Project Background
The Federal government has long recognized and promoted the benefits of coordinating human services transportation. The Coordinating Council on Access and Mobility (CCAM), an interagency group comprised of senior leadership from multiple Federal departments and agencies, has been formed to coordinate Federal efforts. The CCAM defines “human service transportation” as any means used to meet the basic, day-to-day mobility needs of transportation-disadvantaged populations, especially individuals with low-incomes, people with disabilities, and older Americans.1
The General Accountability Office hasidentified 80 federal programs that fund a variety of transportation services for transportation-disadvantaged populations.2 While many different federal programs support transportation, Medicaid has become, after the U.S. Department of Transportation, the largest funding source of medical and health-related transit services.3
Established in 1965, Medicaid is an entitlement program administered by the Centers for Medicare and Medicaid (CMS) and is jointly funded by individual states and the Federal government. Medicaid benefits are guaranteed by law to pregnant women, children, disabled people, and the elderly based on income qualifications. States have the option of extending coverage to other additional populations, based on criteria established in a state Medicaid plan. It is estimated that 71.4 million persons were enrolled in Medicaid and a related children’s health program.4
Efforts to coordinate transportation for the transportation disadvantaged, including non-emergency medical transportation (NEMT), began during the 1970s, primarily through state and local initiatives. These entities recognized that a myriad of Federally-sponsored programs either directly funded client transportation as a direct service or as a supplemental service necessary to ensure access to the primary program services. Federal interest regarding the coordination — or lack thereof — was first documented by the U.S. Senate Committee on Public Works. In public hearings held in 1975, concerns were raised about the lack of coordination of Federally-funded programs supporting transportation in rural areas. This hearing led directly to a landmark General Accounting Office (later renamed as the Government Accountability Office (GAO)) report issued in 1977 that identified a number of hindrances to transportation coordination efforts, including “accountability, paperwork, and bookkeeping problems.”5
In October 1986, the U.S. Department of Transportation (USDOT) and the U.S. Department of Health and Human Services (USDHHS) executed the “Agreement on the Coordination of Transportation Services,” declaring:
…it is the policy of the Department of Health and Human Services and the Department of Transportation to coordinate related programs at the Federal level wherever possible and to promote maximum feasible coordination at the State and local level.6
Since 1986, responsibility for coordination has rested with the Coordinating Council on Access and Mobility (CCAM), which was created under a memorandum of understanding between the USDOT and USDHHS. In 2004, Executive Order 13330 renamed the council the Federal Interagency Transportation Coordinating Council on Access and Mobility.
GAO continued its investigations and studies regarding the coordination of transportation, periodically focusing on specific recommendations. In one 2003 study, GAO recommended executive action on the part of the Federal government to:
Develop and distribute additional guidance to states and other grantees that encourages coordinated transportation by clearly defining the allowable uses of funds, explaining how to develop cost-sharing arrangements for transporting common clientele, and clarifying whether funds can be used to serve individuals other than the program’s target population.7
In 2005, CCAM, responding to one element of Executive Order 13330, issued its report to the President.
Five key recommendations were put forth, including one that directly addressed cost allocation methods:
In order to ensure that adequate resources are available for transportation services for persons with disabilities, older adults and individuals with lower incomes, and to encourage the shared use of vehicles and existing public transportation services, the CCAM recommends where statutorily permitted that standard cost allocation principles for transportation be developed and endorsed by Federal human service and transportation agencies.8
In the passage of the Fixing America’s Surface Transportation (FAST) Act (Pub. L. No. 114-94) in 2015, Congress stipulated that the USDOT and CCAM develop a cost allocation technology to account for disparate Federal reporting requirements and maintain separation of funding sources by trip for NEMT, the term given to transportation provided to eligible clients who need access to
medical services.9
The USDOT notes the challenges to this seemingly simple task; these challenges include harmonizing different systems that utilize different levels of financial accounting, for example:
- Human service agency funding typically flows funds by the eligible individual, and
- Public transportation funding flows to the local transit system.
- This fundamental funding difference has hindered transportation coordination efforts for decades.
SBIR Program Objectives
This project is being sponsored by the USDOT’s Small Business Innovation Research (SBIR) program. The purpose of this program is to invite small businesses, with their valuable resources and creative capabilities, to submit innovative research ideas and solutions in response to the topics identified by the USDOT.
The SBIR Program encourages small businesses to engage in research or research and development (R/R&D) that has the potential for commercialization and meets Federal R/R&D objectives.
- Stimulate technological innovation;
- Meet Federal research and development needs;
- Foster and encourage participation in innovation and entrepreneurship by socially and economically disadvantaged persons; and
- Increase private sector commercialization of innovations derived from Federal research and development funding.
Project Objectives
This project seeks innovative solutions for a cost allocation method/technology that accounts for divergent Federal requirements and funding sources by trip. The development of an allocated cost model for NEMT can result in improved coordination across multiple Federal Agency programs that provide funding to access human services transportation.
This approach also responds to a Government Accountability Office audit recommendation to “finalize and issue a cost-sharing policy and clearly identify how it can be applied to programs under the purview of member agencies of the Coordinating Council that provide funding for NEMT.”10
1 U.S. Department of Transportation and U.S. Department of Health and Human Services, Final Report on the DOT/DHS Coordination Roundtable, U.S. Department of Transportation, Technology Sharing Program, August 1992, p 10.
2 General Accountability Office, Transportation Disadvantaged Populations: Federal Coordination Efforts Could Be Further Strengthened, GAO-12-647, Washington, D.C., Feb. 28, 2012, p 6.
3 Burkhardt, J.E., Richard Garrity, Kathy McGehee, Susanna S. Hamm, Karen Burkhardt, Cindy Johnson, and David Koffman, Transit Cooperative Research Program Report 144: Sharing the Costs of Human Services Transportation Volume 2: Research Report, Transportation Research Board of the National Academies, Washington, D.C., 2011, p. 22.
4 Centers for Medicare and Medicaid, September 2019 Medicaid & CHIP Enrollment Data Highlights, Washington, D.C., December 2019, p. 1.
5 U.S. General Accounting Office, Hinderances to Coordinating Transportation of People Participating in Federally Funded Grant Programs, Volume 1, GAO/RCED-77-119, Washington, DC, October 17, 1977, p. 53.
6 U.S. Department of Transportation and U.S. Department of Health and Human Services, Final Report on the DOT/DHS Coordination Roundtable, U.S. Department of Transportation, Technology Sharing Program, August 1992. p. 1.
7 U.S General Accounting Office, Transportation Disadvantaged Populations: Some Coordination Efforts Among Programs Providing Transportation Services, but Obstacles Persist, GAO-030697, Washington, DC, June 2003. p. 37.
8 Coordinating Council on Access and Mobility, Report to the President: Human Services Transportation Coordination – Executive Order 13330, 2005, p. 33.
9 H.R. 22, 114th Congress, Fixing America’s Surface Transportation (FAST) Act, Section 3006(c)(2)-(3) and Small Business Innovation Research (SBIR) Program Phase I Program Solicitation, 6913G619QSBIR1, p. 53.
10 General Accountability Office, Transportation Disadvantaged Populations: Nonemergency Medical Transportation Not Well Coordinated, and Additional Federal Leadership Needed, GAO-15-110, Washington, D.C., December 2014, p 32.