We have been hearing the same question from a lot of agencies lately: is our GEMT money going away? The short answer is not right now, and not all at once. But there is a proposed federal rule worth understanding, along with a Texas Medicaid rate update that takes effect this fall. Here is a plain-language look at both, and what your agency can do about them.
First, a quick refresher on GEMT
Ground Emergency Medical Transportation (GEMT) programs exist because Medicaid reimbursement for ambulance services falls well short of what it actually costs to deliver that care. Depending on the source, Medicaid can pay less than a third of the true cost of a transport.
GEMT was created under the Obama Administration to help close that gap. Through State Plan Amendments, states can draw down additional federal funds to reimburse eligible EMS providers for a portion of their documented, unreimbursed Medicaid costs. Historically these programs served public entities like fire departments and government-run EMS, though some states have expanded eligibility to private agencies. For many public agencies, these dollars are not extra. They help keep the doors open and the trucks staffed.
The proposed CMS rule, in brief
On May 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule (file code CMS-2449-P), which was published in the Federal Register on May 22. It was proposed to implement Medicaid reforms tied to the One Big Beautiful Bill Act.
Here is the part that has EMS leaders paying attention. For the first time, CMS is proposing provider-specific payment limits on certain targeted Medicaid supplemental payments, and it names GEMT, air ambulance, and non-emergency medical transportation (NEMT) providers directly. In practice, the proposal would cap those supplemental payments at the equivalent Medicare Ambulance Fee Schedule (AFS) rate for comparable services.
A simple example helps. If the Medicare AFS rate for an ALS emergency transport in your area is $450, that figure could become the maximum you receive through your GEMT program, including what you have already been paid by Medicaid. For agencies whose GEMT programs currently reimburse above the Medicare rate to reflect actual costs, that is a meaningful change.
The timeline is longer than the headlines suggest
This is not an overnight cut. Under the proposal, the payment limits would not take effect until rating periods beginning on or after January 1, 2029, and they would phase in over several years. Funding would not disappear immediately. It would gradually move toward Medicare AFS levels over time.
That runway matters. It gives agencies time to understand their exposure and plan, rather than react.
Not every program would be affected the same way
The proposed rule includes a potential exemption for state GEMT programs that use an actual cost approach to reimburse public fire and EMS agencies, while paying private providers on a standard fee schedule. Programs built on that cost-based methodology for public agencies may be shielded, though CMS has not spelled out exactly which cost calculation methods qualify. More clarity is needed there.
Programs that do not use an actual cost approach, and states that rely on Intergovernmental Transfers to fund the state share, appear more likely to be caught by the cap. One detail Texas agencies should note: early analyses suggest non-expansion states (which include Texas) could be capped at 110 percent of the Medicare AFS rate, versus 100 percent for expansion states. We will keep watching how that shakes out as the rule is finalized.
Where the comment period stands
The federal public comment period on CMS-2449-P closed on July 21, 2026. Industry groups including the International Association of Fire Chiefs, the Congressional Fire Services Institute, and AIMHI pushed hard for member input during that window. Even though the comment period has passed, this remains a proposed rule, not a final one. It is worth staying engaged with Texas and national associations as CMS reviews feedback and moves toward a final rule.
Meanwhile, a Texas rate change lands September 1
Closer to home, the Texas Medicaid and Healthcare Partnership (TMHP) is implementing reimbursement rate changes and updates for ambulance procedure codes effective September 1, 2026, based on the state’s public rate hearing process. This is separate from the federal GEMT rule, but it affects the same bottom line.
If your agency bills Texas Medicaid, now is the time to pull the updated ambulance fee schedule and confirm your billing systems reflect the new rates for dates of service on or after September 1. Using the wrong rate can mean underpayments or claim corrections down the road. The current figures are available through TMHP’s Online Fee Lookup and the static ambulance fee schedule.
What your agency can do now
You do not need to make big moves today, but a few steps will put you in a stronger position:
- Stay connected to Texas and national EMS associations, which are tracking the final rule closely.
- Build the possibility of tighter supplemental funding into your longer-range budget planning, so it is a scenario you have prepared for rather than a surprise.
How EMERGICON can help
This is exactly the kind of moving target we watch so you do not have to. Our team can help you understand how the proposed GEMT rule could affect your specific program, make sure your Texas Medicaid billing is ready for the September 1 rate update, and keep your reimbursement as strong as the rules allow. If you have questions about what any of this means for your agency, reach out. We are happy to walk through it with you.
To learn more, contact EMERGICON today at 866-839-3671, or support@emergicon.com.
Sources and further reading
- Public Consulting Group, overview of EMS supplemental payment programs and GEMT (PDF)
- International Association of Fire Chiefs, action alert on the proposed GEMT rule
- AIMHI, toolkit for understanding and responding to the proposed GEMT rule
- TMHP, Rate and Code Updates, where the September 1 ambulance fee schedule and Online Fee Lookup are posted
This post is for general informational purposes and reflects proposed federal rulemaking that may change before it is finalized. It is not legal, financial, or reimbursement advice specific to your agency.