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13 in-house. Georgia has five regions; however, these regions Some states have very specific and more far-reaching stan- are combined so that there are two brokers covering the dards (e.g., Georgia includes standards for the broker) and the entire state. Florida, Maryland, Massachusetts, Oregon, and requirements are set forth in state regulations (Kentucky). In Vermont all use community-based brokers. the remaining states, the standards are locally determined. These results indicate that although there are standards in The use of brokerages for the provision of NEMT can place for NEMT providers, they are often not as inclusive work in favor of the coordination of services or, depending and standardized as those that are in place for public transit on the brokerage model, can also be an obstacle to coordina- providers. For example, in Portland, Oregon, the broker, Tri- tion. For example, if a NEMT brokerage only handles County Metropolitan Transportation (TriMet), determines NEMT, then the coordination of transportation services is the standards, which are higher than the state-mandated not as likely, as only one trip purpose is served by the bro- requirements. ker. In these cases, the public transit operators may or may not participate as a provider within the brokerage. It was States use a variety of mechanisms to monitor the qual- determined that in Georgia and Virginia a significant major- ity of service and guard against fraud. These mechanisms ity of service providers are entities other than public transit include electronic and paper reporting, field monitoring, operators. For example, in Georgia the number of participat- customer surveys, inspection of driver and vehicle records, ing transit operators includes 13 of the 126 transit agencies various types of audits, and complaint information. Unlike (36 small and large urban and 90 rural providers). Eight of school bus requirements, which are highly regulated, there these coordinated agencies are in urban areas and include the is little in the way of a formalized process in some states. use of fixed-route services (in such cases, the broker has a There are also indications that, in at least one state surveyed, financial interest in coordinating with fixed-route), whereas, there was very little monitoring of service. Some states sur- as of September 2005, 5 of the 90 rural transit operators were veyed have not tracked on-time performance and some did participating in the Medicaid program. In Virginia, in 2002, not routinely collect safety and accident data. Table 3 pro- the brokerage utilized very few transit agencies with the vides the survey results with regard to service standards and exception of fixed-route transit in urban areas (information monitoring of service. provided by the Virginia Department of Medical Assistance Services). However, in states where the brokers serve multi- ple funding agencies and/or is the transit agency (e.g., Florida, BARRIERS AND CHALLENGES Oregon, and Vermont), the brokerage system can foster the coordination of transportation services. The major focus of this synthesis is to report on real and per- ceived barriers and challenges to the coordination of NEMT Table 2 shows the survey respondents' various methods and public transportation. Barriers or challenges stop the of providing NEMT, describes how services are delivered, efforts of some, while impeding progress for others. With and indicates what entities are responsible for eligibility, this focus in mind, respondents were provided with various screening, and verification. categories of challenges to choose from. The results indi- cated a number of real and perceived challenges across many categories. Some challenges could be included in several cat- Standards and Monitoring of Service egories; however, for the purposes of analysis they were assigned to just one. Table 4 presents these challenges, which NEMT is a federal/state program that has a set of basic federal are highlighted and discussed here. guidelines. The standards that guide the NEMT service--from standards for paperwork to standards for vehicles and operation of the service--are determined at the state and/or local level. Regulatory, Legal, and Compliance Issues These standards in large part determine the cost of the service. One of the key issues for coordination is that of often dissimi- Regulatory, legal, and compliance issues relate to a variety of lar service and operating standards. The subject of standards requirements. Regulatory and legal barriers included the was disclosed in a number of surveys and in anecdotal evidence Managed Care/Freedom of Choice waiver requirements, offered by a Medicaid provider in New York State. Because whereas compliance included issues related to service moni- one of the perceived barriers to coordinating was that there are toring and standards. This category of challenges generated different (typically lower) standards for service for NEMT many responses, from both the transit and Medicaid perspec- providers as compared with public transit providers, the survey tives. One theme that emerged from the urban transit asked the Medicaid state program managers to indicate if they providers and Medicaid representative's responses is that had standards and, if so, to describe them. The results indicated there are different levels of service that are required for trips that in about half of the responding states there are state- provided under the ADA; for example, as compared with mandated standards in place with regard to driver training, those required for NEMT. Furthermore, these levels of ser- driver qualification, vehicles, and, in some cases, insurance vice are different in different areas, because some transit levels. These standards typically follow state motor vehicle agencies go above and beyond what is required by the ADA laws and relate to the type of vehicle being driven. and others do not. Trying to fit the two services in one system

