Audit letter arrives. It asks you to provide, for examples of trips you billed eighteen months ago, proof that each trip actually occurred: who drove, with what vehicle, from where to where, for which appointment, with what documentation. For most NEMT operators, that letter is where they discovered which things their system had never caught. The journey is real. The evidence is not built to stand up to review.
I run engineering at Mindbowser, and the fraud and integrity side of NEMT is one of the clearest cases I know of where proper software design at the time of travel is worth more than the amount of cleanup afterward. The government has done something unusual here: through the GAO, the HHS Office of Inspector General, the Department of Justice, and state attorneys general, the government has documented exactly how NEMT fraud occurs, scheme by scheme. And every schema described is a software control waiting to be built. This is that mapping.
What federal records actually show
Start with the scale, because that determines the stakes. In a September 2022 report on NEMT fraud, the Government Accountability Office found that from fiscal years 2015 to 2020, state investigations resulted in 132 criminal charges and 57 civil settlements or judgments involving NEMT providers, in 25 states. The number was 189 results, which GAO rounded to nearly 200. The cases were concentrated in a few states, New York with 56 cases, Ohio with 36 cases, Indiana with 18 cases, although GAO was careful to note that the distribution reflects where investigations were conducted, not where the most egregious fraud occurred.
Inspector General audits tell the same story in dollar terms. A review of New York City’s NEMT claims examined $269.6 million in payments and recommended the state refund $84.3 million, and another $112 million flagged as potentially non-compliant. Of the 100 sample claims, 17 claims were fully compliant, 41 claims were not fully compliant, and 42 claims could not be determined. An audit in Massachusetts found at least $14.1 million in improper payments, with 86 of 100 sample service lines noncompliant, and of those 100 service lines, driver qualifications and vehicle documentation were inadequately documented.
Now it’s the number that reframes everything. In CMS’ fiscal year 2025 measurements, the improper Medicaid payment rate was 6.12%, about $37.39 billion. However, CMS explicitly states that inappropriate payments are not a measure of fraud, and that 77% of the incorrect amounts represent inadequate documentation, which generally does not indicate fraud or abuse. Read carefully, as these are the most useful facts on this page. The biggest category of loss is not stolen money. This is money paid for real travel that cannot be properly documented. And documentation is something that is controlled directly by the software.
So the goal is not a fraud detection product baked into the billing system. This builds, in the course of itself, evidence that each of the six schemes below is unsustainable. Let me take them one by one.
Scheme 1: Ghost trip, stopped by GPS trip evidence
The oldest scheme is billing for trips that never happen. GAO documented billing providers for trips to closed facilities, or for appointments that did not exist, or for members who were not in close proximity to a vehicle. The claim looks clean on paper because the paper doesn’t know where the van is.
The controls are GPS trip proof. When trips are captured as GPS breadcrumbs, starting point, route, and destination, with system-generated, immutable timestamps for each stage, ghost trips are no longer billable. Geofencing pick-up and drop-off confirms that the vehicle is actually at the member’s location and at the destination. Claims cannot be made without travel data to support them. It’s the same GPS and route data that the operator has collected for delivery is converted into proof of claim rather than a discarded by-product.
Scheme 2: Riders who have no appointments and are ineligible are terminated with claims-to-appointments matching
A more subtle version bills for real travel expenses that should not be covered: travel for members who are hospitalized or die on the date of service, or travel without an actual medical appointment at the other end. The vehicle is moving. The trip is not a covered benefit.
The controls are compatible, in both directions. Real-time eligibility verification at the time of booking, via standard transactions 270 and 271, catches members who are not covered on the service date before the trip departs. And claims-to-appointment matching ties each billed trip to a confirmed appointment, so trips to any destination are unrelated. Both checks are included at the time of ordering and making a claim, not at post-payment review. Getting it into the billing flow is the difference between knowing about the problem before the trip and refunding it after an audit, which is the same discipline executed through NEMT’s custom-built billing software.
Scheme 3: Inflated mileage and fake tolls, stopped based on system-calculated distance
The GAO and state cases illustrate a series of overbilling tricks: inflating mileage, adding tolls that are never paid, and dividing a single trip into multiple billable segments. Each relies on humans entering numbers that are not checked by the system.
The control is to take the number from the human hand. When mileage is calculated by the system from the actual GPS route and not entered by the driver or biller, inflation no longer occurs. Toll roads are aligned with the route. A one-time trip cannot be split into three because the trip data represents one continuous trip. The pattern throughout is the same: wherever a billable value is typed in by a person, that is the place to substitute the system-calculated value obtained from the travel log.
PakarPBN
A Private Blog Network (PBN) is a collection of websites that are controlled by a single individual or organization and used primarily to build backlinks to a “money site” in order to influence its ranking in search engines such as Google. The core idea behind a PBN is based on the importance of backlinks in Google’s ranking algorithm. Since Google views backlinks as signals of authority and trust, some website owners attempt to artificially create these signals through a controlled network of sites.
In a typical PBN setup, the owner acquires expired or aged domains that already have existing authority, backlinks, and history. These domains are rebuilt with new content and hosted separately, often using different IP addresses, hosting providers, themes, and ownership details to make them appear unrelated. Within the content published on these sites, links are strategically placed that point to the main website the owner wants to rank higher. By doing this, the owner attempts to pass link equity (also known as “link juice”) from the PBN sites to the target website.
The purpose of a PBN is to give the impression that the target website is naturally earning links from multiple independent sources. If done effectively, this can temporarily improve keyword rankings, increase organic visibility, and drive more traffic from search results.
