# How to Handle NEMT Broker Complaints in 2027: Deadlines, Proof, and Fixes

Canonical URL: https://nemtguide.com/guides/broker-rider-complaints/ · Updated 2026-09-29

When a rider, family member, or clinic complains to your NEMT broker, the broker sends the complaint to you for a response. Answer by its deadline, which can be as short as 1 business day, with objective proof: trip times, GPS data, video, and a statement signed by the driver. Brokers count confirmed complaints against you, so log every one and fix the cause.

- Answer every complaint the broker sends you before its deadline. CareOregon's brokerages give 3 business days, or 1 for serious cases.
- Send records, not opinions: trip times, GPS data, video, and a statement the driver signed and dated.
- Brokers score confirmed complaints. MTM Health in Virginia expects them on fewer than 0.1 percent of completed trips.
- In Georgia and Texas, two complaints about one van within days force an inspection or pull it from service.
- Never let a driver discourage or punish a rider for complaining, and review complaints every month to catch repeats early.

A complaint can reach your broker from a rider, a daughter, a dialysis nurse, or the state. The broker logs it, sends it to you, and waits for your side. What you send back, and how fast, often decides whether the complaint counts against you.

## How a rider complaint reaches you

Brokers take complaints from almost anyone. Georgia's NEMT manual (July 1, 2026) says complaints may come from members, their representatives, providers, the state, or any person or group that contacts the broker. MAS in New York takes them online, through its call center, by email or mail, and through surveys. Its October 2023 manual says call center staff are trained to spot complaints a caller never names as one.

The broker has to act on them. Federal rules require every state NEMT broker to have oversight procedures that monitor complaints and make sure rides are timely and drivers are licensed, qualified, competent, and courteous ([42 CFR 440.170](https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-440/subpart-A/section-440.170)). CMS adds that the state, the broker, and the transportation company should all watch complaints about courteous drivers, clean vehicles, and timely rides (SMD 23-006, September 28, 2023).

A complaint can also start somewhere else. A health plan member may file a grievance at any time, by phone or in writing, with the plan or the state, as the state decides ([42 CFR 438.402](https://www.ecfr.gov/current/title-42/section-438.402)). Georgia runs its own toll-free line for NEMT complaints, and state staff may ride along on trips. In Georgia, the broker still has to record and respond to every complaint about NEMT service. MTM Health's standard agreement forwards each complaint it receives to the provider for a response.

### Complaint, grievance, appeal, or incident

| Term | What it means | Who handles it |
|---|---|---|
| Complaint or grievance | Dissatisfaction with the service, such as a late ride, a rude driver, or a dirty van. Federal health plan rules call it a grievance: anything other than a benefit decision ([42 CFR 438.400](https://www.ecfr.gov/current/title-42/section-438.400)) | The broker investigates, and you answer |
| Appeal | A request to review a decision, such as a denied or reduced trip | The broker or plan decides it |
| Incident | An event such as an injury, accident, theft, harassment, or abuse (Georgia manual, section 920.9) | You report it to the broker, at once for any injury, and file an [incident report](https://nemtguide.com/templates/nemt-incident-report-form/) |

One event can be both. MTM Health in Rhode Island treats a verbal argument between a driver and a rider, a securement problem, or habitual lateness, no-shows, or rudeness as a Tier 2 issue. It needs a written report within 24 hours, and missing any reporting deadline costs $500 in liquidated damages (handbook updated July 1, 2026). For how grievances move through a health plan, see member grievance.

## How fast you have to answer

The broker's own clock to the state is short, so the time it gives you is shorter.

| Program | What the broker needs, and by when | Source |
|---|---|---|
| CareOregon brokerages | Your response within 3 business days for general grievances, or 1 business day for serious ones. Tell the brokerage if you will be late, and why. | Manual version 1.3, February 2024 |
| MTM Health standard agreement | Complaints are forwarded to you for immediate attention and response, and service problems must be resolved promptly | Agreement dated January 1, 2023, as Pennsylvania posts it |
| MTM Health, Rhode Island | Written report within 24 hours for Tier 2 issues such as a verbal argument, a securement problem, or habitual rudeness | Handbook updated July 1, 2026 |
| Georgia broker | The broker calls the person back within 24 hours and sends the state its findings and corrective actions within 5 business days | DCH manual, July 1, 2026, sections 920.11 and 920.12 |
| South Carolina draft contract | The broker acknowledges each complaint within 1 business day and is expected to resolve and close it within 5 business days | Solicitation 5400029919, posted June 26, 2026 |
| Indiana broker target | 95 percent of complaints and appeals investigated, remediated, and closed within 15 business days | FSSA presentation, August 28, 2025 |
| Federal ceiling for health plans | Each grievance resolved within the state's timeframe, no more than 90 calendar days, plus up to 14 days if the plan extends it | [42 CFR 438.408](https://www.ecfr.gov/current/title-42/section-438.408) |

When a request arrives without a due date, ask for one in writing. Then work to beat it by a day.