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TABLE 2 GENERAL STATE NEMT CHARACTERISTICS State and FFP Method and Description of How Services Waiver Method of Providing NEMT Decision Makers Are Delivered Eligibility and Screening California Private transportation providers enroll State level staff and upper management Medi-Cal recipients contact the provider Authorization is approved if the Medi- as Medi-Cal providers and determine Legislature directly. The provider requests prior Cal recipient has a functional limitation their own service area. authorization. Medi-Cal pays for w/c that precludes their use of public or vans, guerney vans, and nonemergency private transportation. Medical ambulance service under NEMT. Colorado Several approaches are used, including State level upper management and local There is a broker for the metro area Broker or local department of social local and regional brokerages, locally level staff counties and individual county services checks with a statewide arranged contracts with private administration through local verification system that is available transportation providers, and public departments of social services for the through the fiscal agent. Medical fixed-route transit. remaining counties. Florida Agency for Health Care Administration State and local level staff There are local community Local county coordinators or their (AHCA) contracts with the Commission transportation coordinators/brokers that contractors handle eligibility and 1915(b) for the Transportation Disadvantaged arrange or directly provide NEMT for screening. for the statewide coordination of clients in their service areas. Medical NEMT. AHCA pays the Commission a fixed amount each month for services. Kentucky Statewide brokerage. NEMT program is State level staff and upper management Medicaid recipients contact regional Regional brokers have access to operated under a 1915(b) waiver, Legislature broker, and then the broker either eligibility information via Internet allowing the state to restrict freedom of approves or requests denial of the trip. If connection. If the broker has a question 1915(b) choice. approved, the broker schedules the trip about eligibility, it contacts the Office with a provider that has contracted with of Transportation Delivery, which then Medical the broker to provide transportation. verifies the eligibility. Maryland Local brokerages, locally arranged State and local level staff Marylands 24 j urisdictions are provided Either the local health department or the contracts with public and private funds to arrange for NEMT. In 23 vendor screens for eligibility. The state transportation providers, public fixed- jurisdictions these funds go to the local mandates specific screening questions route transit, gasoline vouchers, and health departments. In one county the that must be asked. agency vehicles and staff. funds go directly to the public transit Administrative agency, which is a county DOT. Michigan Local brokerages, locally arranged State level staff and local level staff The Michigan Medicaid Program has an Local MDHS offices are responsible for contracts with private and public intradepartmental agreement with the eligibility and verification. transportation providers, and public Michigan Department of Human fixed-route transit. Services (MDHS) to administer the provision of NEMT for the fee-for- service beneficiaries. The qualified health plans are responsible for NEMT for their enrollees. MDHS coordinates NEMT through its local offices and bills Administrative Medicaid for the transportation expenses on a monthly basis. (continued)

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TABLE 2 (continued) GENERAL STATE NEMT CHARACTERISTICS State and FFP Method and Description of How Services Waiver Method of Providing NEMT Decision Makers Are Delivered Eligibility and Screening Missouri Statewide brokerage and state State level upper management Missouri ensures NEMT through a Broker verifies eligibility on the date of cooperative agreements with public statewide brokerage. There is one transport through one of three transit and other agencies and schools. statewide broker that provides mechanisms: (1) state agency's Administrative transportation arrangements and interactive voice response system, (2) (is changing to ancillary services for eligible recipients. agency's fiscal agent via the Internet, or medical) There are also state cooperative (3) point of service terminals that agreements with public transit and other provide a paper printout of eligibility agencies and schools to draw federal information on a specific date of NEMT funds on current funding sources. service. North Carolina NEMT is arranged locally through each State and local level staff Local DSS coordinators use the least The local DSS offices are responsible county's Department of Social expensive modes that meet the needs of for eligibility and verification. Services (DSS). Each DSS has a the clients. They are strongly coordinator who is in charge of the encouraged to use the local public transit Medical local NEMT transportation program. agencies. State has an Executive Order in place to encourage coordination. Oregon There are nine transit systems serving as State and local staff Designated regional broker determines The regional brokers and their medical transportation brokerages. the best approach for NEMT using the contractors determine eligibility. 