# Medicaid Enrollment Moratoriums: How NEMT Enrollment Freezes Work and What to Do While You Wait

Canonical URL: https://nemtguide.com/glossary/enrollment-moratorium/ · Updated 2026-09-30

A Medicaid enrollment moratorium is a temporary freeze on enrolling new providers of one type, or in one area, that CMS or the state sees as high risk for fraud. Under 42 CFR 455.470 it lasts 6 months, extendable in 6-month steps. As of September 30, 2026, North Dakota freezes new NEMT companies statewide, Minnesota freezes them in the Twin Cities metro, and Colorado's freeze ends that day.

- A moratorium stops new enrollments of one provider type, or in one area, for 6 months at a time. Enrolled providers keep working.
- Applications still pending when a freeze starts are often denied or not processed, as in Minnesota, North Dakota, Ohio, and Indiana.
- Medicaid health plans cannot fill the gap, because their network providers must be enrolled with the state within 120 days.
- Some states grant exceptions where members lack rides. Ask in writing, with the area and the numbers.
- When a freeze ends, be ready for high risk screening with fingerprints and a site visit, and file on the first day enrollment reopens.

## How a Medicaid enrollment moratorium works

A moratorium stops a state Medicaid agency from enrolling new providers of one type, or new providers in one area, for a set time. It is a fraud control tool. The federal rule is [42 CFR 455.470](https://www.ecfr.gov/current/title-42/section-455.470), and it allows two kinds.

| | CMS moratorium | State moratorium |
|---|---|---|
| Who starts it | CMS, after consulting the state | The state Medicaid agency |
| Why | CMS finds the provider type poses an increased risk to Medicaid | The state finds a significant potential for fraud, waste, or abuse in a type CMS has identified as high risk |
| Members' access | The state may opt out if the freeze would hurt members' access, and must tell CMS in writing | The state must first find the freeze will not hurt members' access |
| CMS's role | CMS imposes it and announces it in the Federal Register | CMS must agree before it starts |
| Length | 6 months, extended in 6-month steps | 6 months, extended in 6-month steps, with the reason documented in writing each time |

A state can also impose numerical caps or other limits instead of a full freeze. CMS's compendium, updated November 17, 2025, says states should send CMS their request on form CMS-10628 at least 30 days before the start date, or before an extension. States have wide discretion over the details, which is why each freeze reads differently.

CMS announces its moratoriums in the Federal Register. States announce theirs in provider bulletins and notices, such as Minnesota's MHCP provider news, Indiana's IHCP bulletins, Colorado's provider bulletins, and North Dakota's provider enrollment moratoria notice.

## Which states have NEMT enrollment moratoriums (September 2026)

| State | What is frozen | Dates | Notes |
|---|---|---|---|
| Minnesota | New NEMT providers located in Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties | January 27, 2026 to January 27, 2027 (extended July 23, 2026) | Companies located in other counties can enroll. See [Minnesota's metro freeze](https://nemtguide.com/news/minnesota-metro-nemt-enrollment-freeze/). |
| North Dakota | New NEMT agencies statewide | From June 11, 2026, for 6 months unless extended | Applications not at final approval on June 11 were denied. See [North Dakota](https://nemtguide.com/states/north-dakota/). |
| Indiana | New providers of many 1915(c) waiver services, including waiver transportation | From August 1, 2026, for 6 months, extendable | Covers waiver services, not the state plan NEMT benefit. See [waiver transportation providers](https://nemtguide.com/guides/waiver-transportation-provider/). |
| Ohio | Home health, hospice, private duty nursing, personal care aides, home care attendants, and waivered services organizations and individuals | May 14 to November 14, 2026, unless CMS approves an extension | Does not list ambulance or wheelchair van providers. Ohio's screening rule lists supplemental transportation as a waivered services organization service. |

Colorado's statewide NEMT freeze runs out on September 30, 2026, and Arizona's ended in 2024:

| State | What was frozen | Dates | What to know |
|---|---|---|---|
| Colorado | New and pending NEMT providers statewide | October 1, 2023 to September 30, 2026. Enrollment reopens October 1, 2026 (HCPF bulletin B2600542, September 2026) | New companies need Health First Colorado enrollment, driver and vehicle credentialing in ProCredEx, and a MediDrive contract. See [Colorado](https://nemtguide.com/states/colorado/). |
| Arizona | NEMT and four other provider types, statewide | Extended June 9, 2024, and ended December 9, 2024 | Applications filed before it ended still need an exemption form. See [Arizona](https://nemtguide.com/states/arizona/). |

Check your state's provider bulletins before you buy vans or sign a lease. Our [state guides](https://nemtguide.com/states/) list each Medicaid enrollment office.

