# Passenger Carrier Operating Authority for NEMT: State Certificates and the MC Number

Canonical URL: https://nemtguide.com/glossary/operating-authority/ · Updated 2026-10-02

Passenger carrier operating authority is government permission to carry riders for pay. Many states require their own for trips that start and end inside the state, and FMCSA issues federal authority, an MC number, for paid trips across a state line. For NEMT, Kentucky issues a taxicab or disabled persons vehicle certificate, Missouri grants authority through MoDOT, and Pennsylvania through its Public Utility Commission.

- Operating authority is permission to carry riders for pay. It is a separate paper from your Medicaid enrollment, your broker contract, and your USDOT number.
- A federal MC number does not cover trips inside Pennsylvania or Missouri, and a state certificate does not cover a paid trip across a state line.
- The kind of authority limits who may pay you. Virginia's NEMT carrier certificate allows pay through Medicaid only.
- Run no paid trips until the certificate is issued. Pennsylvania bars advertising the service before then too.

Before your first paid ride, a government office has to let your company carry passengers for hire. That permission is operating authority. Which office grants it depends on where your trips start and end, and the kind you hold decides who may pay you.

## What operating authority covers

Operating authority is a certificate or permit that lets a company act as a for-hire passenger carrier. It belongs to your company, and in many states each vehicle is then registered or plated under it. It is a separate paper from your Medicaid enrollment, your broker contract, and your drivers' licenses, and a state can require all of them.

It comes at two levels, and each covers different trips:

- **Federal authority covers paid trips across a state line.** FMCSA says for-hire carriers in interstate commerce must get operating authority "no matter how small or light the vehicle(s) used, unless exempted" (Appendix A to 49 CFR part 390, current September 30, 2026). Each type of authority costs $300 ([49 CFR 360.3T](https://www.ecfr.gov/current/title-49/section-360.3T)), and a passenger carrier files at least $1.5 million of liability coverage for vehicles seating 15 or fewer, driver included ([49 CFR 387.33T](https://www.ecfr.gov/current/title-49/section-387.33T)). The filings, steps, and exemptions are in [USDOT number for NEMT](https://nemtguide.com/guides/dot-number-for-nemt/).
- **State authority covers paid trips that start and end in one state.** Pennsylvania's PUC says a federal DOT or motor carrier number does not authorize intrastate business (FAQ revised June 25, 2024). MoDOT says the same for Missouri in its FAQ of May 2026.

A company with trips of both kinds holds both.

## Kinds of state operating authority

States issue it through different offices and under different names, from a transportation agency in Kentucky and Missouri to a utility regulator in Pennsylvania and Rhode Island and the DMV in Virginia. Filing fees run from $50 in Virginia to $350 in Pennsylvania, and most states add a yearly renewal or per-vehicle fee. Here is what five states issue to NEMT companies, as of October 2026:

| State | Who issues it | What a NEMT company gets | Fees |
|---|---|---|---|
| Kentucky | Transportation Cabinet, Division of Motor Carriers | Taxicab or disabled persons vehicle (DPV) certificate | $250 to apply, $250 a year to renew, and $30 per vehicle a year |
| Missouri | MoDOT Motor Carrier Services | Common carrier certificate or contract carrier permit | $10 per vehicle a year if you are not in Unified Carrier Registration |
| Pennsylvania | Public Utility Commission | Paratransit or contract carrier authority | $350 per class, one time, plus a yearly assessment on revenue |
| Rhode Island | Division of Public Utilities and Carriers | NEMT certificate, after a public hearing | $125, then $100 a year |
| Virginia | DMV Motor Carrier Services | NEMT carrier certificate, Medicaid riders only | $50 filing, $3 per vehicle a year, and a $25,000 bond |

The name of the authority tells you what it allows:

- **Common carrier authority** lets you serve the general public for individual fares, usually with a filed rate list called a tariff. A Virginia common carrier on irregular routes may charge no more than the rates on file with DMV and may not refuse service without good cause. Pennsylvania's paratransit class covers advance reservation rides, at individual charges, in vehicles holding 16 or fewer people, driver included, and may not start or end at an airport (authority types, September 2022).
- **Contract carrier authority** covers riders you carry under written contracts, such as a nursing home or day program agreement. Missouri's permit names the contracting parties and the area served, a copy of each contract goes on file, and the state does not regulate contract rates (RSMo 390.061). Pennsylvania's contract carrier application includes the service contract. In Virginia, contract passenger authority covers groups at a group fee, under a contract of at least one hour made with the group's representative, so it does not fit single riders.
- **NEMT-only authority** fits companies that serve Medicaid riders alone. Virginia's NEMT carrier may carry only Medicaid members whose trips DMAS or its brokers arrange. Rhode Island declares every NEMT operator a common carrier under its Division of Public Utilities and Carriers (R.I. Gen. Laws 39-14.3-2, effective August 1, 2024).
- **Vehicle-type certificates** follow the van. In Kentucky a taxicab certificate covers vehicles with up to 8 regular seats, and a DPV certificate covers lift or ramp vehicles with up to 15 regular seats and no stretcher (KRS 281.010). The Transportation Cabinet says DPV vans may still carry riders who walk.
- **Need-based certificates** add a test of whether the area needs another company. See [certificate of public convenience and necessity](https://nemtguide.com/glossary/certificate-of-public-convenience-and-necessity/).

Some states exempt medical rides from a passenger carrier permit. California's Charter-Party Carriers' Act does not apply to vehicles used only for medical transportation (Public Utilities Code 5353(i)). Missouri's carrier law does not apply to taxicabs, or to trips under a contract with the state or a local government that pays the carrier directly (RSMo 390.030). Read the conditions before you rely on an exemption.