1915(b) least expensive appropriate mode. Medical Texas State contracts with private State level staff and upper management TxDOT manages nine call centers with HHSC shares (electronically) Medicaid transportation providers and public Legislature state employees. TxDOT headquarters eligibility information with TxDOT. transit agencies. Recent legislation contracts with a wide variety of TxDOT's call centers conduct mandates that the Health and Human providers across the state, including eligibility and screening. Services Commission (HHSC) contract both public and private operators. All with TxDOT for the provision of trips are prior authorized through transportation services to clients of TxDOT Medical Transportation eligible health and human service Program intake workers. The program Medical programs, including Medicaid. was recently changed to allow for a pass-through entry between TxDOT and the operator. Vermont Regional brokers coordinate services Transit association Local brokers arrange the trips, which Eligibility and screening is conducted locally, with oversight from the are provided with a variety of modes. by the local brokers. Vermont Public Transportation There is an extensive network of Administrative Association. volunteers who participate with the local brokers. Washington Regional brokerage--through State level staff and upper management Brokers are responsible for delivering State provides eligibility information competitive procurements. transportation services in their regions. weekly; brokers also have medical eligibility verification as backup if the weekly information is inadequate. Administrative

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16 TABLE 3 SERVICE STANDARDS AND MONITORING State or Local Contractually Required How Are Services State Monitoring Service Standards Monitored? California Both state and local Driver training, driver experience, and vehicle Services are monitored through standards are set in accordance with established state electronic and paper reports, regulations pertaining to the type of vehicle and the field monitoring, customer transportation involved. surveys, and the inspection of driver and vehicle records. Colorado 90% state and 10% There are very specific standards in the provider Services are monitored through local contracts. There are standards for the type of driver electronic and paper reports, training required and the type of drivers hired (with customer surveys, and program regard to type of license, driving record, criminal integrity audits. record, etc.). There are also specific requirements with regard to vehicles and their accessibility, maintenance, upkeep, and cleanliness. Every vehicle must be insured for a minimum $500,000 combined single limit. Florida 100% state There are specific standards that are defined in the Services are monitored through contract between the Agency for Health Care electronic and paper reports, Administration (AHCA) and the Commission. Local field monitoring, and the coordinators often add to these minimums to make inspection of driver and vehicle them compatible with public transit. records. Local coordinators conduct their operational monitoring. Kentucky 50% state and 50% There are specific requirements in a number of areas Services are monitored through local (i.e., drivers, training, vehicles, broker electronic and paper reports, responsibilities, etc.). These requirements are set forth field monitoring, customer in Kentucky State Regulations--603 KAR 7:080: surveys, and the inspection of Human Service Transportation Delivery. driver and vehicle records. Maryland 30% state and 70% Contractually required service standards are locally Services are monitored through local determined. annual customer surveys, field monitoring, and the quarterly submission of complaint logs. Michigan Local Contractually required service standards are left to Services are monitored through the discretion of the local Michigan Department of electronic and paper reports. Human Services offices. Missouri State There are specific requirements with regard to driver Services are monitored through training, driver experience/driving record, vehicle electronic reports and customer maintenance and inspections, as well as first aid and surveys (quarterly). safety requirements. North Carolina Local There are required standards with regard to safety Services are locally monitored and risk management. Local transit systems set through different mechanisms higher standards. including examining the trips for a particular date and/or random sampling of trips. (continued)

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17 TABLE 3 (continued) SERVICE STANDARDS AND MONITORING State or Local Contractually Required How Are Services State Monitoring Service Standards Monitored? Texas All Requests for Proposals and contracts with An annual assessment of the individual providers are handled through TxDOT Medicaid Medical headquarters. A new process is pending. Previous Transportation Program is standards for drivers, vehicles, safety, and other scheduled to begin in FY2006. It requirements were well below standards for public is anticipated that the assessment transit. New requirements have stronger standards. will include the following elements: Review trip eligibility determination Surveys Review of safety Review of telephone service Fixed rate usage Quality review Driver and vehicle records. Washington Both state and local There are standards with regard to driver training, Services are monitored through driver experience, and vehicles. electronic and paper reports, field monitoring, customer surveys, and the inspection of vehicle records. has proven difficult. Broward County Transit (Florida) and three jurisdictional lines to transport passengers to a regional TriMet (Oregon) both operate ADA and Medicaid services in medical facility, often without coordinating with the agen- their regions; however, each is a separately managed and cies in the counties they cross. The North Carolina DOT has operated program within the organization. begun an initiative to identify