## What to send with your response

A good response is short and backed by records. CareOregon's manual asks for objective documentation: what was seen, heard, or measured, not what someone felt. It also says brokerages treat every grievance as potentially valid and preventable until the documentation proves otherwise.

1. **Log it the day it arrives.** Give it a number and write the broker's reference number and due date beside it. The free [NEMT complaint log](https://nemtguide.com/templates/nemt-complaint-log/) has the columns.
2. **Pull the trip record.** Get the scheduled and actual pickup and drop-off times, the driver, the vehicle, and the odometer readings. MTM Health in Virginia expects GPS tracking on more than 90.01 percent of trips, so the GPS trail should be there.
3. **Get the driver's statement the same day.** Have the driver write what happened, in order, then sign and date it. Memory fades fast.
4. **Pull the video.** CareOregon strongly recommends dash cameras with inward and outward views, and says the footage can help a brokerage decide whether a complaint is substantiated. See NEMT dash cameras.
5. **Add outside proof.** A police report, or a record that the other party's insurer paid, carries weight. CareOregon lists both as adequate documentation.
6. **Write the answer.** Use the format below.
7. **Send it before the deadline and keep a copy.** Save what you sent and when with the complaint.

### A response the broker can use

Georgia's manual requires its broker to report each complaint's cause, findings, solution, and any changes that resulted (section 920.13). Build your answer the same way, so the broker can pass it on without rewriting it. The example column is made up, to show the level of detail.

| Part | What to write | Example |
|---|---|---|
| The complaint | Broker reference number, trip ID, date, and rider | Ref. 4471, trip 88213, March 3, 10:00 a.m. pickup |
| What the records show | Times, GPS, video, odometer | GPS shows arrival at 9:52 a.m. The rider boarded at 10:04 a.m. |
| The driver's account | One or two lines, with the signed statement attached | The driver waited at the main entrance and called the rider at 9:55 a.m. |
| Finding | Confirmed, not confirmed, or partly confirmed | Not confirmed for lateness. Confirmed that the van was too warm. |
| Fix | What you changed | The van's air conditioning was repaired March 4. Invoice attached. |
| Prevention | What stops a repeat | Drivers now check cabin temperature on the pre-trip inspection. |

## How brokers decide and score complaints

The broker, not you, decides whether a complaint is substantiated. CareOregon's brokerages decide whether each grievance was preventable and whether the provider or driver was at fault, then track those findings for patterns by provider and driver. South Carolina's draft contract has a supervisor review every complaint found unsubstantiated after the first review. Modivcare's Kansas manual (May 2022) sends providers a monthly report of validated grievances about their company and drivers.

Then the count matters.

| Program | How complaints are scored |
|---|---|
| MTM Health, Virginia (handbook approved August 10, 2026) | Substantiated complaints must stay below 0.1 percent of completed trips. Some also carry points: 2 for a substantiated securement complaint, a vehicle safety problem such as a torn seat belt or broken air conditioning or heat, or a missing required attendant, and 3 for leaving a rider at the wrong place or without the right level of assistance. |
| MTM Health, Rhode Island (handbook updated July 1, 2026) | Complaint rates below 0.09 percent are green, 0.1 to 0.49 percent yellow, and 0.5 percent or more red |
| Indiana (FSSA, August 28, 2025) | The state holds its broker to no more than 1 percent of completed one-way trips with a valid member complaint, and ties part of the broker's pay to it |

MTM Health's Virginia points last one year. At 3 points you lose access to its trip marketplace until points come off. At 5 you are suspended for 5 business days, at 8 for 10 days with your recurring trips taken away, and at 10 you are removed from the network.

**Complaint rate = confirmed complaints ÷ completed trips × 100**

A company with 1,200 completed trips reaches Virginia's 0.1 percent line at 1.2 confirmed complaints, so two confirmed complaints over those trips put it over. That is why each answer matters. For every metric brokers track, see [NEMT broker scorecards](https://nemtguide.com/guides/nemt-broker-scorecards/).

