Open the Books obtained Medicaid billing data from the Centers for Medicare & Medicaid Services covering Massachusetts providers from 2018 to 2024. This analysis traces non-emergency transportation claims, a program worth hundreds of millions of dollars annually, at the same time two fraud schemes were operating undetected inside it. It’s part of our Cost of Fraud series. Read part 1 and part 2 here.
Bakali Mukasa billed MassHealth for rides to methadone clinics that were never driven. His Waltham-based company, JBM Health and Educational Services Inc., collected more than $770,000 from Massachusetts Medicaid for 16,907 trips that never occurred, including nearly 100 trips billed for patients who were already dead.
Investigators discovered the scheme by cross-referencing billing records against the clinic’s own logs. On the dates the rides were supposedly provided, patients had been issued take-home medication, meaning there was no reason to travel. The ghost rides were hiding in plain sight.
In February 2026, the Massachusetts Attorney General’s Office indicted Mukasa and JBM, a company now dissolved, on charges of Medicaid false claims, larceny, and money laundering. The proceeds were allegedly funneled through real estate and investment accounts, with transfers to Uganda, where Mukasa currently lives.
Less than a year earlier, the same office indicted Ardit Islamaj, 36, and his Worcester-based Instant Transportation LLC on 17 counts: Medicaid fraud, larceny, patient abuse, identity fraud, money laundering, and witness intimidation. Between August 2018 and August 2023, Islamaj allegedly billed MassHealth more than $3 million for rides that never occurred, including trips for deceased patients, hospitalized patients, and patients who had canceled. Employees were instructed to impersonate MassHealth members to inflate trip counts. A former employee was paid thousands of dollars to stay quiet before meeting with investigators.
Two companies. Two schemes. $3.77 million in alleged stolen funds. Five years without detection.
The Claims Data Shows an Explosion in Volume
In the Medicaid system, every service has a billing code called an HCPCS code that identifies what is being provided. Non-emergency transportation is primarily billed under code T2024, which covers the daily coordination of rides for Medicaid members: not a single trip, but the ongoing management of a patient’s transport over time.
Using CMS billing data for Massachusetts, Open the Books tracked claims under all non-emergency transport codes from 2018 to 2024.
Non-emergency transport claims grew 403%, from 4,417 in 2018 to 22,228 in 2023.
T2024 accounted for nearly 59% of all claims over the period. That growth is not proof of fraud on its own. Medicaid enrollment in Massachusetts expanded significantly during the pandemic, and demand for this service is real and legitimate.
But the numbers document a program that scaled dramatically while two separate fraudulent operations ran undetected inside it.
A New Billing Code Appeared in 2023
In 2023, a second transport code appeared in the Massachusetts data for the first time: T2038, which covers individual trips rather than daily coordination. By 2024, T2038 had reached 10,489 claims, nearly matching T2024’s volume that year.
The reason for this shift is not visible in the public data. Open the Books is asking MassHealth why T2038 adoption accelerated so sharply and whether the transition was accompanied by additional oversight.
What the Data Cannot Show
The CMS dataset has important limitations that are worth stating clearly.
The payment column in the Massachusetts file contains no dollar figures, only claim counts. That means it is not possible to calculate directly from this data how much any provider was paid. In the Massachusetts State Checkbook, transport payments are presented as lump sums, making it difficult for taxpayers or external auditors to trace funds at the provider level.
There is a second gap. CMS suppresses data for providers that submit fewer than 11 claims per period to protect patient privacy. That threshold means small operators, precisely the type of company most likely to run a short-lived fraud scheme, may not appear in the public record at all.
Neither JBM Health nor Instant Transportation appears in the CMS data. The public record had no way to flag them.
The claims-to-patient ratio, a common fraud indicator, also requires caution here. T2024 is a per diem coordination code, meaning a patient with chronic needs, such as dialysis or regular treatment, can legitimately generate many claims over time. High ratios are not automatically suspicious in this context.
Four Enforcement Actions in 18 Months
The two indictments are not isolated. In October 2024, the AGO reached a $380,000 settlement with a Swampscott-based provider for billing MassHealth for services it never delivered. In July 2025, a Millville-based company paid $1.045 million to resolve allegations that it billed for routes it never drove and transported disabled passengers without required safety monitors on board.
That is four enforcement actions against Massachusetts non-emergency transportation providers in roughly 18 months.
Whether this reflects an intensified enforcement effort, a systemic vulnerability in the program, or both is a question MassHealth and the legislature have not publicly addressed.
The Questions MassHealth Has Not Answered
Non-emergency transportation is an essential service. People who cannot drive themselves still need to reach dialysis appointments, chemotherapy, and mental health treatment. The program exists for good reason.
The problem is the absence of basic controls and the opacity that makes those controls hard to verify from the outside.
How long did it take to detect these schemes, and what triggered the investigations? How many audits were conducted specifically on non-emergency transport codes between 2020 and 2025? Does MassHealth have automated checks that cross billing records against mortality data and patient eligibility? Why does the State Checkbook aggregate transport payments rather than publishing them at the provider level?
The Worcester scheme ran for five years. The Waltham scheme ran for over a year. In both cases, the fraud was uncovered by active investigation, not by a system that caught it automatically.
Every dollar paid for a ride that never happened is a dollar not available for someone who genuinely needs one.
Massachusetts has one of the most generous Medicaid programs in the country. That generosity deserves transparency to back it up.
Methodology
This analysis uses Medicaid billing data published by the Centers for Medicare & Medicaid Services, covering Massachusetts providers from January 2018 through December 2024. The dataset includes provider name, billing code (HCPCS), month and year, total claims, and total unique beneficiaries. Payment amounts are not included in this data release. Non-emergency transport was defined as claims under codes T2024, T2038, A0425, A0428, S0302, and A0120. Growth figures compare 2018 annual totals to 2023 annual totals, the dataset’s peak year. Fraud case details are drawn from press releases issued by the Massachusetts Attorney General’s Office.
Source data: CMS Medicaid claims, Massachusetts subset (Open the Books analysis) · Massachusetts AGO press releases (Feb. 2026, Apr. 2025, Jul. 2025, Oct. 2024).
