PWW|AG is closely monitoring a newly released proposed rule from the Centers for Medicare & Medicaid Services (CMS) that could significantly reshape the future of Ground Emergency Medical Transportation (GEMT) supplemental reimbursement programs nationwide.
On May 20, 2026, the Centers for Medicare and Medicaid Services released a proposed rule that could have major long-term implications for Ground Emergency Medical Transportation (GEMT) reimbursement programs nationwide. (See the full release from CMS)
For the first time, CMS is proposing a formal provider-specific payment limit on certain targeted Medicaid supplemental payments made to transportation providers, specifically identifying GEMT providers, air ambulance providers, and NEMT providers within the rule language. While the proposed payment limits would not take effect until rating periods beginning on or after January 1, 2029, the long-term implications for EMS reimbursement strategy, supplemental payment sustainability, state plan amendment structures, and future Medicaid financing models could be substantial.
Under the proposal, targeted Medicaid supplemental payments for GEMT providers would be limited to the equivalent Medicare Ambulance Fee Schedule (AFS) payment rates for comparable services.
CMS specifically states that Medicaid supplemental payments tied to GEMT arrangements could not exceed the applicable Medicare AFS payment amounts, including the associated base rates, mileage, geographic adjustments, and rural/super-rural add-on calculations.
For example, if the ambulance fee schedule amount is $450 for an ALS emergency in your area, that could be the maximum amount you would receive under your GEMT program (inclusive of what you’ve already received from Medicaid).
This proposal represents a potentially significant policy shift because many current GEMT supplemental payment methodologies nationally are based on cost reconciliation models or Average Commercial Rate (ACR)-style calculations that can exceed traditional Medicare ambulance reimbursement levels.
CMS specifically noted concerns that some targeted supplemental payment arrangements are financed through intergovernmental transfers (IGTs) and “provider-funded mechanisms” (Provider Tax) that, in CMS’ view, may reward providers based more on their ability to finance the non-federal share than on improving Medicaid access or quality outcomes.
CMS also specifically identifies GEMT supplemental payments among the targeted practitioner / provider payment arrangements it believes require additional fiscal oversight and Medicare-based payment limits moving forward.
If finalized as written, this rule could substantially alter future GEMT financing structures, supplemental payment ceilings, SPA methodologies, and the long-term sustainability of Medicaid supplemental reimbursement programs for ambulance agencies across the country. (View a highlighted version of the proposed rule)
PWW Advisory Group is actively reviewing the proposed rule and will continue providing updates and strategic analysis to the EMS industry as additional guidance emerges.
