NEMT Driver Requirements in 2027: License, Background, and Training

Every Medicaid NEMT driver has to clear a short federal checklist, then a longer one from the state and each broker. The federal part is the same everywhere. The rest changes by state and contract, and a trip by a driver who misses any of it can go unpaid. This page lays out the rules side by side so you can hire to the strictest one you face.

The federal minimum for every NEMT driver

Section 209 of the Consolidated Appropriations Act, 2021 added section 1902(a)(87) to the Social Security Act. It requires every state Medicaid plan to make sure, at a minimum, that for each NEMT provider and individual driver it pays:

1. The provider and driver are not excluded from any federal health care program and are not on the HHS Inspector General’s exclusion list.
2. The driver has a valid driver’s license.
3. The provider has a process to address any violation of a state drug law.
4. The provider has a process to disclose each driver’s driving history, including traffic violations, to the state Medicaid program.

The rule covers rideshare companies and their drivers too. Only public transit authorities are exempt, and states may enforce it through an attestation. Oregon wrote it straight into its rules: drivers must tell the plan or its transportation provider about any state drug law violation and any change in their driving history (OAR 410-141-3925, effective January 1, 2022).

CMS says in its Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023) that federal Medicaid law sets no other basic driver standards. Drivers must hold current licenses for the vehicles they drive, and states may add more, such as a chauffeur’s license, a cap on license points, or a health certification. In a state that runs NEMT through a broker under 42 CFR 440.170(a)(4), the broker must have oversight procedures that keep transport personnel licensed, qualified, competent, and courteous. That is why brokers set most of the rules below.

Two more federal rules apply no matter what your state says:

• Exclusion means no payment. HHS OIG says no federal health care program pays for items or services furnished by an excluded person, and that bar reaches anyone who employs or contracts with that person.
• ADA training and assistance. Every company that runs demand response rides must train staff to proficiency so they operate vehicles and equipment safely and treat riders with disabilities respectfully (49 CFR 37.173). Drivers must help riders with securement, ramps, and lifts when needed or asked, leaving their seat to do it (49 CFR 37.165).

NEMT driver requirements at a glance

The table puts the federal floor next to common state and broker rules as of September 2026. The sections that follow give the exact limits by program.

Requirement	Federal rule	Examples of state rules	Examples of broker rules
Minimum age	None in Medicaid law. 21 for interstate van drivers covered by federal motor carrier rules (49 CFR 391.11).	18 in Virginia, Minnesota, New Jersey, and Texas plans. 21 in Georgia and Louisiana.	21 in MTM Health’s standard agreement and its Virginia and Rhode Island handbooks
Driver’s license	A valid license. A CDL only for vehicles built for 16 or more people or rated 26,001 pounds or more.	Valid for the vehicle class. Held 2 years in Virginia. Unrestricted in Wisconsin, apart from corrected vision.	A current, legible copy in the file (MTM Health). Held 3 or more years (MediTrans).
Driving record	A company process to report each driver’s history to Medicaid	Usually no more than two moving violations or chargeable accidents in 3 years, and no drunk driving conviction in the last 3 to 7 years	A 3-year record pulled every year (MTM Health). A clean record (Modivcare, MediTrans).
Criminal background	None beyond the exclusion rule	Before hire, and yearly in Louisiana. State police or FBI checks in Louisiana, state and national checks in Texas, a state background study in Minnesota.	Before hire and yearly (MTM Health). National checks (SafeRide Health).
Sex offender registry	None	State and national registries before hire and yearly in Texas. A registry check before the first ride in Virginia.	National registry (SafeRide Health). No listing in 10 years (MTM Health in Rhode Island).
Exclusion checks	Not excluded and not on the OIG list	OIG and SAM.gov monthly in Texas. OIG before hire in Oregon.	OIG and the federal excluded parties list (MTM Health)
Drug and alcohol tests	Required by federal rules only for CDL drivers and transit contractors	Five-panel test yearly in Louisiana. A testing program under 49 CFR parts 40 and 655 for Texas plans.	Before hire, after accidents, on suspicion, and at random (MTM Health). Owners too (Verida).
Medical fitness	Only for drivers under federal motor carrier rules	A medical examiner’s certificate in Minnesota. An exam every 2 years for New York ambulettes.	Confirm the driver has no known impairment (MTM Health)
Training	ADA training to proficiency	Before the first ride in most states. See the training section.	PASS, first aid and CPR, and defensive driving (Modivcare). Fraud, waste, and abuse, and HIPAA (MTM Health).

