Medicaid Transportation Benefit at Risk, Former CMS Official Says

Having access to transportation in order to get to medical appointments is one of the recognized examples of social determinants of health.

Writing in a blog post for Health Affairs, a former Obama administration official for CMS urges the Trump administration to drop a budget proposal to allow states to end payment for the Medicaid non-emergency medical transportation (NEMT) benefit. NEMT has been included in Medicaid since the program began more than 50 years ago, as Congress recognized that transportation issues are frequently cited as a barrier to timely, preventative care, and are a leading reason why patients miss appointments.

Eliot Fishman, who was the director of the State Demonstrations Group and the Children and Adults Health Programs Group at CMS from 2013 until early 2017, wrote that the most often cited reasons for using NEMT are accessing behavioral health services (including mental health and substance abuse treatment), dialysis, preventive services (including doctor visits), specialist visits, physical therapy/rehabilitation, and adult day health care services.

Writing with co-author Marsha Simon, PhD, Fishman, now senior health policy director for Families USA, said that in the past CMS has allowed limited exceptions, or waivers, to how states handle NEMT in 1 of 3 circumstances. None of those circumstances were considered a precedent for allowing states to drop or limit NEMT for all Medicaid populations.

The specific circumstance were:

• If limited benefit packages were approved for people who otherwise would not have been eligible for Medicaid, usually for family planning benefits
• Tests of new elements under the Affordable Care Act
• Three states were allowed to limit NEMT in the early stages of state plan amendments to implement the new “benchmark” benefit plans in 2007 to 2009.

It is written into Medicaid that a state plan must "specify that the Medicaid agency will ensure necessary transportation for recipients to and from providers; and describe the methods that the agency will use to meet this requirement."

Fishman and Simon note that studies have found the return on investment is estimated at 10 to 1 and even 11 to 1. They also note that Medicare Advantage plans are offering medical transportation as a business decision despite the lack of Medicare reimbursement for NEMT.

Meanwhile, private, on-demand ride-sharing companies are also getting into the medical transportation business, albeit for those willing and able to pay privately. Earlier this year, Uber introduced Uber Health, a service that allows hospitals, doctor’s offices, and other health systems to order a ride for their patients. Lyft partnered with Allscripts, integrating Lyft’s proprietary application programming interface into Allscripts’ electronic health record system.