2026 NEMT Mid-Year Review: What Changed and What's Next

Drawn from Genie Journal issues #01 through #06 · 12 min read

Six months ago we published our read on what would change in NEMT in 2026: broker consolidation, tightening compliance, rate pressure, and an aging population pushing demand up regardless. Half the year is gone. Some of that held up. One call was wrong within weeks. This is what actually happened between January and June, organized by theme rather than by month, with our own predictions scored at the end.

The short version: the broker map was redrawn in at least four states, Medicaid enforcement went from a Minnesota problem to a national mandate in under 90 days, two states wrote electronic trip verification into law, and fuel did something almost nobody predicted. Underneath all of it, one requirement kept surfacing in every state and every contract: prove the trip happened.

Contents:

• 1. Brokers: The Map Got Redrawn
• 2. State Medicaid: Reform Moved Faster Than Expected
• 3. Compliance: From One State to All Fifty in 90 Days
• 4. Technology and AI: The Accessibility Gap Held
• 5. Funding and Cost: The Fuel Whipsaw
• Scoring Our Own 2026 Predictions
• What Carries Into the Second Half

1. Brokers: The Map Got Redrawn

The year opened with Modivcare emerging from Chapter 11, having cut funded debt by more than 85%, roughly $1.1 billion, and secured $100 million in new capital. It never stopped paying providers through the restructuring. But financial stability did not translate into contract stability. Within days, more than 100 Maine lawmakers signed a bipartisan letter urging the governor to terminate the state's $750 million MaineCare NEMT contract and reopen bidding.

What followed was the busiest six months of broker turnover in recent memory. SafeRide Health took over NEMT for UnitedHealthcare Community Plan of Texas on January 1, while MTM Health picked up the Nebraska equivalent the same day. In March, HealthSpring moved its Cigna Medicare Advantage NEMT benefit from Modivcare to MTM. On April 1, Georgia consolidated all five Medicaid regions under Verida, replacing Modivcare statewide. And Colorado set July 1 for its metro program to move from Transdev Health Solutions to MediDrive, covering nine counties in Phase 1.

Consolidation continued on the corporate side too, with MTM's acquisition of Access2Care extending its coverage across all 50 states.

2. State Medicaid: Reform Moved Faster Than Expected

States did not wait for Washington. North Carolina opened the year by reversing the 3% NEMT rate cut that took effect in October 2025, restoring reimbursement to prior levels with retroactive corrections that did not require providers to resubmit claims. Colorado found a five-year billing error that had allowed metro Denver providers to bill roughly $669 per large wheelchair pickup instead of roughly $65, with the correction projected to return about $33 million this fiscal year and $60.5 million in FY 2026 to 2027.

The most consequential state action came out of Colorado. HB26-1328 cleared the House 56 to 9 and the Senate 32 to 3, and was signed into law on June 4. It creates a Transportation Community Advisory Board inside HCPF, requires brokers to provide participating providers with software, training, and technical assistance, mandates auditable electronic trip records, and reclassifies NEMT from an administrative cost to a medical service so the state can capture a higher federal match. New York moved in a similar direction with S9398, which would pilot a unified platform for NEMT authorization, coordination, monitoring, and payment across two to five counties.

Maryland expanded coverage rather than tightening it. CMS approved a state plan amendment requiring Medicaid NEMT to cover related travel expenses including lodging and meals, with a federal budget impact of about $428,000 for FFY 2026. Meanwhile Medicaid work requirements moved from federal mandate to state rollout, with Indiana signing a three-month rule in March, Idaho following in April, and Nebraska implementing early via state plan amendment on May 1. CBO estimates 18.5 million adults across 42 states and D.C. will be subject when the federal mandate takes effect January 1, 2027.

On the Medicare Advantage side, the story reversed mid-quarter. The CY 2027 Advance Notice proposed an effectively flat 0.09% net payment increase in January. After a record 47,000 comments and sustained industry pressure, CMS finalized 2.48% on April 6, worth more than $13 billion.

3. Compliance: From One State to All Fifty in 90 Days

This was the defining theme of the half-year. In February we reported a federal audit flagging up to $196 million in questionable New York Medicaid NEMT payments out of $445 million reviewed, a Massachusetts indictment over an alleged $770,000 phantom-rides scheme covering more than 16,000 trips, and a Minnesota guilty plea in a multi-million-dollar fake rides case.

Minnesota became the test case. CMS withheld $243.8 million and named NEMT among 14 high-risk provider types. State DHS reported 71 open NEMT investigations and a 62% drop in billed rides after the program was flagged. A revised corrective action plan was approved in March covering 17 elements and 35 implementation dates, but a federal judge declined to release the deferred funds in April. By May 31, DHS had completed a five-month review of 5,583 high-risk providers: 2,061 revalidated, 3,411 notified of disenrollment, 59 referred to the Office of Inspector General. Most disenrollment notices traced to incomplete paperwork, failed site visits, or failed background studies rather than fraud. After provider and lawmaker pushback, DHS reopened billing for about 2,140 providers that appealed.

