California TCP Permit in 2027: When a NEMT Company Needs One for Non-Medical Rides

When a NEMT van needs a TCP permit

The California Public Utilities Commission (CPUC) licenses charter-party carriers: companies paid to carry a person or group, on a prearranged trip, in a vehicle reserved for that party. Their authority carries a TCP number. A Medi-Cal enrollment, a broker contract, or a city business license does not give you that authority.

Vans that carry only medical riders do not need it. Public Utilities Code 5353(i) exempts “vehicles used exclusively to provide medical transportation,” including vehicles that carry developmentally disabled people for regional centers. The CPUC’s exemption page lists the trips that qualify:

• Rides to or from a doctor or dentist appointment.
• Rides to or from hospitals, clinics, or doctors’ offices for any medical care, treatment, or diagnosis.
• Rides for people in wheelchairs or on gurneys, even when a trip has no direct medical purpose, as long as the vehicle is set up and used for medical transport.
• Companions, such as a caregiver or family member riding with the patient.
• Rides for people with developmental disabilities to or from regional centers.

The list names where the rider is going and what help they need. It says nothing about who pays, so a private-pay ride to a clinic is on it like any other clinic ride. What puts the exemption at risk is a paid trip with no medical purpose for a rider who is not in a wheelchair or on a gurney: a grocery run, a church service, a casino outing, or an airport ride.

The exemption also works van by van, never for your whole company. The CPUC says a van used for both medical rides and other paid passenger trips may lose the exemption entirely, including for its medical trips, and that any van used even occasionally for non-medical paid rides should be checked. Vans you keep for medical work only stay exempt, even when another van in your fleet runs charter trips. For borderline cases, the CPUC tells operators to get a formal opinion from its Transportation Licensing staff or a lawyer before relying on the exemption.

A TCP permit covers trips that start and end in California. A paid trip that crosses a state line can also need federal authority, which out-of-state NEMT trips explains.

Which TCP authority fits a NEMT company

The CPUC issues several kinds of charter-party authority. Four matter for a NEMT company adding non-medical rides. If every charter vehicle seats fewer than 16 people, driver included, a P permit covers public charter rides.

Authority	Fits	Vehicles	New fee
P permit	Charter rides for the public	Seating fewer than 16, driver included	$1,000
Z permit	Only contract work for businesses, government agencies, or private schools	No seating limit set	$1,000
B certificate	Charter rides for the public	Any size, with a 125 air mile pickup limit for vehicles seating 10 or fewer	$1,000
A certificate	Charter rides and round-trip sightseeing	Any size, anywhere in California	$1,500

A Z permit suits a company that never offers rides to the public and drives only under contract, for example for a senior living community or a county agency. Once you advertise rides to families or the public, you need a P permit or a certificate. P and Z permits cannot be transferred to a buyer; A and B certificates can, for a $300 fee. The CPUC suggests a B certificate if you might add a vehicle seating 16 or more later.

Charter rides are priced by the mile, by the hour, or both. Public Utilities Code 5401 bars charter-party carriers from charging individual fares, except for round-trip sightseeing and school bus contractors paid by parents. If you want to sell seats one rider at a time, such as a per-seat fare on a weekly shopping shuttle, the CPUC presumes that is passenger stage service, which needs its own certificate and a filed tariff. Charge the person or group who books the van instead, as a charter. For pricing private rides, see private pay NEMT, and for the kinds of trips seniors book, see starting a senior transportation business.

What you need before you apply

The CPUC will not issue authority until these pieces are in place. Under Public Utilities Code 5374, you must show you can follow CHP safety rules, keep a preventive maintenance program, check every driver’s record regularly, train drivers in safety, follow hours-of-service rules, and run a drug and alcohol testing program.

1. Form your business. An LLC or corporation needs its articles and Statement of Information on file with the Secretary of State before it applies.
2. Enroll in the DMV Employer Pull Notice program. File form INF 1104 to open an account and get a requester code. The program then tells you about each enrolled driver’s convictions, accidents, and license suspensions. The CPUC says the contract can take about six weeks, and even an owner who drives alone must enroll. General Order 157-E bars any driver the DMV presumes to be a negligent operator.
3. Set up a drug and alcohol testing program. Drivers of vehicles seating 15 or fewer, including the driver, need pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing under General Order 157-E, modeled on 49 CFR parts 40 and 382. Pre-employment alcohol tests are not required. The CPUC posts a list of testing consultants (August 14, 2026 edition) but endorses none of them. NEMT driver drug testing covers how testing programs work.
4. Line up a vehicle and insurance. You need at least one vehicle before the CPUC issues authority, and the CPUC says insurance costs much more when you apply without one. Your insurer files proof of liability coverage, with the PL-912 endorsement, directly with the CPUC. File workers’ compensation too if you have employees.
5. Book the vehicle inspections. Every van that is not a bus needs a 19-point inspection at a shop licensed by the Bureau of Automotive Repair before it starts service, then every 12 months or 50,000 miles. Keep those records for three years.
6. Get a CHP number if you run a bus. A vehicle built for more than 10 people, driver included, is a bus under Vehicle Code 233. File the CHP 362 Motor Carrier Profile and get a CA number before you apply. The CHP inspects a bus operator’s terminal at least every 13 months, and you pay a $15 inspection fee per bus with your application.