## Who a moratorium covers, and who it does not

**New applicants.** The freeze stops new enrollments of the listed type. Pending applications are at risk. Minnesota said it would not process submissions already in its queue. North Dakota denied applications not yet at final approval. Ohio denied unprocessed applications and refunded any application fee. Indiana said it would deny open applications that had not finished screening before August 1, 2026.

**Enrolled providers.** They keep serving members and can revalidate. Growth rules vary. Minnesota lets enrolled providers add locations for services they already provide. Ohio adds no new service locations during its freeze. Indiana's waiver freeze also blocks changes of ownership and adding counties or services.

**Health plan networks.** A Medicaid health plan cannot sign you up to get around a freeze. The state must enroll every network provider of its health plans, and a plan may contract with you for no more than 120 days while enrollment is pending ([42 CFR 438.602(b)](https://www.ecfr.gov/current/title-42/section-438.602)). Ohio's notice lets plans contract only with providers whose agreement took effect by May 13, 2026. A broker that contracts with the state only for rides is outside that 120-day rule ([42 CFR 438.9](https://www.ecfr.gov/current/title-42/section-438.9)), so ask the state whether its broker network needs a Medicaid enrollment during the freeze.

**Members.** Member eligibility does not change. Minnesota says its freeze does not affect member enrollment, and Ohio says members keep getting services from enrolled providers.

## Federal moratoriums that reached transportation

CMS used its own moratoriums on ambulance suppliers from 2013 to 2019. From July 30, 2013, it froze new ambulance suppliers in Harris County, Texas, and seven nearby counties. From July 29, 2016, it froze new non-emergency ground ambulance suppliers statewide in New Jersey, Pennsylvania, and Texas. Those freezes reached Medicaid and CHIP in the same states. Texas's was lifted September 1, 2017, after Hurricane Harvey. New Jersey's and Pennsylvania's were extended again from July 29, 2018, and CMS let the remaining freezes expire on January 30, 2019.

In 2026, CMS announced nationwide Medicare moratoriums on new medical supply companies (effective February 27, 2026) and on new home health agencies and hospices (effective May 13, 2026). None covers transportation. For home health, CMS left it to each state to decide whether to freeze its Medicaid program too, and Ohio's May 14, 2026 notice cites that CMS announcement. Section 1866(j)(7)(B) of the Social Security Act bars court review of CMS's decision to impose a moratorium. For Medicare, a CMS freeze does not apply to applications received before it starts, or to most changes of ownership (42 CFR 424.570). State Medicaid freezes set their own terms, as the pending-application denials above show.

## What to do while enrollment is frozen

1. **Confirm the scope.** Read the notice for the provider type, the area, and whether it turns on where your company is located or where it serves.
2. **Ask about a pending application.** Find out in writing whether it was denied, held, or refunded.
3. **Ask for an exception if members lack rides.** Minnesota may allow new providers where capacity is short, with CMS approval for each one. Indiana wants a narrative on the access problem you would fix. Arizona's 2024 freeze allowed exemptions for underserved areas and for health plans short of time and distance standards. Send the county, the service level, and trip numbers.
4. **Get ready to file on day one.** Line up your NPI, insurance, vehicle inspections, and driver files, and plan for fingerprints from every 5 percent owner. See [how to become a Medicaid transportation provider](https://nemtguide.com/guides/how-to-become-a-medicaid-transportation-provider/).
5. **Earn money outside Medicaid.** Private pay riders and facility contracts need no Medicaid enrollment. See [private pay NEMT](https://nemtguide.com/guides/private-pay-nemt/) and [NEMT facility contracts](https://nemtguide.com/guides/how-to-get-nemt-facility-contracts/).
6. **Be careful buying an enrolled company.** Ask the state in writing how it treats the change first. See [how to buy a NEMT business](https://nemtguide.com/guides/buy-a-nemt-business/).
7. **Watch the end date.** Freezes can be extended. Sign up for your state's provider bulletins and check them a month before the date.