Minimum age and license rules

Program	Minimum age	License rule
Virginia (DMAS, updated May 26, 2026)	18	A valid license for the assigned vehicle, held at least 2 years
MTM Health in Virginia (approved August 10, 2026)	21	Two years of driving experience and a valid license for the vehicle
MTM Health standard agreement (January 1, 2023)	21	A current, valid license for the vehicle type. Drivers must be U.S. citizens or legal resident aliens and able to read, write, and speak English.
MTM Health in Rhode Island (updated July 1, 2026)	21	A current, valid license for the assigned vehicle
Rhode Island (state law, August 1, 2024)	Not set	A Rhode Island operator’s license plus a special license from the Division of Public Utilities and Carriers
Georgia (July 1, 2026)	21	A Georgia license, or one from a bordering state the driver lives in
Louisiana (July 14, 2025)	21	Class D or CDL, plus city or parish permits in Orleans and Jefferson
Minnesota	18	Valid for the class of vehicle driven
Texas health plans	18	Valid
New Jersey mobility assistance vehicles	18	A valid license, shown to state staff on demand
Wisconsin specialized medical vehicles	Not set	Unrestricted, except vision corrected to 20/30 or better with lenses worn while driving
New York upstate Medicaid taxis	Not set	A Class E license
MediTrans (Louisiana)	Louisiana’s 21	A license held 3 or more years
Federal motor carrier rules	21	Only for commercial vans on interstate trips, with a road test and English proficiency

The federal motor carrier rules set aside the transportation of sick and injured persons (49 CFR 390.3T), so ask FMCSA whether they reach your interstate trips before you plan around them.

Virginia shows how the layers stack. The state sets 18, and MTM Health, its broker, sets 21. When a state and a broker disagree, the stricter rule decides who can drive your broker trips.

A commercial driver’s license is rarely needed. Federal rules require one only for a vehicle designed to carry 16 or more people, including the driver, or rated at 26,001 pounds or more (49 CFR 383.5). See do NEMT drivers need a CDL for the details.

Driving record limits

Brokers and states read the same motor vehicle record but draw the line in different places.

Program	What disqualifies a driver
MTM Health standard agreement	A suspended, expired, or revoked license. Three or more at-fault moving violations, or two or more at-fault accidents with injury or damage, in 36 months. Any accident counts as at fault unless the driver proves otherwise with a police report.
Virginia (DMAS and MTM Health)	More than two chargeable accidents or moving violations in 3 years, a DMV point balance below minus 2, or a suspension or revocation for moving violations in the last 5 years
Georgia	A drunk or drugged driving conviction in the 5 years before hire, or a suspended or revoked license in the last 5 years. A child support suspension is excused after release and 90 days in good standing. Two at-fault violations or accidents on NEMT trips remove the driver.
Louisiana	Three or more moving violations, or any drunk driving conviction, in the past 3 years
Minnesota	In the past 3 years, a canceled, revoked, or listed suspension of the license, a conviction for driving without a valid license, or a drunk driving conviction or revocation
Texas health plans	More than one moving violation in any rolling 12 months, on or off the job, or a drunk driving conviction in the 7 years before hire or at any time after
MTM Health in Rhode Island	A suspension or revocation for moving violations in the last 5 years

Pull the record before the first ride and on every renewal. MTM Health’s standard agreement wants a record covering the previous 3 years every year, and Minnesota requires a new one each year. Virginia also requires its broker to use the state DMV’s Driver Alert program, which alerts an enrolled employer the day after a new conviction posts to a driver’s record. Keep police reports for any no-fault accident in the driver’s file.