## How operating authority shows up in dispatch and billing

### Dispatch: check where each trip starts and ends

Picture a Kentucky company with a DPV certificate. A rider in Paducah asks for a private pay ride to a specialist in Nashville. The Kentucky certificate covers trips inside Kentucky, so unless an exemption fits, that ride needs FMCSA authority with $1.5 million of coverage on file before you accept it. The reverse catches companies too: an MC number alone does not let a Missouri company run a paid ride from Springfield to St. Louis.

Mixing work in one van can cost you an exemption. California's PUC says its medical exemption applies vehicle by vehicle, and a vehicle used for both medical and other for-hire rides may lose the exemption entirely, medical trips included. Ask the PUC's licensing staff before a wheelchair van takes paid airport or event rides. Rhode Island goes further: its Medicaid office requires NEMT certificate holders to keep a separate fleet that carries only NEMT members (EOHHS policy effective October 31, 2024).

### Billing: the authority decides who may pay you

A Virginia NEMT carrier certificate allows pay through Medicaid reimbursement only. When an assisted living home wants to pay for a resident's ride, or a family calls for a private pay trip, that ride falls outside the certificate. For that work Virginia DMV issues common carrier authority on irregular routes: you carry the general public for individual fares, inside the service areas on your certificate, and charge no more than the tariff you file with DMV.

In Kentucky the certificate doubles as your Medicaid license. The Transportation Cabinet says you upload the operating certificate, which it considers the license, when you enroll, and your regional broker collects copies of it and each vehicle's fee receipt card before you get trips. Without it there is no provider number to bill under.

## How to get state operating authority

1. **Find your office.** Your [state guide](https://nemtguide.com/states/) names it: a transportation department, DMV, utility commission, or transportation cabinet. Kentucky's steps are in the [Kentucky guide](https://nemtguide.com/states/kentucky/).
2. **Pick the kind that matches who pays you.** Medicaid only, the general public, or contract customers. Hold more than one if you serve more than one.
3. **Have your insurer file first.** Kentucky wants a Form E filed by an insurer authorized in Kentucky before you apply. Missouri keeps a Form E on file for as long as you hold authority. Virginia's NEMT carriers need at least $350,000 of liability coverage for vehicles seating 1 to 6, driver included, and $1.5 million for 7 to 15.
4. **Apply and wait.** Pennsylvania says no service may be provided or advertised until the certificate is issued, and its fine for operating without one is $1,000 per violation (FAQ revised June 25, 2024).
5. **Qualify each vehicle.** Kentucky issues a plate and fee receipt card for each vehicle, at $30 a year (KRS 281.631). Virginia requires plates designated for NEMT carriers, and Rhode Island's NEMT vehicles carry Public Service plates.
6. **Renew on time.** A Kentucky certificate not renewed within one year of its renewal date is void (KRS 281.630). Rhode Island certificates renew by December 31. Missouri carriers not in Unified Carrier Registration buy a $10 decal for each vehicle every year and file a financial statement each year.
7. **Keep every broker's copy current.** Send each broker the new certificate when you renew or add a vehicle. Your full list of licenses is in [NEMT license requirements](https://nemtguide.com/guides/nemt-license-requirements/).

## Frequently asked questions

### Is operating authority the same as a USDOT number?

No. A USDOT number identifies your company for safety records. Operating authority, shown by an MC number, is permission to carry paid riders across state lines. FMCSA says for-hire carriers in interstate commerce need both operating authority and safety registration, however small the vehicle, unless an exemption applies (Appendix A to 49 CFR part 390, current September 30, 2026). Missouri also asks for a USDOT number before it grants in-state authority.

### Do I need operating authority if I only carry Medicaid riders?

In many states, yes. Kentucky's Transportation Cabinet treats your motor carrier certificate as the license you upload when you enroll in Medicaid. Virginia has a certificate just for carriers that serve only Medicaid riders, and Rhode Island requires an NEMT certificate of operating authority before any vehicle provides NEMT there, unless your company already holds a Rhode Island taxicab certificate. California is one exception for its charter-party permit: vehicles used only for medical transportation are exempt under Public Utilities Code 5353(i).

### Does my state certificate cover a ride into another state?

No. A paid ride from your state into another is interstate commerce, and it needs FMCSA operating authority unless an exemption applies. You also file at least $1.5 million of liability coverage for vehicles seating 15 or fewer, driver included (49 CFR 387.33T). Exemptions such as commercial zones come with conditions, so get FMCSA's answer before you rely on one.

### How long does it take to get state operating authority?

It depends on the state. Kentucky's Division of Motor Carriers asks you to allow up to 14 business days, once your insurer's filing, vehicle inspections, and background checks are done. Pennsylvania's PUC estimates 3 months or longer for most passenger authority (FAQ revised June 25, 2024). Rhode Island holds a public hearing on every NEMT certificate application. Start before you sign up for broker trips.

## Official resources

- [Kentucky Division of Motor Carriers: Passenger vehicle certificates](https://drive.ky.gov/Motor-Carriers/Pages/Passenger-Vehicle.aspx)
- [MoDOT Motor Carrier Services: Missouri Operating Authority](https://www.modot.org/MOPA)
- [Pennsylvania PUC: Intrastate authority types and fees](https://www.puc.pa.gov/media/2045/motor_carrier_authority_types2022.pdf)
- [Virginia DMV: Non-Emergency Medical Transportation Carrier](https://www.dmv.virginia.gov/businesses/motor-carriers/intrastate/medical)