## What happens to the driver and the van

Complaints about a vehicle can take it off the road quickly.

| Rule | What triggers it | What you must do |
|---|---|---|
| Georgia DCH manual, section 913.2 (July 1, 2026) | Two or more passenger complaints about cleanliness, heat, air conditioning, or other problems within 5 days | Inspect the vehicle, fix it, and record the fix in its permanent file |
| Texas NEMT Services Handbook, section 2620 (August 1, 2021) | Two substantiated complaints about cleanliness, temperature, or other problems within 10 days | Keep it out of service until the corrective action is documented |
| South Carolina draft contract (June 2026) | Two or more member complaints about cleanliness or temperature within the same 5 days | The broker removes it until the correction is made and documented |

Drivers face their own steps. CareOregon's brokerages may suspend a driver while they investigate claims of improper conduct or harassment, and a complaint about driving or customer relations can require intervention training. MTM Health in Virginia bars a driver from every MTM health plan if the driver commits another violation after retraining for a serious one. Georgia's manual lets the state require its broker to remove a provider or driver at once for an investigation or retraining (section 920.15). Track who was retrained and when in a [driver training log](https://nemtguide.com/templates/nemt-driver-training-log/).

## How to stop repeat complaints

Most repeat complaints trace back to a few causes. Sort each month's complaints by type, driver, and vehicle, and fix the pattern before the broker finds it.

| Complaint | Common cause | Fix |
|---|---|---|
| Late pickup or missed appointment | Tight schedules, [will-call returns](https://nemtguide.com/glossary/will-call-trip/) with no van nearby | Call ahead when running late. MTM Health's Rhode Island handbook requires you to call affected riders about a delay, and its standard agreement requires you to tell MTM at once about a delay that will make a rider late. See [improving on-time performance](https://nemtguide.com/guides/improve-nemt-on-time-performance/). |
| Van too hot, too cold, or dirty | Skipped checks, broken air conditioning | Check the cabin on every pre-trip inspection. MTM Health in Virginia expects air conditioning to about 68°F and heat to about 74°F, measured from the rear. |
| Rude or unsafe driver | Rushed days, no coaching | Retrain on the complaint's subject and record it. See [NEMT driver training](https://nemtguide.com/guides/nemt-driver-training/). |
| Securement or level of assistance | The driver missed the manifest | Read the level of assistance on each manifest. MTM Health's Virginia manifests list curb-to-curb, door-to-door, or hand-to-hand. |
| Wrong vehicle type | Dispatch error | Match the mode on the manifest before assigning the trip |
| The same rider, again and again | A poor fit with one driver, or abusive behavior | Keep the same driver on recurring trips when it works. If a member is verbally abusive, CareOregon lets you ask not to transport that member. |

Driver continuity helps. South Carolina's draft contract requires its broker to schedule recurring trips for members with a brain injury, chronic mental illness, or a developmental or intellectual disability with the same provider and driver to the extent possible, unless the member filed a complaint about that driver. It asks for similar treatment for members who are frail or on dialysis.

Watch facility complaints too. Indiana requires its broker to build an outreach plan when one facility files more than two complaints within 3 months (FSSA, August 28, 2025). When a clinic complains, call its transportation contact yourself.

## What drivers must do when a rider complains

Brokers set rules for this moment, and breaking them turns one complaint into two.

1. **Never discourage the complaint.** MTM Health's Rhode Island handbook bars drivers from trying to stop members, families, escorts, or medical providers from complaining, including by refusing to give contact information.
2. **Tell the rider how to file it.** CareOregon requires providers to explain the rider's right to file a grievance and how to submit it, and then report it to the brokerage.
3. **Point to the posted procedure.** MTM Health's Virginia handbook requires the broker's toll-free and TTY numbers and the complaint procedures posted inside each vehicle. Texas's NEMT handbook (August 1, 2021) requires a "How is my driving?" sticker with a number the public can call.
4. **Never retaliate.** CareOregon bars retaliation against a rider or anyone who reports a complaint, under any circumstances. MTM Health's Virginia handbook lists the right to complain without fear of penalty among member rights.
5. **Finish the ride.** CareOregon says drivers must complete scheduled rides unless they have a credible fear that they cannot transport the member safely.
6. **Write it down that day.** The driver's signed account is the first thing the broker will ask for.

Phone scripts for these calls are in NEMT customer service.

## When you think the finding is wrong

Disagree with records, in writing, and through the broker's own process.

