Certificate of Public Convenience and Necessity (CPCN) for Wheelchair and Stretcher Transportation

Most permits check that you are safe: your vans, your drivers, your insurance. A certificate of public convenience and necessity asks one more question, whether the public needs another company at all. That question is why a CPCN can take months, why competitors get a say, and why you should read the code before you buy a van for a new county.

What makes a CPCN different

Three things set a CPCN apart from the other papers a NEMT company holds:

• A need test. The board looks at whether existing service already meets the public’s needs, not only at whether you qualify.
• A say for competitors. Operators already in the area are notified and can protest or speak at the hearing.
• A set territory and term. The certificate names where you may operate, and it expires on a fixed schedule.

Compare the papers that sit next to it:

• A for-hire vehicle or NEMT permit checks your vehicles, drivers, and insurance. Santa Rosa County’s code, for one, says its wheelchair and stretcher permit may not be denied because the area is already served.
• A business tax receipt or business license registers your company and collects a local tax. It does not ask whether the area needs you.
• Operating authority is the general term for state or federal permission to carry passengers for pay. See passenger carrier operating authority.

Spellings vary. New Orleans calls its version a Certificate of Public Necessity and Convenience (CPNC), Santa Rosa County shortens its name to COPCN, and Pennsylvania issues a Certificate of Public Convenience.

Where wheelchair and stretcher companies need one

Alachua County, Florida, and New Orleans put NEMT companies through a need test. Santa Rosa County, Florida, uses the name for wheelchair and stretcher service but its code is mixed on the need test, and Pennsylvania dropped its need test in 2017.

Place	Issued by	What it covers	Need test
Alachua County, Fla.	Board of County Commissioners	Every nonemergency transport provider, Gainesville included	Yes. The board weighs whether current service is adequate.
New Orleans, La.	Ground Transportation Bureau (Public Works)	Each NEMT van, as a special services CPNC	Yes. A new company must show existing ones cannot serve.
Santa Rosa County, Fla.	Board of County Commissioners	Wheelchair and stretcher service, $500 for a new certificate	Mixed. A certificate can be refused as duplicate service, a permit cannot.
Pennsylvania	Public Utility Commission	Paratransit carriers, including wheelchair and stretcher vans, $350 to apply	No, since June 3, 2017. It reviews fitness.

Santa Rosa’s code pulls two ways. Section 12-58 says Level 1 wheelchair and stretcher service needs a certificate of public convenience and necessity, and section 12-66 bars new certificates that duplicate the same type of service in the same area. Yet section 12-65 says a permit for non-medical transportation, the code’s other name for that same service, may not be denied for duplication. Ask the county which one it will issue you before you plan around a protected territory.

The name alone does not tell you who must apply. Martin County, Florida, issues four classes of certificate of public convenience and necessity, and all four cover ambulance and other life support services (Martin County Code section 87.104, Supplement 63, May 5, 2026). None covers a wheelchair van, as the Martin County page explains. Florida’s other county certificates are in Florida NEMT license rules.

How proving public need works

Alachua County

When you apply, the Board of County Commissioners notifies every existing operator serving any part of your proposed area. Each has 30 days from the mailing to file a formal protest and serve it on you. Within 90 days of the notice, the board grants the certificate, grants it with conditions, or denies it (Administrative Code section 52.29).

The board may weigh whether existing services are adequate to meet reasonable public needs, your finances, your qualifications, any protests, and whether a new certificate could seriously impair the service existing operators provide. A certificate lasts two years, and the board handles each renewal like a new application (section 52.30).

New Orleans

New CPNCs are decided at hearings on the fourth Friday of January, May, and September, with applications due by 4 p.m. on the first Friday of that month (CPNC 101, updated June 5, 2026). Under City Code section 162-185, the city weighs the effect on existing certificate holders and on public transit, and a new CPNC company must establish that existing CPNC companies do not or cannot adequately provide the service. Existing holders may appear as intervenors. When applications exceed what public necessity calls for, the city may hold a lottery (section 162-184). Deadlines, fees, and van rules are on the New Orleans page.

Building your case

Because the board looks at unmet need, come with proof as well as paperwork:

1. Map your territory. List the towns or zones you will serve and the base you will run from.
2. Show the demand. Ask dialysis centers, nursing homes, and hospital discharge staff for letters describing rides they cannot get booked.
3. Show the gap. Note the certified wheelchair and stretcher operators already there and what they do not cover, such as weekends, early dialysis chairs, or stretcher trips.
4. Show you are fit. Alachua’s application asks for each vehicle’s make, model, year, mileage, and VIN, three county residents as references, a rate schedule, and an agreement to file insurance before the certificate takes effect. Bring proof of your finances too, since the board weighs them.
5. Answer protests in writing. Respond to each objection before the hearing so the board has your side on file.

Where the need test no longer applies

Some states kept a certificate and dropped the need test. Pennsylvania’s Public Utility Commission removed the rule that passenger carrier applicants prove a public demand or need, in a final rulemaking published June 3, 2017 (47 Pa.B. 3099). Its policy statement now looks at your capital, equipment, experience, insurance, safety plan, and compliance record (52 Pa. Code 41.14, effective February 10, 2018). Your application is still published in the Pennsylvania Bulletin and paused at least five weeks for possible protests (PUC timelines, January 2024), as the Pennsylvania guide explains.

Kentucky dropped its need test in 2015. SB 153, signed March 19, 2015, repealed the section that let others protest an application and had the state issue a certificate to any applicant who meets the chapter’s rules. Under KRS 281.010, as in effect June 27, 2025, a certificate is a certificate of compliance, and wheelchair vans run under a disabled persons vehicle certificate, a class that excludes vehicles equipped with a stretcher. See the Kentucky guide for the rest. Your full list of state and local licenses is in NEMT license requirements.