Criminal background checks

Program	The check	Records that disqualify
MTM Health standard agreement	Before hire and every year	Any sexual or violent crime. A felony in the last 7 years unless MTM’s client approves. A substance abuse conviction in the last 7 years. Current probation, parole, work release, or a pending charge that would disqualify.
Virginia (DMAS and MTM Health)	Virginia State Police or national databases, plus the sex offender registry, before the first ride	A barrier crime under Virginia Code 37.2-314(B)
Georgia	Run by the broker, with the results kept in the driver’s file	Any sexual or violent crime. A felony in the last 5 years needs review by the broker and the state.
Louisiana	Every year, run by the State Police, an agency it authorizes, or the FBI, with results sent straight to the broker	The prohibited crimes in state law, unless pardoned or expunged
Texas health plans	State and national criminal history checks, and state and national sex offender registry checks before hire and every year	Abuse, neglect, or exploitation of children, elders, or people with disabilities at any time. Listed felonies and misdemeanors, or drug offenses, within 7 years. Medicaid fraud.
MTM Health in Rhode Island	State or national check before hire and every year	Any felony in the last 10 years, a sex offender registry listing in the last 10 years, and listed misdemeanors such as theft, assault, and weapons or drug charges
Minnesota	A Department of Human Services background study before the driver starts	A disqualification without a set-aside from the state
Oregon Health Plan rides	A criminal background check under state law before hire	Decided case by case through the plan’s exception process

Texas health plans require providers to report a driver’s new conviction, pending felony charge, or registry listing within 10 business days. Minnesota requires you to stop using a driver the moment the state says the driver is no longer eligible.

When a screening company runs the check, the Fair Credit Reporting Act applies. The FTC says you must give a stand-alone written notice, get written permission, and give a copy of the report and a summary of rights before you turn someone down because of it. For the full process, see NEMT driver background checks. For which crimes bar which drivers, see can a felon be a NEMT driver.

Exclusion checks

Search every driver, and every owner and manager, before hire and every month after. CMS asked states in letter SMDL #09-001 (January 16, 2009) to require providers to check the OIG website monthly, and OIG posts updates to its list every month.

1. Search the OIG exclusion list. Run the search online at exclusions.oig.hhs.gov.
2. Search SAM.gov exclusions. MTM Health’s standard agreement bars anyone on the federal excluded parties list, which now lives in SAM.gov.
3. Search your state’s list, where one exists. Texas health plans also check the state Inspector General’s list, the Texas Comptroller’s debarment list, and the Social Security death file before hire and every year.
4. Save a dated copy of every result in the driver’s file, or use one exclusion screening log for all staff.

Texas health plans must run the OIG and SAM.gov checks every month, and a driver whose checks are past due may not drive. Oregon requires the OIG check before hire.

Drug and alcohol testing

Federal testing rules reach most NEMT drivers only through a contract. Your broker’s testing rule is usually the one that applies.

Rule	Who it covers	What it requires
FMCSA, 49 CFR part 382	Drivers who need a CDL	Full federal testing. The motor carrier exception for sick and injured passengers does not apply to it (49 CFR 382.103).
FTA, 49 CFR part 655	Transit agencies with FTA urban or rural grants, and their contractors	Federal transit testing, which can reach you when you drive for a transit agency
Texas health plans	Every NEMT driver other than rideshare drivers	A testing program that follows 49 CFR parts 40 and 655
MTM Health standard agreement	Drivers and attendants	Tests before hire, after an accident, on reasonable suspicion, and at random at FTA rates. A refusal counts as a positive. No positive test and no treatment for substance abuse in the last 5 years.
Louisiana	Every NEMT driver	A five-panel test every year and on suspicion, with results sent straight to the broker. After a failed test, a substance abuse professional must clear the driver, and three follow-up tests follow in the next 6 months.
MTM Health in Rhode Island	Every driver	A five-panel program with tests before hire, after accidents, and at random for more than 25 percent of drivers each year
Verida, SafeRide Health, Modivcare, MediTrans	Drivers, and owners at Verida	A current or pre-hire drug screen

Virginia’s rules also bar drivers who use alcohol, illegal drugs, or misused prescriptions on duty. MTM Health’s agreement lets a driver work on prescribed medication only with written word from the driver’s doctor that it will not affect driving. See NEMT driver drug testing and the drug and alcohol policy template.

Medical and physical requirements

Most programs do not ask for a medical exam, but a few do.

• Minnesota requires every driver for a NEMT company to be physically qualified under the federal motor carrier standard (49 CFR 391.41) and to carry a valid medical examiner’s certificate while driving. A CDL or a school bus endorsement can stand in for the certificate, and the state can grant a waiver for some conditions.
• New York ambulettes enroll with Medicaid only with a DMV letter of compliance with Article 19-A, the state’s bus driver law, dated on or after the most recent July 1. Under the DMV’s guide (CDL-15, February 2026), each driver has a medical exam before hire and every 2 years, a yearly driving abstract and review, a defensive driving observation, and a road test and written test every 2 years.
• Wisconsin allows a vision restriction only if the driver’s vision is corrected to 20/30 or better.
• MTM Health’s standard agreement treats your request to credential a driver as your statement that the driver has no known physical or mental impairment that would prevent safe driving.