- **Ask for the finding and its reason in writing.** You cannot answer a finding you have not seen.
- **Send what is new.** A video clip or GPS trail the broker did not have can change the result.
- **Use the broker's complaint channel.** MTM Health's Virginia and Rhode Island handbooks (updated July 2026) invite providers to complain through their field monitor or vendor account manager, the contact page at mtm-inc.net, or a letter to MTM Health, Attention: Quality Management, 16 Hawk Ridge Circle, Lake Saint Louis, MO 63367.
- **Watch the filing window.** Modivcare's Kansas manual (May 2022) lets providers file a grievance within 180 calendar days of an event.
- **Appeal a driver suspension.** CareOregon lets a provider send a written appeal of a driver's suspension or disqualification, which the brokerage reviews before its final decision.
- **Know the state can step in.** Georgia's manual says the state may review and override a broker's resolution of a complaint (section 920.3).

Keep every complaint file. MTM Health's standard agreement requires complete records of your operations for 10 years. Federal rules also give the state, CMS, and the HHS Inspector General the right to audit a health plan's subcontractors for at least 10 years after the contract ends ([42 CFR 438.230](https://www.ecfr.gov/current/title-42/section-438.230)). For the next steps when a broker stops answering, see how to escalate a problem with a NEMT broker.

## Frequently asked questions

### How long do I have to answer a complaint from a NEMT broker?

Check your broker agreement and manual. CareOregon's manual (version 1.3, February 2024) gives providers 3 business days for general grievances and as little as 1 business day for serious ones. MTM Health's standard agreement sends complaints to you for immediate attention and response. If the broker gives no due date, ask for one in writing, because its own deadline to the state can be as short as 5 business days, as in Georgia.

### What proof should I send with my response?

Objective documentation: what was seen, heard, or measured. That means the trip record with scheduled and actual times, GPS data, dash camera video, a narrative signed by the driver, and any police report or insurance record. CareOregon's manual says brokerages treat every grievance as potentially valid and preventable until the documentation proves otherwise, so a statement without records rarely clears you.

### Can a broker give me fewer trips because of complaints?

Yes. Modivcare's Kansas provider manual (updated May 2022) says excessive grievances about a provider may reduce the work it gets or remove it from the network. MTM Health in Virginia assigns infraction points for certain substantiated complaints, and 3 points suspend your access to its trip marketplace. CareOregon's brokerages may limit your trip volume while you work through a corrective action plan.

### Can I stop driving a rider who keeps complaining or is abusive?

You can ask. CareOregon's manual lets a provider ask the brokerage not to send a verbally abusive member again, and the brokerage honors reasonable requests. Drivers still must complete scheduled rides unless they have a credible fear that they cannot transport the member safely. Never retaliate against a rider for complaining, which CareOregon bars under any circumstances.

### What if I think the broker got the finding wrong?

Ask for the finding and its reason in writing, then send any new records. MTM Health's Virginia and Rhode Island handbooks (updated July 2026) let providers complain through their field monitor or vendor account manager, the contact page at mtm-inc.net, or a letter to MTM Health Quality Management. CareOregon allows a written appeal of a driver suspension. In Georgia, the state can review and override a broker's complaint resolution.

### Is a rider complaint the same as an incident report?

No, but one event can be both. Georgia's NEMT manual treats a complaint as dissatisfaction with service and an incident as an event such as an injury, accident, theft, or abuse, which the broker reports to the state at once. MTM Health in Rhode Island treats habitual lateness, no-shows, rudeness, a verbal argument, or a securement problem as a Tier 2 issue that needs a written report within 24 hours.

## Official resources

- [eCFR: 42 CFR 438 subpart F, Medicaid managed care grievance and appeal system](https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-438/subpart-F)
- [CMS: Medicaid Transportation Coverage Guide (SMD 23-006)](https://www.medicaid.gov/federal-policy-guidance/downloads/smd23006.pdf)
- [CareOregon: Transportation Provider Manual (grievances, documentation, response times)](https://careoregon.org/docs/default-source/nemt/nemt-provider-manual.pdf)
- [MTM Health: Virginia provider handbook (performance metrics and infraction points)](https://www.mtm-inc.net/wp-content/uploads/2018/12/VA-Provider-Handbook-2026.pdf)
- [Georgia DCH: NEMT Policies and Procedures, section 920 (complaints and incidents)](https://www.mmis.georgia.gov/portal/Portals/0/StaticContent/Public/ALL/Handbooks/Non-Emergency%20Medical%20Transportation%20(NEMT)%20Q3%20-%20July%202026%2020260918170713.pdf)