and coordinate those services. Another barrier cited was that different laws and rules apply to public transit operators than to NEMT providers; Financial Issues specifically, drug testing, vehicle (ADA compliance), and The financial issues listed by the respondents appear to be real Commercial Drivers License requirements. These require- and significant challenges to the coordination of services ments typically result in higher costs for the transit agencies, between NEMT and public transportation. One major issue in making it difficult to compete against those operating under urban areas, which has been discussed for many years with- a less stringent set of policies and procedures. out resolution, is the question of which agency should pay for the trip of an ADA paratransit-eligible Medicaid client to One state found that the Centers for Medicare and Medic- travel for a medical need--the state Medicaid agency or the aid Services (CMS) process for requesting waivers is a major local transit agency. Following this same issue, should the barrier that requires a significant amount of administrative Medicaid agency pay the regular fare (which includes federal, work. One state did not actually use a waiver and eliminated state, and local subsidies, but not in urban areas where only the freedom of choice requirement. local money is used), the entire local share of the cost, or the fully allocated cost? One NEMT manager did not understand Jurisdictional Issues that large urban areas (more than 200,000 population) do not receive federal operating subsidies. Some state transit agen- There were two jurisdictional issues indicated that could be cies require that their transit grantees collect the fully allo- considered real challenges to the coordination of services. cated costs for human service agency trips (e.g., Virginia) The first is that, in some rural areas, the public transit provider rather than the general public fare, whereas one state attorney does not have enough vehicles to allow one to leave the ser- general ruled that Medicaid can only pay the regular general vice area for an entire day to provide a long distance medical public fare (Idaho). CMS has determined that it is appropriate trip. Another real barrier can be found in small cities where for NEMT to pay a rate higher than the general ADA fare. the service mode is fixed-route and the operator does not have the proper authority to travel outside the service area. Other financial concerns listed included the business deci- sion of whether the reimbursement rate is too low for Medic- In North Carolina, the many rural county transit agencies aid trips and would cause transit agencies to lose money by (typically coordinated with Medicaid) often cross two or subsidizing the trip. In cases where a third-party administrator

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18 TABLE 4 CHALLENGES Regulatory/Legal/ The level of service required for paratransit trips provided under the ADA is Compliance Issues higher than the level of service required for Medicaid trips, thus making it difficult to coordinate these trips together in a cost-effective manner. The transit system is subject to more stringent standards than those required by Medicaid with regard to vehicles, equipment, driver licensing, drug testing, and training, etc. These regulations result in higher costs than would be found among providers that exclusively carry Medicaid clients. Drug testing makes ADA service cost more than Medicaid service. Coordinating Medicaid transportation with general public service is a challenge because the state human service agency staff does not understand the complexity of transit regulations. For example, for vehicle fleet size the state DOT uses the FTA-funded services as the guide to peak need. Contracted services (including Medicaid) are not included, which leaves the impression that the state DOT has a negative view of Medicaid transportation. Some public transit agencies see the drug testing and commercial drivers license requirements as a means for establishing standards for quality mobility providers (not as a barrier). The 27 different transit agencies in the state have very different ADA structures and regulations. The regulatory/legal/compliance issues attached to transit funding sometimes prohibit coordination. The belief is that $1 of federal money in a coordination project compels compliance with all FTA regulations. Many of the local transit agencies and human service agencies believe that they cannot coordinate because of regulatory issues who can and cannot ride on the bus. The Centers for Medicare and Medicaid Services process for requesting waivers is a major barrier. It is a lot of administrative work to pull together all of the information that is necessary to request a waiver. Jurisdictional Issues The transit boundaries are much smaller than the Medicaid transportation brokerage region boundaries. Some rural transit agencies are unwilling to provide long distance NEMT to urban areas for specialized care. The state Medicaid agency requires prior approval to transport clients out of the county for services. Obtaining this approval is an administrative burden. There are different standards for vehicle and driver licensing and permits in the different counties. There are jurisdictional issues for small urban transit providers who operate in towns where there are not major medical facilities--the small fixed-route providers are not always able to travel out of their service area. Financial Issues The state's billing and reimbursement mechanism requires expensive software customization, contractual services for electronic eligibility verifications, full- time monitoring, and the payment for services is not always processed in a timely manner. The state Attorney General ruled that Medicaid can only pay the regular fare