Colorado Non-Medical Transportation (NMT) in 2027: Provider Type 36, the Waivers It Covers, and What It Pays

Non-medical transportation is the ride Colorado’s home and community-based services waivers pay for when the trip is not to medical care. It takes a member to an adult day center, a grocery store, a day habilitation program, or a job, so the member can keep living at home.

What NMT covers in Colorado

The Department of Health Care Policy and Financing (HCPF), Colorado’s Medicaid agency, defines NMT in its rule as transportation that lets waiver members reach non-medical community services and supports, as their Person-Centered Support Plan requires, to prevent institutionalization (10 CCR 2505-10, section 8.7535). Six waivers include it, and as of October 2026 so does the State Supported Living Services Program:

• Elderly, Blind, and Disabled (EBD), Community Mental Health Supports (CMHS), Brain Injury (BI), and Complementary and Integrative Health (CIH) waivers. Rides between home and adult day centers, shopping, community activities, and counseling the state plan does not cover.
• Developmental Disabilities (DD) waiver. Rides to day habilitation, prevocational services, and supported employment, including the member’s workplace.
• Supported Living Services (SLS) waiver. Rides to the community and to the same day, prevocational, and employment services.

NMT never replaces NEMT. A waiver member’s ride to a doctor or dialysis is an NEMT trip, which MediDrive books and pays statewide from January 1, 2027, while NMT rides go to the places in the support plan and are billed straight to Health First Colorado. HCPF’s NEMT billing manual says rides to receive waiver services must be NMT, and its October 2026 provider bulletin says NMT providers cannot enroll with MediDrive, which schedules no NMT trips. Behavioral health secure transportation is a third program with its own provider type 97, covered in Colorado BHST. For the general difference between the two kinds of ride, see NEMT vs NMT.

The rule also limits when a trip is billable. Family, neighbors, friends, or community agencies who can drive for free come first, and the case manager must find that free transportation is not available before NMT is used. A bus pass is used only when it costs the same or less than a van trip.

How to enroll as an NMT provider

Colorado enrolls NMT companies in two steps, and the order matters. HCPF’s NMT page warns that an enrollment application filed before step one is denied.

Step 1: Get the Certificate of Compliance

1. Fill out the NMT Provider Intake Checklist (form updated August 2026). It lists your agency, your Medicaid provider ID if you have one, and whether you hold a PUC common carrier or large market taxi permit.
2. Attach the insurance proof. A commercial auto certificate of insurance, or the declarations page for a personal auto policy, naming the Department of Health Care Policy and Financing, 303 E. 17th Ave., Suite 1100, Denver, CO 80203, as certificate holder.
3. Attach every driver’s file. A copy of the Colorado driver’s license, the motor vehicle record, and a Colorado or national criminal history check for each NMT driver.
4. Attach the vehicle inspections for each vehicle that the schedule below requires.
5. Email it all to hcpf_hcbs_nmt@state.co.us. HCPF says it sends the certificate, or a request for more information, within 10 business days.

A company that holds a PUC common carrier permit skips the compliance documents and gives its permit number on the application instead. The rule frees PUC certificate and permit holders from its driver and vehicle requirements (section 8.7535), and state law lets a provider that already meets another state agency’s safety standards show that compliance instead (C.R.S. 25.5-1-802(3)).

Step 2: File the enrollment application

1. Take the training. Complete the HCBS/CFC/MFP Provider Training Course on the CO TRAIN website and pass its quiz with at least 80 percent. Attach the certificate.
2. Gather the general documents. An IRS SS-4 or 147C letter for an EIN enrollment, a W-9 signed within the last six months, and a voided check or a bank letter signed within six months.
3. Apply in the Provider Web Portal. Choose enrollment type Atypical, provider type 36 (Home and Community-Based Services), and the NMT specialty. Enter the certificate number in the Certificate panel and attach the certificate on the Attachments and Fees page.

HCPF’s specialty list, updated August 13, 2026, files NMT as specialty 661 for every waiver that covers it. It is a moderate risk specialty, which means a site visit at your service location, with no application fee and no NPI required. One application covers every waiver, but each service location needs its own. A company already enrolled for other waiver services adds NMT with a maintenance application instead.

Since August 1, 2026, the certificate must also go with every revalidation, which HCPF requires at least every five years. Report a change of ownership, address, phone, or service area in the Provider Portal within 35 calendar days (section 8.7403). See Medicaid revalidation for how the five-year cycle works.

Driver, vehicle, and insurance rules

Drivers

Every NMT driver must be at least 18, have a year of driving experience and a valid Colorado license, give you a Colorado motor vehicle record covering seven years, and pass a Colorado or national criminal history check. The rule disqualifies a driver with:

• A substance abuse conviction in the past seven years.
• A Class 1 or 2 felony in Colorado at any time, or a crime of violence in the past seven years.
• Certain Class 4 felonies in the past four years.
• An unlawful sexual offense against a child at any time.
• A Colorado DUI or excessive alcohol content conviction in the past two years.

Comparable convictions in other states count, and a deferred judgment counts as a conviction while it lasts. For how to run and store these checks, see NEMT driver background checks.

Vehicles

The rule requires a safety inspection covering the items in PUC Rule 6104, on a schedule set by the vehicle’s age: none for a vehicle made in the last five years, every 24 months for one six to ten years old, and every year from eleven years on. Wheelchair vehicles are inspected every year whatever their age. The inspector must be trained and work for an auto repair company authorized to do business in Colorado.

HCPF’s inspection form (March 2022) has a second page for wheelchair vehicles. Among other items, a lift must raise at least 600 pounds, a ramp under 30 inches long must hold 300 pounds and a longer one 600 pounds, and a van 22 feet long or shorter needs a doorway at least 56 inches high. Run our vehicle inspection checklist before the mechanic does.