Insurance minimums by seating

General Order 115-G (amended March 21, 2024) sets minimum liability coverage by each vehicle’s seating capacity, driver included, from $750,000 for the smallest vans to $5,000,000 for vehicles seating 16 or more:

Vehicle seating, driver included	Minimum liability coverage
8 or fewer	$750,000
9 to 15	$1,500,000
16 or more	$5,000,000

Ask your agent and the CPUC how a wheelchair van’s seating capacity is counted before you buy the policy. The policy cannot be canceled on less than 30 days’ notice to the CPUC. If coverage lapses, the CPUC suspends your authority, and it revokes it if the gap is not fixed within 90 days. NEMT insurance requirements covers the coverage your Medi-Cal and broker work needs.

How to apply, what it costs, and how long it takes

Applications, insurance filings, vehicle updates, and fee statements all go through the CPUC’s Transportation Carrier Portal (TCPortal).

1. Create a TCPortal account and choose the authority type.
2. Upload your documents: Secretary of State filings, your pull notice requester code, proof of your testing program, and your vehicle list with each van’s DMV commercial registration.
3. Pay the filing fee: $1,000 for a P or Z permit or a B certificate, or $1,500 for an A certificate (Public Utilities Code 5373.1). Fees are not refundable, even if your application is denied.
4. Answer deficiency notices quickly. The CPUC sends a notice listing anything missing, such as the insurance filing, proof of drug testing, or a CHP bus inspection.
5. Start rides only once the permit is issued. Applying and getting a file number does not let you operate.

The CPUC’s August 2026 activity report charts the median time to process new applications it granted, across all carrier types, at about two weeks or less in every month from September 2025 to August 2026. Its licensing page advises against applying until you are sure you can start operating, and paying for insurance, within two to three months.

Rules for every charter ride

General Order 157-E sets the daily rules:

• Prearranged rides only. No street hails, taxi meters, or roof lights.
• A waybill on every ride. It lists your name and TCP number, the plate, the driver, who booked the trip and when, how it was booked, the number of riders, at least one passenger’s name, and the pickup and destination. Paper or electronic is fine.
• Your TCP number on the van. Vehicles built for 15 or fewer people show the full number, with the TCP prefix and the P suffix, on the front and rear bumpers, readable at 50 feet in daylight. Remove it when you sell the van. See NEMT vehicle signage for medical-side markings.
• Your TCP number in every ad, including websites and flyers.
• A current vehicle list. Report each van you add or remove within 10 days.
• Drivers under your control. Every driver is your employee, or works for a subcarrier that holds its own TCP authority.
• Three years of records. Keep waybills, maintenance and safety records, driver records, and complaint records, and answer any written complaint within 15 days.

Keeping exempt vans and permitted vans apart

One non-medical trip in a medical van can cost that van its exemption, so set rules your dispatchers can follow every day:

1. Give every van one role, medical only or charter, and write it in your fleet list.
2. List only charter vans on your TCP vehicle list, with their insurance, inspections, and TCP markings.
3. Block non-medical bookings for medical vans in dispatch, even a one-time favor for a regular rider.
4. Keep a waybill and a separate invoice for every charter ride, priced by the mile or hour.
5. Ask the CPUC first when a van must do both. Email the licensing staff at licensing@cpuc.ca.gov and keep their written answer with your records.

Renewal and good standing

The permit lasts three years (Public Utilities Code 5376). The CPUC’s application instructions (revised August 2018) say it sends a renewal application about 120 days before expiration, and General Order 157-E requires it back at least three months before the permit expires. Renewal costs $100. If it arrives after the permit has expired, you file again as a new applicant and pay the full fee.

You also pay the CPUC’s PUCTRA fee on your revenue. For 2026 it is 0.1% of gross revenue from trips within California, plus a minimum of $10 a quarter or $25 a year (Resolution M-4878). Carriers with $100,000 or less in yearly revenue file once a year by January 15. Everyone else files by January 15, April 15, July 15, and October 15, and late filings carry a 25% penalty. Track charter revenue month by month so each statement is quick to complete.

The CPUC’s August 2026 activity report names lapsed insurance and missing PUCTRA statements among the reasons it suspends or revokes a carrier’s authority. Set calendar reminders for each policy renewal and each fee statement.

The California state guide covers the Medi-Cal side. If your vans also carry regional center clients, the regional center vendor guide explains that work and its own exemption.