Drivers covered by federal motor carrier rules on interstate trips also need a medical certificate. See rural NEMT for when those rules reach NEMT vans.

Training requirements

Nearly every program wants training finished before the first ride. The courses repeat across programs: passenger assistance and wheelchair securement, first aid and CPR, defensive driving, and HIPAA and fraud awareness.

Program	What drivers complete	When
Virginia (DMAS)	The broker’s driver training program, or an internal program the broker approves in writing	Before transporting any member
MTM Health in Virginia	PASS, HIPAA, defensive driving, and first aid and wheelchair securement where they apply	Before transporting, then refreshed as required
Louisiana	Defensive driving of at least 4 hours, in-person CPR, child passenger restraints, PASS and wheelchair securement, and HIPAA	Before any ride. Defensive driving every 3 years, PASS and securement every 2.
Georgia	Driver training with passenger assistance, safety and sensitivity, and defensive driving, plus first aid and spill kit training	Before driving under the program, with 90 days allowed for drivers new to the training
Oregon Health Plan rides	First aid, CPR, and blood spill procedures, then defensive driving and a passenger service and safety course	First aid and CPR before driving. The courses within 3 months of hire and every 3 years.
Wisconsin	First aid and CPR, care of a rider having a seizure, and every ramp, lift, and restraint you use	Before driving. First aid every 3 years, CPR kept current.
Illinois	A safety training program approved by the state	Before transporting, then every 3 years
MTM Health standard agreement	Your own driver training program, including fraud, waste, and abuse, and HIPAA	Before driving, with records in each driver file
Modivcare	A hands-on PASS wheelchair certificate, first aid and CPR, and defensive driving	Before driving, with first aid and CPR kept valid
Verida	First aid, CPR, defensive driving, passenger sensitivity, spill kits, proper lifting, wheelchair securement, and orientation	Before contracting

Illinois shows what a gap costs. If you cannot show a driver’s certification when the state asks, it recovers every payment for that driver’s rides. For a week-one plan and renewal dates, see NEMT driver training.

Rules for the job itself

Some requirements cover how drivers work, not only who they are. Brokers check these on spot checks and in complaints.

• Photo ID. MTM Health’s standard agreement requires a picture ID badge with the driver’s and company’s names. Virginia accepts a uniform shirt with the company name or its program ID badge.
• No phone while driving. MTM Health bars cell phone use and texting while driving, and headphones except for your two-way radio. Virginia bars phone use while the vehicle is moving.
• No smoking or vaping in the vehicle, and in Virginia not in front of any member.
• Door-to-door help. Virginia drivers get out to open and close doors and give the level of help shown on the trip, from curb to curb to hand to hand.
• Seat belts first. Virginia and MTM Health require every belt buckled and every wheelchair secured before the vehicle moves.
• No money or gifts. Virginia bars drivers from asking for or accepting money, goods, or more business from members.
• Privacy. Keep rider names and health details out of sight of other riders and out of conversation. Virginia and MTM Health both list this as part of HIPAA compliance.

How to qualify a new NEMT driver, step by step

1. Collect the rules. Get the driver section of your state NEMT manual and each broker agreement. Hire to the strictest line in each row above.
2. Screen age and license first. Ask for the license class, expiration date, and how long the driver has held it.
3. Run the exclusion searches. Search the OIG list, SAM.gov, and your state list, and save dated copies.
4. Pull the driving record covering at least the past 3 years.
5. Give the background check notice and get written permission, then run the check the way your program requires, such as a state police check in Virginia or results sent straight to the broker in Louisiana.
6. Search the sex offender registries your program names.
7. Send the driver for a drug test with the panel your broker requires.
8. Get a medical certificate where your state requires one, as Minnesota does.
9. Finish training before the driver rides alone, and file each certificate.
10. Submit the file to each broker and wait for approval. MTM Health allows no driver on its trips until fully credentialed and does not pay for trips by uncredentialed drivers.
11. Recheck on schedule. Run exclusion searches monthly, pull records and background checks yearly, and report new convictions or accidents as each contract requires.

Build each driver’s folder with the driver file checklist, and see how to hire NEMT drivers for sourcing and interviews. Vehicle rules are in NEMT vehicle requirements, and state-specific rules are in our state guides.