Insurance and the PUC

The agency carries auto liability of at least $300,000 per person and $600,000 per accident for bodily injury plus $50,000 for property damage, or a $500,000 combined single limit (section 8.7406). HCPF says the agency needs these limits even if it schedules no vehicles of its own. An employee who drives a personal car for the agency carries at least $25,000 and $50,000 for bodily injury and $15,000 for property damage on top of the agency’s policy.

NMT needs no PUC authority. HB21-1206, in effect since June 29, 2021, added C.R.S. 40-10.1-105(1)(l), which takes vehicles used for Medicaid nonmedical transportation and NEMT out of PUC regulation. Private-pay rides for the same riders are another matter, and the Colorado state guide explains which PUC authority applies to them.

What NMT pays

Colorado pays NMT by the one-way trip, at a flat rate for the distance band, with no separate mileage. Each trip is one unit. From July 1, 2026, a trip outside Denver County pays $11.02 to $33.17, depending on the waiver, the vehicle, and the distance:

Distance, one way	Mobility van, EBD, CMHS, BI, CIH	Wheelchair van, EBD, CMHS, BI, CIH	Any vehicle, DD and SLS
Band 1, 0 to 10 miles	$11.02	$13.07	$13.14
Band 2, 11 to 20 miles	$20.19	$24.34	$24.28
Band 3, over 20 miles	$29.95	$33.06	$33.17

Trips in Denver County pay more under Denver’s minimum wage pricing: $11.54, $21.11, and $31.27 for a mobility van, $13.70, $25.46, and $34.53 for a wheelchair van, and $13.76, $25.41, and $34.62 on the DD and SLS waivers. Every July 2026 rate is about 2 percent below the April 1, 2026 rate, so check the effective date on each schedule.

Because band 3 has no top, a 45-mile wheelchair trip on the EBD waiver pays the same $33.06 as a 21-mile trip. Price long rides with that in mind, and compare your cost per trip with Colorado’s NEMT fee schedule, which adds pay per mile.

Codes and modifiers

• EBD, CMHS, BI, and CIH. A0120 for a mobility van and A0130 for a wheelchair van, with the waiver’s modifier (U1 for EBD, UA for CMHS, U6 for BI, U1 and SC for CIH). Add TT for band 2 and TN for band 3. Rides to and from an adult day program add HB. On the CIH waiver, adult day rides in bands 2 and 3 use ST and TU in place of the band modifier and HB.
• DD and SLS. T2003 with U3 for DD or U8 for SLS. Add 22 for band 2 and TF for band 3.
• Denver County. Add HX. HCPF’s Denver pricing appendix says the HX modifier will not appear on the prior authorization, so you add it yourself when the service happens while the member is in the City and County of Denver.
• Taxi trips. On the EBD, CMHS, BI, and CIH waivers, bill A0100. It pays the PUC-approved fare, up to $135 a trip, and only a company with active PUC taxi authority can bill it.

Trip limits, prior authorization, and billing

The case manager writes NMT into the member’s support plan and submits the prior authorization. Before each trip, confirm the member is eligible and the prior authorization is approved, as section 8.7407 requires. You can bill only the units on it.

The rule and the July 2026 rate schedules set these yearly limits:

• EBD, CMHS, BI, and CIH. No more than 104 round trips (208 units) per support plan year unless HCPF authorizes more. Rides to adult day programs do not count toward the limit, and HCPF’s billing manual for the CMHS and EBD waivers describes it as two round trips a week.
• DD. No more than 254 round trips (508 units) a year to day habilitation, prevocational, and supported employment services. For members in comprehensive residential services, rides that come with the residential program are already in the residential rate.
• SLS. The same 254 round trips to day and job programs, plus up to 208 other one-way trips a year, at most four a week, billed with modifier SC at $14.38 a trip for any distance (July 1, 2026).

Section 8.7535 adds four payment rules. You are paid the lower of your billed charge or the authorized unit cost. You cannot charge Medicaid more than you charge the public. Nothing accrues while the member is not in the vehicle. And you cannot bill before you are approved, or for a trip by a driver or vehicle that does not meet the rule. You also cannot collect a copay from the member (section 8.7407).

Claims go to Health First Colorado on the CMS 1500 or its electronic version, one unit per one-way trip. HCPF’s waiver billing manual allows diagnosis code R69 on HCBS claims.

Trip records you must keep

Section 8.7405 asks every waiver provider to document each unit of service with:

• Where the service happened.
• The date, with the start and end time.
• The name of the driver.
• The service given, described to match the NMT definition.
• Any change in the member’s condition or needs, and what you did about it.
• The units billed.

Section 8.130.2 requires the record to be made at the time of the trip and kept for seven years. Each entry is signed and dated by the person who gave the service, and electronic signatures count only if your system stops one person from signing for another and blocks changes to a signed entry. NMT is not one of the services HCPF’s electronic visit verification manual lists, so you do not need an EVV record for these trips as of October 2026. For a record-keeping routine that holds up in an audit, see NEMT record retention.

How to get NMT riders

Case management agencies write each member’s service plan and arrange the services in it, so the agency is your sales call. HCPF’s agency directory names the agency for each county. As of October 2026, it lists Rocky Mountain Human Services in Denver (303-636-5600) and The Resource Exchange in El Paso County (719-380-1100). Tell each agency your service area, your hours, how many wheelchair vans you run, and your phone number.

Adult day centers are the other door, because rides to an adult day program sit outside the yearly trip limit on the EBD, CMHS, BI, and CIH waivers. See adult day center transportation for how those contracts work, and how to become a waiver transportation provider for how other states run the same benefit. Send NMT policy questions to HCPF at hcpf_hcbs_nmt@state.co.us.