Hiring a NEMT Consultant in 2027: What They Can and Cannot Do for You

A consultant or startup coach sells time and know-how, and a new owner is often short on both. What no one can sell you is the set of approvals that lets a NEMT company get paid. The state, the IRS, CMS, and each broker grant those to your company directly, on your signature.

What a NEMT consultant can and cannot do

Good help is concrete. A consultant can save you weeks on work like this:

• Reading the rules with you. Your state’s provider manual, each broker’s handbook, and any city or county permit rules.
• Putting the enrollment file together. Owner disclosures, vehicle and driver documents, insurance certificates, and the order to file them in.
• Writing your policies. Drug and alcohol testing, HIPAA, vehicle inspection, complaints, and driver training records.
• Getting you ready for a site visit, if your state makes one before enrollment. See Medicaid site visits.
• Setting up records. Trip logs, driver files, and a simple budget.

What a consultant cannot do is just as clear:

• Promise you trips. Brokers choose who joins and how much work each provider gets. MTM Health’s standard provider agreement, in the January 1, 2023 version Pennsylvania posts, says it does not guarantee any minimum number of trips and that trip volume is at MTM’s sole discretion. MTM Health’s provider page asks companies to apply on its own site and says it will reach out if it has a need in your area.
• Sign for you. The IRS says the responsible party on an EIN is the person who ultimately owns or controls the company. A third party can apply for you only with signed authorization, and that authority ends once the EIN is assigned. Medicaid enrollment and broker agreements are signed by your company too.
• Get around a closed door. States can pause new enrollments. The Ohio Department of Medicaid, for example, stopped accepting new enrollments for several provider types, including waivered services organizations and individuals, from May 14 to November 14, 2026 unless CMS extends it, and denied applications filed before May 14 that it had not yet processed.

What startup filings cost when you do them yourself

Most of a NEMT startup is filing forms with agencies that charge little or nothing. The fees below are as of October 2026. A consultant who files for you pays the same fees and adds a charge of its own.

Step	Fee	Where you do it
EIN for your company	$0	IRS online application
NPI for your company	$0	NPPES, run by CMS
SAM.gov registration, for federal contracts	$0	SAM.gov
Medicaid enrollment	$750 federal application fee in 2026, where your state collects it	Your state Medicaid agency
Broker-required training in Virginia	$0 from MTM Health	MTM Health
Business mentoring	$0 from SCORE	SBA resource partners

A few notes on each:

• EIN. The IRS says you never have to pay a fee for an EIN and warns about websites that charge for one (page updated August 19, 2026).
• NPI. CMS says the NPI is free of charge. After you have it, you report changes to NPPES within 30 days (45 CFR 162.410). See how to get an NPI number.
• SAM.gov. There is no charge to get a Unique Entity ID or to register and keep your registration. APEX Accelerators give free help completing it.
• Medicaid application fee. The fee is $750 for applications filed in 2026. Where it applies, the state collects it before signing your provider agreement, unless you are already enrolled in Medicare or another state’s Medicaid or CHIP program, or already paid the fee to one of them (42 CFR 455.460). See our report on the 2026 fee.
• Training. MTM Health’s Virginia handbook (approved August 10, 2026) says the required state and broker training comes at no cost to the provider. Check what your own broker provides before you pay for a course.
• Mentoring. SBA says SCORE mentors give advice at no cost, and Small Business Development Centers offer counseling and training.

Your state charges its own fees to form an LLC and may charge for state permits. The startup cost guide prices those.

There is no national NEMT license or certification

No federal agency licenses or certifies NEMT companies. CMS’s Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023) lists the federal minimums: drivers and companies not excluded from federal health programs, a valid license for each driver, and company processes for drug law violations and for reporting each driver’s driving history to the state. Beyond those, it says, driver and vehicle standards come from the states. The approvals that matter come from your state, your city or county, and each broker. NEMT license requirements walks through each layer, and how to get NEMT certified explains which certificates count.

The same goes for the person selling help. The FTC’s guidance on coaching programs (August 2022) says there is no licensing requirement to become a business coach, and that scammers often lie about their credentials. A title like “certified NEMT consultant” tells you nothing until you know who certified it and what they checked.

When a startup package is a business opportunity under FTC rules

Some consultants sell a package instead of hours: a “business in a box” with forms, training, and a promise of work. The FTC Business Opportunity Rule (16 CFR part 437) can cover that package. A sale is a business opportunity when all three are true (437.1(c)):

1. The seller asks you to start a new business.
2. You make a required payment, meaning anything you must pay the seller or an affiliate to get or start the business, directly or through someone else (437.1(p)). The definition sets no minimum amount.
3. The seller says it, or someone it names, will provide locations, outlets, accounts, or customers, or buy back what you produce.

“Providing accounts or customers” reaches further than it sounds. It includes handing you existing or potential customers, recommending or requiring a lead generating company, giving you a list of them, or otherwise helping you get your own accounts (437.1(m)). A package that promises to line up broker contracts, facility accounts, or riders can fit. Advertising and general advice about business development and training do not.

