Ohio Law Taking Effect October 6, 2026 Requires GPS Verification of Medicaid NEMT Trips Within 18 Months

Ohio Substitute Senate Bill 315, the Ohio Medicaid Program Integrity and Fraud Prevention Act, takes effect October 6, 2026. Governor Mike DeWine signed it on July 7, 2026. It tells the Ohio Department of Medicaid (ODM) to verify Medicaid NEMT trips by GPS, and it adds fraud checks for every Medicaid provider.

What the GPS system must record

ODM may build the system, hire vendors, or connect existing ones (Revised Code 5164.401). It must:

• Use a ride dispatch system like those of other private ride services.
• Track by GPS your arrival at pickup, the ride start, arrival at drop-off, and the ride end.
• Record timestamps, the route, and total miles.
• Send that data straight to ODM as a condition of payment.

The data must be encrypted and used only for Medicaid oversight. ODM must give providers training and technical support, and no rider may be denied medically necessary care only because a provider failed to use the system.

Who it covers

The law covers NEMT given under the federal rule 42 CFR 431.53. It leaves out rides by ambulance and ambulette (wheelchair van) services licensed by the State Board of Emergency Medical, Fire, and Transportation Services, which the Ohio state guide explains. Sedan, ambulatory van, and taxi-type carriers are inside it. The law does not say how the GPS rule reaches trips that health plan brokers or county NET contracts arrange. It tells ODM to coordinate with the Medicaid health plans and to set the details in rules. The exclusion turns on the licensed company, not the vehicle, so an ambulette company that also gives sedan rides should ask ODM in writing whether those rides are covered.

When each step is due

ODM must require every covered provider to use the system no later than April 6, 2028.

Deadline	What ODM must do
November 5, 2026	Send lawmakers a cost estimate
April 6, 2027	Finish technical standards and a rollout plan
October 6, 2027	Start a pilot with some providers
April 6, 2028	Require every covered provider to use it
October 6, 2031	Match GPS data with other providers’ claims for the rider

That last check confirms the rider went to a Medicaid service at an enrolled provider. Proposed rules on GPS intervals and exemptions get public notice in the Register of Ohio at least 30 days before a hearing.

When a claim gets paid

Once the system is fully running, a NEMT provider gets paid only for trips whose data it sends through the system. ODM must pay a claim when all required GPS and timestamp data are present and no discrepancy about it is unresolved. ODM may grant an exemption for equipment failure or no network, including rural coverage gaps, for emergencies, or for the rider’s safety. Each request must be in writing, and ODM tracks how often each provider asks.

Fraud tools will flag repeated exemptions and gaps between location data and claims, and a person at ODM must review each flag before acting.

The law sets no provider fee and does not say who pays for equipment. The final fiscal note says the NEMT rules may need new state purchases and may add costs for county-run NEMT.

Rules that reach every provider

• Fraud form. You sign a form on Medicaid fraud penalties before ODM enters into a provider agreement with you.
• Owners. At enrollment and revalidation, you name every person who owns 5 percent or more, directly or indirectly.
• Shorter agreements. Agreements last three years at most, not five.
• No claims in a year. ODM must suspend the agreement of a provider that sends it no claim for a year.
• Fast growth. ODM must temporarily suspend payments and investigate a suspicious jump in claims in your first 60 days. It must also flag and investigate any month your claims more than double without a matching rise in the Medicaid members you serve.
• Fraud allegations. When the Attorney General or Auditor of State sends a credible allegation of fraud with evidence, ODM must suspend payments in whole or in part and review your claims before paying. The law’s examples include impossible travel patterns.
• Health plans. Plans may hold payments or review claims first, but only with state approval.

What to do now

1. Record GPS times, the route, and miles on every Medicaid trip now. See NEMT GPS tracking.
2. Log dead zones and device failures in writing for future exemption requests.
3. Comment on ODM’s proposed rules when they appear.
4. Before you revalidate, list every 5 percent owner. See Medicaid revalidation.
5. If you bill only through brokers, ask ODM whether the one-year rule applies to you.