Then it went national. On April 23, CMS ordered all 50 states to submit plans within 30 days to revalidate Medicaid providers in high-risk categories, with NEMT included. Ohio and Missouri governors launched state initiatives within days of each other in May. Colorado extended its enrollment moratorium, which had already blocked more than 600 suspected entities and prevented over $24 million in improper payments, to at least September 30, 2026. CMS deferred $1.3 billion in payments to California in May. HHS-OIG opened a dedicated NEMT audit series on May 28. And on June 10, Ohio passed SB 315, naming NEMT providers directly and requiring Medicaid claims to be supported by GPS-based location data and timestamps.

4. Technology and AI: The Accessibility Gap Held

Uber Health launched self-booking in March, letting healthcare organizations fund trips while riders book independently, with early pilots showing an 86% drop in cancellation and missed connection rates. That deepened rideshare's position in ambulatory, low-acuity volume, but it did not move the line that matters. Neither did autonomous vehicles.

The AV numbers are genuinely impressive: more than 15 million Waymo rides in 2025, expansion into Nashville and Orlando in April, and a reported 92% reduction in crashes resulting in serious or fatal injuries across more than 170 million autonomous miles. But no autonomous medical transportation service operates nationwide. Veyo estimates 85% of ambulatory rides require skills beyond driving: door-to-door assistance, wheelchair securement, CPR certification, HIPAA compliance. An autonomous system can navigate, but it cannot secure a wheelchair or respond to a medical emergency, which means autonomous NEMT still requires a human attendant in the vehicle and the labor-savings math changes accordingly.

The more practical vehicle news came in April, when Kia and BraunAbility unveiled the PV5 WAV concept at the New York International Auto Show, positioned as the first factory-built, fully electric wheelchair-accessible taxi and rideshare vehicle designed with production feasibility in mind.

5. Funding and Cost: The Fuel Whipsaw

On May 6 the national average gas price hit $4.50 a gallon, up 43.6% year over year, with every state posting double-digit increases. Wheelchair vans get 12 to 16 miles per gallon, so per-trip fuel cost on a typical 15-mile round trip climbed from roughly $3 to more than $4 in twelve months. Analysts expected elevated prices through at least the third quarter.

Six weeks later it had reversed. The national retail average slipped below $4 on June 15, roughly an 11% pullback from the peak, with wholesale benchmarks near $2.89 and down more than 23% over the month. The relief was real but the volatility was the actual lesson, and unlike trucking, NEMT broker contracts rarely include automatic fuel escalation.

On the capital side, Massachusetts announced $15.66 million through MassDOT's FY26 Community Transit Grant Program, funding 131 fully wheelchair-accessible vans across 27 regional transit authorities, councils on aging, municipalities, and nonprofits, combining FTA Section 5310 dollars with state Mobility Assistance Program funds. And the NEMTAC national rate survey put a number on what providers had been saying individually: 65 to 70% called current rates barely sustainable or unsustainable, with fully loaded driver costs clustered at $25 to $34 an hour.

Scoring Our Own 2026 Predictions

Here is how the forward-looking calls in our 2026 trends piece held up against six months of actual events.

"The market is rapidly consolidating around larger brokers." Held. Georgia consolidated five regions into one broker. MTM absorbed Access2Care and picked up contracts in Nebraska and from Cigna. Modivcare stabilized financially but lost ground on contracts. The direction was right and the pace was faster than we expected.

"GPS trip verification is becoming a contract requirement in more states each cycle." Held, and then some. We framed this as a gradual contractual drift. It became statute. Colorado wrote auditable electronic trip records into law in June, Ohio passed GPS-verified claims requirements the same month, and the CMS 50-state revalidation order made the underlying documentation standard national rather than state by state.

"Rideshare legally cannot enter the high-acuity market." Held. Uber Health expanded its ambulatory footprint through self-booking, and autonomous fleets logged millions of rides, but not one vehicle in commercial service can carry a passenger who stays in their wheelchair. The moat is intact.

"Medicare Advantage transportation benefits will keep eroding." Partly wrong. The share of MA plans offering transportation did fall to 24%. But we did not anticipate the rate reversal. CMS went from a proposed 0.09% to a final 2.48%, worth more than $13 billion, after record public comment. That does not restore the benefit, but it changes the trajectory we described, and the correct read now is stability rather than continued decline.

"Fuel prices will stay elevated through at least Q3." Wrong. This is the clearest miss. We wrote it during the May spike when the national average hit $4.50 and the supply picture looked locked in. Prices were back under $4 by mid-June. The underlying advice, negotiate escalation clauses and tighten routing, survives the miss, because the volatility itself is the risk. But the forecast was wrong and it was wrong quickly.

"About 60% expect rural provider exit if nothing changes." Too early to score. Six months is not enough to observe this, and the enforcement-driven disenrollments in Minnesota and Colorado make the signal hard to separate from compliance attrition. We will revisit at year-end.

What Carries Into the Second Half

Three things are already scheduled. Colorado's MediDrive transition took effect July 1 alongside a 2% Medicaid provider rate reduction, making it the clearest live test of whether a state can modernize and tighten reimbursement at the same time. Ohio's SB 315 verification framework phases in over eighteen months from early October. And Medicaid work requirements reach their federal effective date on January 1, 2027, with states still calibrating against CMS guidance.

The through-line across all five themes is the same requirement stated five different ways. States want it. Brokers want it. Auditors want it. Health plans increasingly pay for it. Prove the trip happened, with location data, timestamps, and a complete record, and most of what made the first half of 2026 difficult becomes a qualification rather than a threat.