## What happens when a moratorium ends

When a state or CMS lifts a moratorium, a provider that it kept out and that applies within 6 months is screened as high risk ([42 CFR 455.450(e)](https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.450)). That means fingerprints from every 5 percent owner, plus a site visit. See [Medicaid provider risk levels](https://nemtguide.com/glossary/provider-risk-levels/).

CMS's compendium draws a line between lifting a freeze and letting it expire. When a state lets it expire, raising applicants to high risk is optional, and the state should tell CMS how it will enroll and screen the providers it kept out. Colorado's NEMT freeze runs through September 30, 2026, and its September 2026 bulletin says enrollment reopens October 1, 2026. In Colorado the difference does not matter for NEMT, because state rule 10 CCR 2505-10 section 8.125.4.L already lists NEMT as a high risk provider type. Wherever you apply after a freeze, ask the state which screening level your application gets.

Here is what that looks like for a new company. Two partners who waited out a freeze file on the day enrollment reopens. At high risk, both partners must send fingerprints within 30 days of the state's request, and the state visits the office before it approves the application. Book the fingerprint appointments and set up the office before you file, so neither step waits on you.

If your application is denied for another reason after the freeze, see [what to do when a Medicaid application is denied](https://nemtguide.com/guides/medicaid-application-denied/). If your problem is a broker that is not adding providers, that is not a moratorium. See [when a broker network is full](https://nemtguide.com/guides/broker-network-full/).

## Frequently asked questions

### Can I apply for Medicaid enrollment during a moratorium?

Not for the frozen provider type or area. States stop accepting new applications, and many deny the ones already waiting. North Dakota denied every NEMT agency application that had not reached final approval by June 11, 2026. Minnesota said it would not process pending submissions. Ohio denied unprocessed applications for its frozen types and refunded the application fee.

### Does a moratorium affect NEMT providers that are already enrolled?

Usually not their current work. Enrolled providers keep serving members and can revalidate. Growth can be limited, though. Minnesota lets enrolled providers add locations for services they already provide, while Ohio adds no new service locations during its freeze. Indiana's waiver freeze also blocks adding counties, adding services, and changes of ownership for enrolled agencies.

### How long does a Medicaid enrollment moratorium last?

The first period is 6 months. The state can extend it in 6-month steps, documenting in writing each time why it is still needed, and CMS must agree. Minnesota's metro NEMT freeze started January 27, 2026 and was extended on July 23, 2026 to January 27, 2027. Colorado kept its NEMT freeze from October 1, 2023 to September 30, 2026.

### Can I get an exception to a moratorium?

Sometimes. Minnesota may allow new providers where service capacity is not enough, with written CMS approval for each exception. Indiana reviews exception requests with a narrative showing how you would fix an access problem. Arizona's 2024 freeze allowed exemptions for medically underserved areas, state initiatives, and health plan requests to meet time and distance standards.

### Is a full broker network the same as a Medicaid moratorium?

No. A moratorium is a state or CMS freeze on Medicaid enrollment under 42 CFR 455.470, with 6-month periods and CMS concurrence. A broker that stops adding providers is making a business decision under its own contract. You can be enrolled with Medicaid and still wait for a broker. See what to do when a broker network is full.

## Official resources

- [eCFR: 42 CFR 455.470, Temporary moratoria](https://www.ecfr.gov/current/title-42/section-455.470)
- [Minnesota DHS: MHCP provider news](https://mn.gov/dhs/assets/2026-07-14-mhcp-provider-news_tcm1053-761845.pdf)
- [North Dakota HHS: Provider Enrollment Moratoria notice](https://www.hhs.nd.gov/sites/default/files/documents/provider-enrollment-moratoria.pdf)
- [Indiana Health Coverage Programs: HCBS moratorium bulletin BT2026124](https://www.in.gov/medicaid/providers/files/bulletins/BT2026124.pdf)
- [Ohio Department of Medicaid: Statewide new provider moratorium](https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Home/Home%20Health/ODM-Statewide_NP_Moratorium-V2.pdf)