for the purchase of transit service (instead of the cost). The Medicaid system is cumbersome and efforts to reduce costs result in no or inadequate payment to providers. The brokers and third-party administrators of the NEMT program, especially in the capitated rate scheme, have included penalty provisions in their contracts with mobility providers (transit providers) to shift some of the financial risk to the providers. These penalty provisions include minor irregularities such as late reporting or incomplete reporting as determined by the broker. Several mobility providers have made a business decision not to participate in NEMT as a result of those disadvantageous contract provisions. The reimbursement for brokers and providers. Low reimbursement rates limit the number of available NEMT providers. The transit system is required to carry a higher level of insurance than is required for Medicaid trips, thus increasing the cost of the ADA service. Fleet needs and the sources to fund them. Dual eligibility--Medicaid and ADA paratransit. When an ADA customer requests a medical ride, Medicaid should pay for the trip instead of the transit agency. (continued)

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TABLE 4 (continued) CHALLENGES Information/ The Medicaid agency has electronic billing requirements that can be difficult Technology Barriers for transit agencies to meet without significant software expenses. Combining ADA and Medicaid would tax the ability of the paratransit scheduling program that is currently in place. The different record keeping requirements add to the overhead cost of providing mobility services. This is especially the case when coordinating many human service transportation programs, just one of which is NEMT. Health Insurance Portability and Accountability Act is a potential barrier. Many agencies do not want to share client information. Technology varies between private and public programs. Different Goals Transit is interested in meeting ADA requirements, which are narrower in scope than Medicaid requirements. From the transit agency perspective it is more effective to issue Medicaid clients a monthly bus pass. The cost of the monthly pass is less than the cost of one door-to-door round trip, resulting in savings for the program and an increase in the quality of life for the client. Some state Medicaid staff believed that only single-trip passes should be issued for Medicaid-funded appointments, but the administrative costs and staffing required to administer these trips would have a negative financial impact on the program. Medicaid agencies are interested in transporting their clients and not overall public transportation. Eligibility The eligibility process is difficult and time consuming. The transit agency does not always have the needed information to determine a client's eligibility status. Ensuring the eligibility is in place before providing the trip is a major challenge. Penalizing the transit provider for performing a noneligible trip when that trip was ordered by the NEMT broker is unfair. Eligibility ought to be the sole responsibility of the broker and once the trip is assigned by the broker to the transit provider; no inquiry into the eligibility of the client by the transit provider should be needed. The state recently increased the client eligibility requirements for NEMT, which has increased the number of people seeking medically related rides under other programs, such as general public transit. This cost shifting has led to transit vehicle capacity problems, especially for rural transit providers. Medicaid limits eligibility to those with no other means of transportation. Mixing of funding streams--one bus may carry five different types of clients with different funding sources. The different funding sources have different service requirements and eligibility. Dual eligibility between ADA and Medicaid--who should pay for the trip? Operational Barriers The provision of NEMT service can cause significant disruption to all facets of an established paratransit system owing to the following: the eligibility process, the billing system, the customer service staffing, the no-shows and cancellations, and the database maintenance. Medicaid clients share rides with ADA clients, which prompts them to request paratransit trips for which they are not eligible. A high level of monitoring is necessary to deal with this issue. Educating transit systems on how to schedule and dispatch fully coordinated services is challenging. Some clients need a higher level of personal care than the (public transit) staff is prepared to provide. Some agencies expect the transit provider to be the liaison for the client with the medical provider. NEMT has a 30-min pick-up and will-call return pickup requirement that require most transit providers to have their drivers wait with the client rather than use the driver's time more productively by delivering trips for other programs or even other NEMT trips to different destinations. Medically fragile people have different service needs than able-bodied people. With a central dispatch center and shared vehicles there are issues with regard to which agency should pay for maintenance, which agency should provide the local match, etc. The hours of operation are different, the frequency of service is different, and all public transit vehicles must be ADA-compliant. Transit agencies have higher standards with regard to driver training. (continued)

