifies the provider directly. See payment suspensions for how a withhold works.

Why NEMT is on the list

NEMT showed up early in the findings. Optum’s Phase 1 report to DHS, dated January 30, 2026, says it ran 12 checks on NEMT claims. When Optum and DHS reviewed the first findings on November 24, 2025, Optum named four providers for DHS to consider for payment suspension, and three came from the NEMT checks.

DHS’s March 2, 2026 briefing to the Minnesota House Fraud Prevention Committee listed more NEMT oversight:

• NEMT is a high-risk provider type, with background checks and site visits at enrollment and at revalidation every three years.
• New NEMT providers in the seven-county metro area cannot enroll during a moratorium that began January 27, 2026. On July 23, 2026, DHS extended it to January 27, 2027. See Minnesota’s metro enrollment freeze.
• A private vendor audits fee-for-service NEMT after payment. Auditors check trip logs, driver and vehicle credentials, and whether billing is backed by mileage and authorizations. The briefing said the auditor was reviewing 62 NEMT providers.

The same briefing showed how much fee-for-service NEMT the review covers. In 2024, 551 fee-for-service NEMT providers provided 1.4 million trips, with $32.2 million in paid claims. Health plans oversee 80 percent of NEMT spending, and their claims are outside this review.

What the 2026 law adds

Chapter 121 of the 2026 Minnesota Session Laws, signed May 27, 2026, creates a new section, Minnesota Statutes 256B.0447, effective January 1, 2027.

Rule	What the law says
Review is required	DHS must conduct enhanced prepayment review of fee-for-service Medical Assistance claims
Share of claims	At least 65 percent of all fee-for-service claims, starting April 1, 2027
Notice to a provider	Written notice at least 15 days before a provider is placed under review, with the reason, the start date, and the standards for ending the review. DHS may delay, limit, or withhold notice to protect an audit or investigation
Payment timing	The review must follow the federal timely payment rule, 42 CFR 447.45
New riders	A provider under review can still take new clients unless another action bars it
Public reporting	At least once a year, DHS must post the services under review and the results, including denials, delayed payments, and referrals

The same chapter adds Minnesota Statutes 256B.0448 on postpayment review, also effective January 1, 2027. A provider under postpayment review must keep records that support its claims and send them when DHS asks. Missing the deadline can lead to recovery of payments or sanctions under section 256B.064.

What to keep ready

Minnesota law already says what a trip record must show. Under Minnesota Statutes 256B.0625, subdivision 17b, payment depends on a record for each trip, and money paid for an undocumented trip can be recovered. Records must be legible, in English, and able to tie each trip to a specific vehicle and driver.

Each trip record needs	Notes
Rider’s name	The member who rode
Date of service	Required when it differs from the date the entry was made
Driver’s printed name or provider number	Enough to identify the driver
Driver’s dated signature	Attesting the record and actual miles are accurate
Rider’s or medical provider’s dated signature	If both refuse or cannot sign, the driver notes that signatures were requested
Origin and destination addresses	With the mileage for the most direct route and how that route was found
Mode of transportation	Name or number of the mode
Vehicle license plate	For the vehicle used
Pickup and drop-off times	Both required
Odometer readings	At pickup and at drop-off
Extra attendant’s name	When one is used for special transportation

Chapter 121 also adds NEMT to Minnesota’s electronic visit verification law, Minnesota Statutes 256B.073. Starting January 1, 2027, or on federal approval if that comes later, NEMT providers must meet its requirements, and an electronic visit record that holds every element above can serve as the trip record.

See NEMT trip documentation for how to build these records, or use our trip log template.

What fee-for-service NEMT providers should do now

1. Check your MN-ITS mailbox every business day. Look for a PREPAYDOCREQUEST folder and answer any request by the date in the letter.
2. Read your RA02 each warrant cycle. Track every suspended claim by its claim number and submission date.
3. Bill NEMT on its own claims. Keep other services off the same claim so they are not held too.
4. Plan for up to 90 days of waiting. Build a cash reserve that covers payroll, fuel, and insurance while claims sit in review. See NEMT cash flow and how long Medicaid takes to pay.
5. Complete every trip record before you bill. A flagged claim is only as strong as the record behind it.
6. Keep serving your riders. Stopping service can cost you your enrollment.
7. Watch your mail in 2027. From January 1, 2027, DHS must give written notice at least 15 days before it places a provider under enhanced prepayment review, unless notice would harm an audit or investigation.

For enrollment, licensing, and rates across the state, see our Minnesota state guide. To prepare for an audit after payment, see how to prepare for a Medicaid audit.

Key dates

Date	What happened
October 29, 2025	Governor Walz announces prepayment review for 14 high-risk services
November 24, 2025	Optum and DHS review the first findings: three of four providers named for possible suspension come from NEMT checks
December 30, 2025	Suspended claims appear on the remittance advice
February 13, 2026	DHS says it has begun placing documentation requests in MN-ITS mailboxes
March 2, 2026	DHS briefs the House Fraud Prevention Committee on NEMT oversight
May 27, 2026	Governor signs chapter 121, which makes prepayment review a state law
January 1, 2027	Minnesota Statutes 256B.0447 and 256B.0448 take effect
April 1, 2027	DHS must review at least 65 percent of all fee-for-service claims

Who to contact

• Prepayment review questions: dhs.healthcare-providers@state.mn.us. Say you are an enrolled provider.
• MHCP Provider Resource Center: 651-431-2700 or 800-366-5411
• DHS NEMT policy questions: transportation.DHS@state.mn.us