Cutting Medicaid Non-Emergency Medical Transportation Will Harm Community-Level Public Transportation

"As has been discussed previously on the Health Affairs Blog (here, here, and here), Medicaid’s non-emergency medical transportation (NEMT) benefit is stuck in the crosscurrents of competing trends: On the one hand, the value of the benefit is increasingly apparent due to recent research and the increasing interest in NEMT as a tool to address social determinants of health. On the other, the Trump administration is persistently taken actions (including a Request for Information scheduled for this year and a regulation projected for 2021 that will have the effect of curtailing Medicaid NEMT, even as the administration advances policies to promote NEMT in other health care markets (including as a transportation supplemental benefit in Medicare Advantage).

The purpose of this post is not to re-hash arguments previously made on the blog but to advance a new argument for the importance of NEMT. That is: Because Medicaid NEMT and local transportation services are commonly provided by the same local transportation agencies, the two services are interdependent. Cuts to Medicaid NEMT would therefore undermine entire communities’—not just Medicaid beneficiaries’—access to transportation. This is particularly true in rural states where local transportation agencies have fewer funding streams and serve less affluent communities. While states rely on different models to deliver NEMT (including contracting with statewide NEMT brokers, embedding NEMT within managed care organization contracts, and directly reimbursing transportation providers), transportation agencies remain important providers of NEMT—particularly in rural communities. To create efficiencies, transportation agencies commingle Medicaid NEMT with other essential services, including para-transit for people with developmental and physical disabilities, senior rides for older adults, and services for other vulnerable citizens who rely on public transportation to get to work, grocery stores, vocational training, and other destinations necessary to maintaining community engagement."