What the seller must give you

If the rule applies, the seller must give you a one-page disclosure document in the FTC’s set format at least 7 calendar days before you sign any contract or pay anything (437.2 and 437.3). It tells you:

• Legal actions: any civil or criminal action for misrepresentation, fraud, securities violations, or unfair or deceptive practices in the past 10 years against the seller, its affiliates, its officers and directors, or its sales managers, listed in an attachment.
• Refunds: whether the seller offers a refund or cancellation, with the full terms attached.
• Earnings: whether the seller or its salesperson has said what buyers can earn.
• References: the name, state, and phone number of at least 10 recent buyers nearest you, or every buyer from the past three years.

Any earnings claim needs a reasonable basis, written proof you can ask to see, and a separate statement titled EARNINGS CLAIM STATEMENT REQUIRED BY LAW. It gives the dates of the results and the number and percentage of buyers who reached them (437.4). “Earn your investment back within one year” counts as an earnings claim (437.1(f)), so a promise of a set monthly income from one van does too.

The rule also bans specific practices (437.6). A seller may not misrepresent how likely it is to find you customers, claim a government agency endorses or is connected to the offer, make you waive reliance on its disclosures, refuse a refund it promised, or hide that it paid a “successful buyer” it points you to. States can add their own business opportunity laws on top (437.9(b)), and the FTC’s form tells buyers they can also contact their state attorney general.

Franchise or business opportunity

A package that also licenses you a brand name is usually a franchise instead. Under the Franchise Rule, a franchise has three parts: you operate under the seller’s trademark, the seller exerts significant control or gives significant help with how you operate, and you make a required payment (16 CFR 436.1(h)). Franchises get a longer disclosure document and a 14-day wait, covered in NEMT franchise. The Business Opportunity Rule steps back for franchises the Franchise Rule covers, except those exempt from it because their required payments are very small or nothing is in writing (437.8).

Promises that should end the call

• “We guarantee broker contracts” or “we have trips waiting.” Brokers assign trips, not consultants. Under the FTC rule, misrepresenting the chance of finding you customers is a violation (437.6(j)).
• “You need our national NEMT license.” There is none. Ask which state, county, or broker requires the thing being sold.
• “We are approved by Medicaid,” or Medicaid and Medicare names and logos on the sales page. Federal law bars using words like Medicaid, Medicare, CMS, or HHS in an ad or solicitation in a way that falsely suggests government approval (42 U.S.C. 1320b-10).
• “Guaranteed monthly income from one van.” An income promise needs written proof and, under the business opportunity rule, an earnings claim statement. The FTC’s coaching guidance says promises of guaranteed income or a “proven system” are signs of a likely scam.
• “Pay us a share of your Medicaid payments and we will bill under our number.” Medicaid pays the provider that gave the ride. A billing agent may receive payment in your name only when its pay is tied to the cost of billing, is not a percentage of what is billed or collected, and does not depend on collection (42 CFR 447.10).
• “We send you riders for a fee per rider.” Pay that rises with Medicaid referrals can be a kickback. See anti-kickback rules for NEMT.
• “We will find you grant money.” See grants for NEMT businesses for which programs are real.
• “Sign today or lose your spot.” If the package is a business opportunity, the seller must wait at least 7 days after giving you the disclosure. The FTC advises taking your time and talking to someone you trust before paying.

Check the consultant like Medicaid will

A consultant who runs your company day to day can become part of your Medicaid file. Federal rules define a managing employee as a general manager, business manager, administrator, director, or anyone else who exercises operational or managerial control over, or conducts, the day-to-day operation, under contract or another arrangement, whether or not on your payroll (42 CFR 455.101). You disclose each managing employee’s name, address, date of birth, and Social Security number to your state Medicaid agency (42 CFR 455.104).

The state checks managing employees against federal exclusion lists, including the OIG’s List of Excluded Individuals and Entities, at least monthly (42 CFR 455.436). The OIG says an exclusion bars federal program payment for all administrative and management services an excluded person provides, no matter who submits the claims (exclusions FAQ, updated April 30, 2026). Before you sign:

1. Search the consultant and their company on the OIG exclusion list, and save a screenshot.
2. Search their name with words like complaint or scam, and check with your state attorney general, as the FTC suggests.
3. Call past clients in your state, and ask how long their enrollment and broker credentialing took.
4. Ask for the FTC disclosure document if the package promises customers or contracts.

Questions to ask and terms to get in writing

A short written agreement protects both sides. Put these terms in it:

1. The deliverables. List each document or task, such as a filled-in enrollment packet or a set of policies, with a date for each.
2. The fee and what it pays for. A flat fee for listed work is easy to check. Tie payments to delivered work, not to approvals the consultant cannot control.
3. The refund policy. Write down when you get money back and how much. Under the FTC rule, a business opportunity seller must attach its refund terms to the disclosure.
4. Who owns the filings and accounts. Your company owns its EIN, NPI, Medicaid enrollment, state permits, and broker agreements. The IRS mails the EIN notice to your company even when a third party applies, and the third party’s authority ends when the EIN is assigned. Open every portal login in your company’s name, and keep the passwords yourself.
5. Who signs. You or an officer of your company signs every application, disclosure, and attestation.
6. What happens to your records when the contract ends: every document comes back to you, and the consultant keeps no access to your accounts.
7. Confidentiality. The consultant keeps your business and rider information private and returns it at the end.

Then do the rest yourself or with free help. The startup guide covers each step in order, and NEMT startup mistakes shows where new owners lose the most money. If a seller breaks its promises, report it at ReportFraud.ftc.gov and to the attorney general in your state and the seller’s state.