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New GPS Compliance Mandate in New York State for NEMT Providers

The Non-Emergency Medical Transport (NEMT) industry is constantly changing. Only businesses that quickly adopt new technology can survive in this market.   

The latest update is the New York State Department of Health’s (NYSDOH) new mandate for NEMT providers or Transport Providers (TPs).   

In a communication to registered TPs dated February 1, Medical Answering Services (MAS) and Modivcare, the two principal Transportation Managers in the State, have said that starting April 3, 2023, all Transportation Providers must ensure full compliance with the NYSDOH GPS mandate.  

This mandate is a significant step in the NEMT ecosystem, where transportation managers play a crucial role in reimbursing Medicaid transport claims. This mandate comes from the very top.   

The GPS compliance requirement is part of a broader effort by NYSDOH to improve the quality of healthcare services, ensuring patient safety and efficiency, along with better compliance. 

NYSDOH GPS Mandate: What It Means for TPs

The mandate requires TPs or NEMT providers to submit the starting point, endpoint, and all GPS coordinates along the trip, known as “breadcrumb data,” to the Transportation Manager.  

The detailed reporting mandate means that digitization of NEMT operations is now essential for TPs providing Medicaid NEMT. Fleet owners must take the initiative to implement this in their process, a task that can be challenging without the use of modern NEMT software.  

Reporting of GPS Milestones 

The NYSDOH mandate requires reporting GPS milestones for all trips. These milestones mark each journey’s start and end points and are pivotal in enhancing program integrity. They enable tracking the service delivery for Medicaid NEMT in a standardized and verifiable way, weeding out dishonest elements and improving the industry.   

Reporting of Breadcrumb Data 

In addition to GPS milestones, the mandate requires TPs to submit breadcrumb data and their claim to the transportation managers. Breadcrumb data refers to the documenting and retaining GPS coordinates recorded at various points along the trip in a standardized GPS reporting format.   

These granular data points provide a comprehensive picture of the trip, further strengthening the program’s integrity. It ensures that every route taken is documented and verifiable, which is a significant step towards what the NYSDOH aims to achieve with the GPS mandate – that NEMT services are delivered efficiently and ethically, improving the NEMT ecosystem using technology. 

Did this Come from the NYSDOH?  

The communication came from MAS and Modivcare. As key transportation managers in New York State, they play a significant role in the NEMT process. They act as Third-Party Intermediaries (TPIs). TPIs are responsible for receiving and processing the GPS data from TPs.  

As transportation managers, they oversee the coordination and delivery of NEMT services for the state; therefore, communication from them is essentially communication directly from the NYSDOH. So, their call for implementing this mandate is trustworthy. 

NEMT Software as GPS Providers  

NEMT software uses GPS technology and API integration to connect two separate software systems seamlessly via codes, definitions, and protocols. These software systems are the TP’s GPS system and the transportation manager’s software for recording and submitting Medicaid transport claims.  

This need is what NEMT software like Tobi fulfills, providing in-vehicle navigation and real-time GPS tracking. 

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Tobi Cloud: Implementation and Compliance 

To ensure GPS compliance, MAS and Modivcare NEMT transportation providers can take specific steps. These include ensuring all drivers have GPS capability and dispatchers properly route and record each trip’s GPS data.  

With its companion driver app, Tobi Cloud is one of the tools for GPS compliance. Integration with the Kinetik Care Billing platform ensures that Tobi enables an easy Medicaid claims process and compliance with the GPS mandate.   

Plus, with a dedicated onboarding team and 24×7 customer support, we help NEMT TPs implement Tobi into their process. Our software experts have a turnaround time for any technical issues of under 24 hours. So, implementing Tobi into your existing work process is easy. 

Potential Challenges 

While implementing this mandate, TPs might face issues such as connectivity problems with the GPS or drivers forgetting to indicate their arrival at the pickup or drop-off location. However, technological advancements have overcome these obstacles. The software tracking the GPS information can submit it during or after the trip in case of barriers outside the TP’s control. 

Some Common Questions 

Several questions might arise regarding the GPS mandate. This document may address many of these questions. We have explained the most common question here for convenience.  

How will TPs know if the GPS information they or their designated TPI/ATMS provide is acceptable? 

The GPS information’s correctness is crucial for issuing prior authorization for the trip in question. If the GPS information is incorrectly formatted, it could prevent this authorization. The transportation managers’ outreach teams proactively contact TPs to confirm the correct formatting and are prepared to work with the TPs and TPIs/ATMS to facilitate corrected formatting when necessary. 

What happens if there is a connectivity problem with the GPS or the driver forgets to indicate their arrival at the pickup or drop-off location? 

While these issues might occur, technology helps largely overcome such obstacles. In the rare instances where connectivity issues prevent the submission of GPS information associated with Medicaid transport, you can submit the information during or after the trip. Tobi can work seamlessly within these compliance standards.    

What will be considered a match between GPS data and the assigned Trip Invoice? 

The NYSDOH will determine the GPS match limits regarding the distance from the pickup location, drop-off location, and miles traveled.   

To ensure that bad actors cannot abuse the new system, NYSDOH isn’t revealing these standards. 

What happens if the GPS data does not match the pickup, drop-off, or miles indicated on the trip invoice? 

If the GPS information submitted at attestation does not match the pickup, drop-off, and mileage indicated on the trip invoice, it will prevent the attestation from generating a prior authorization. It is the responsibility of the Transportation Provider to ensure that every event along the trip is recorded in real-time, either manually or using technology such as geofencing. 


The GPS compliance requirement is a significant step towards improving the quality of healthcare services in New York State. All NEMT providers must ensure they are fully compliant with this mandate.  

Tobi Cloud can help you comply with this new requirement. Our in-vehicle navigation and real-time GPS tracking make it easy for you to meet the GPS mandate. Our integration with the Kinetik Care Billing platform simplifies the Medicaid claims process and ensures compliance.  

Sign up for Tobi’s free trial to see how it works for yourself or contact our experts for more information and specific questions. With Tobi, you’re in good hands to navigate the future of NEMT