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20 TABLE 4 (continued) CHALLENGES Other Barriers Transit agencies are typically not just coordinating NEMT, but also senior transportation programs, mobility programs for persons with developmental disabilities, Head Start transportation, and many others. Each of these programs has their own, and sometimes conflicting rules, requirements, and limitations. There are information barriers to the extent that clients as well as sponsoring agencies are not aware of all the existing mobility services that are available to them. Identification of entities. Medicaid agencies' documentation requirements versus public transit's personnel and time constraints. exists, there are penalty provisions for minor irregularities and that do not have the staff to manage this effort. This prob- difficulties with invoices that make participation by public lem can have financial implications if the trip is provided, transit agencies difficult. but then is not reimbursed. Another concern for transit agencies, particularly those in rural areas, is that the same Another financial concern, which is also a technology vehicle may have clients from six different agencies on issue, is that some states' billing and reimbursement mech- board, each of which has a different set of eligibility crite- anisms require expensive software customization, contrac- ria. In one state it was noted that the Medicaid eligibility tual services for electronic eligibility verifications, and verification requirements were increased, resulting in addi- full-time monitoring. Also, the payment for services is not tional costs for public transit. always processed in a timely manner. This makes partici- pation in NEMT difficult for smaller rural public transit agencies. Operational Barriers One transit agency reported that the provision of NEMT can Intake Responsibility cause significant disruption to all facets of an established ADA paratransit agency for a number of reasons, including The responsibility for trip intake is expensive and time con- the intake process, the billing system, the customer service suming in both urban and rural areas. The functions of trip staffing, the no-shows and cancellations, and the database intake are complicated and require the following multistep maintenance. process: It was also reported in one state that NEMT has a 30-min Verification of Medicaid eligibility, will-call/return pick-up requirement that requires that transit Assessment of need (in some states, the intake is required providers have their drivers wait with the client, rather than to determine if the individual requesting service has a car using the driver's time more productively by undertaking trips or can get a ride elsewhere), for other programs or by taking other NEMT trips to different Verification of trip purpose (is the individual requesting destinations. In addition, some Medicaid clients require a service going to an eligible service?), and higher level of care than what the public transit agency staff Determination of what mode of services the individual is able or willing to provide. is eligible for; fixed-route, paratransit, volunteer, etc. Often, the responsibility for trip intake rests with the bro- Information and Technology Barriers ker or directly with the service provider. In some states, the transportation vendor (sometimes this is the public trans- The requirements for the use of technology in billing and oper- portation operator) performs these functions, whereas in other ational areas make participation by smaller agencies difficult. states, the broker or local health or Department of Social Ser- These agencies have difficulty investing in the technology and vices handles eligibility, screening, and verification (in Texas often cannot afford the staff necessary to maintain it. One sig- it resides with TxDOT). Regardless of where this function nificant barrier that could be classified under "information occurs, this information is typically available electronically, technology" is that there are significantly different record although not always in a timely manner (as noted in the keeping requirements for NEMT when compared with public barriers section). transit. This is particularly true in urban areas, where the only information collected from a general public passenger is the Transit agencies reported that the intake process is diffi- fare that was paid. This is less of a barrier in rural areas oper- cult and time consuming and that the agency does not ating demand-response service, because the public transit always have the required information before the trip. This agencies are already collecting information needed to provide could pose difficulties for those smaller transit agencies the trip.

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21 Other Challenges keep the medical information necessary to provide the trip as confidential. One survey respondent indicated that the Health One major barrier is that Medicaid agencies have the single Insurance Portability and Accountability Act of 1996 goal of ensuring that beneficiaries can access their medically (HIPAA) is a potential barrier. However, this is a misunder- necessary appointments for the lowest cost that meets the standing, because transit agencies do not come under this clients' needs. In urbanized areas, this goal can often be requirement, although at least one agency reported problems achieved in a cost-effective manner by issuing bus passes to in this area. Medicaid-eligible clients. However, in some states this does not occur because the Medicaid focus is single-trip oriented. Medicaid agencies do not always realize that the administra- Finally, many rural transit agencies are typically coordi- tive costs associated with issuing single-trip passes are equal nating not just NEMT, but also senior transportation pro- to or greater than the cost of a multiride pass. grams, mobility programs for persons with developmental disabilities, job access, and other programs. Each of these Confidentially of records is also a potential barrier, programs has their own, and sometimes conflicting rules, because public transit agencies may not be equipped to requirements, and limitations.