# NEMT Fleet Safety Program in 2027: A Written Plan for 1 to 10 Vans

Canonical URL: https://nemtguide.com/guides/nemt-fleet-safety-program/ · Updated 2026-10-02

A fleet safety program is your written plan for safe driving: who may drive, how often you check driving records, how drivers are trained and coached, how vans are inspected, and how every crash is reviewed. For one to ten vans it fits on a few pages. TennCare, MTM Health, and Florida's coordinated transportation system already require parts of it in their contracts and rules.

- OSHA, NHTSA, and an employer safety group set out 10 steps for a driver safety program, and they fit a one-van company as well as a large fleet.
- Write down which driving records disqualify a driver, pull every record at hire and at least yearly, and note who reviewed it and when.
- Hold a short safety meeting every month and rotate the risks NEMT drivers face: backing, lifts, securement, phones, weather, and fatigue.
- Review every crash and near miss, whoever was at fault, and fix the cause instead of telling the driver to be careful.
- Pennsylvania cuts workers' comp premiums 5 percent for a certified safety committee that meets at least monthly.

A fleet safety program is the part of your manual about driving: who may drive your vans, how you keep checking them, and what you do after something goes wrong. A company with one to ten vans can run it in a few pages and an hour a month.

## What a fleet safety program is, and why a small company needs one

OSHA, NHTSA, and the Network of Employers for Traffic Safety wrote the basic outline in their joint Guidelines for Employers to Reduce Motor Vehicle Crashes. They say the 10 steps work for any organization, whatever its size or number of vehicles:

1. Senior management commitment and employee involvement
2. Written policies and procedures
3. Driver agreements
4. Motor vehicle record checks
5. Crash reporting and investigation
6. Vehicle selection, maintenance, and inspection
7. A disciplinary action system
8. A reward and incentive program
9. Driver training and communication
10. Regulatory compliance

The reason is the road. The Bureau of Labor Statistics counted 5,070 fatal work injuries in 2024, and transportation incidents were the most common cause, at 38.2 percent (1,937 deaths, released February 19, 2026). Roadway crashes involving motor vehicles alone killed 1,146 workers that year. NIOSH calls motor vehicle crashes the leading cause of work-related deaths in the United States. Your drivers spend their whole shift on the road with riders who cannot brace for a crash.

The guidelines are advice, not a regulation. They note that OSHA's General Duty Clause still requires employers to keep the workplace free from recognized hazards likely to cause death or serious harm.

## Who already requires parts of it

You may be following half a program already, because brokers and states write the pieces into contracts. These are current as of October 2026:

- **TennCare (Tennessee).** The contract with its health plans (Amendment 25, July 1, 2026) requires at least 32 hours of driver training before the first ride and 15 hours every year, covering defensive driving, risk management, emergency evacuation, and annual road tests. Drivers need a physical exam at least as thorough as the federal commercial driver exam and an acceptable driving record before the first ride, the record again every year, and random drug and alcohol tests covering at least 20 percent of drivers each calendar year. Drivers must report any moving violation or suspension right away.
- **MTM Health.** Its standard provider agreement (Pennsylvania copy, January 1, 2023) requires a driver orientation and training program, a three-year driving record in each driver file updated every year, and drug and alcohol testing before hire, after accidents, on suspicion, and at random.
- **Virginia.** The Medicaid program's requirements (updated May 26, 2026) bar drivers with more than two chargeable accidents or moving violations in the last three years, or a license suspension or revocation for moving violations in the last five. The broker must use the DMV's Driver Alert monitoring program.
- **Florida.** Rule 41-2.006 requires operators paid with transportation disadvantaged funds to follow Rule 14-90. That rule requires each bus transit system to adopt a written System Safety Program Plan. The term covers community transportation coordinators and private operators with recurring contracts, and the vans and sedans they run count as buses.
- **CareOregon.** Its provider manual (version 1.3, February 2024) strongly recommends inward and outward facing dash cameras, and says footage can go to the broker as evidence when it reviews a complaint or incident.

Ask each broker you drive for to send its driver and vehicle standards in writing. Build your program to the strictest one, and it covers the rest.

## What to put in the written program

Keep each part to a page or less. Date it, have each driver sign that they read it, and review it every year. The [policies and procedures guide](https://nemtguide.com/guides/nemt-policies-and-procedures/) shows how it fits with the rest of your manual.

1. **Commitment and who is in charge.** A short statement signed by the owner, naming the person who runs the program, even if that is you.
2. **Who may drive.** License class, driving record limits, background check, and drug testing. The [background check guide](https://nemtguide.com/guides/nemt-driver-background-check/) and [drug testing guide](https://nemtguide.com/guides/nemt-driver-drug-testing/) cover the screening.
3. **The driver agreement.** Each driver signs that they understand your rules on phones, seat belts, speed, and reporting. The OSHA guidelines make this a separate step, and TennCare requires drivers to report new moving violations and suspensions right away.
4. **Training and road tests.** What each driver learns before the first ride and every year after, and a road test in the vehicle type they will drive. See the [driver training guide](https://nemtguide.com/guides/nemt-driver-training/), the defensive driving guide, and the [road test form](https://nemtguide.com/templates/driver-road-test-form/).
5. **Vehicle checks.** A daily [inspection checklist](https://nemtguide.com/templates/nemt-vehicle-inspection-checklist/), a maintenance schedule, and, as the OSHA guidelines recommend, a mechanic's inspection at least once a year filed with each van's records.
6. **Crash and near miss reporting.** Every crash is reported to you the same day and reviewed, whatever its size.
7. **Coaching, discipline, and recognition.** How you act on telematics data, violations, and preventable crashes, and how you recognize safe driving.
8. **Records.** Where each driver file and vehicle file lives and how long you keep it.

## Driving records: set limits and check them every year

Write down which records disqualify a driver before you pull anyone's. The federal rule for commercial motor vehicle carriers is a good routine for any fleet. At least every 12 months, the carrier gets a record covering the past 12 months from each licensing agency where the driver held a license or permit to drive commercial vehicles, reviews it, and gives great weight to speeding, reckless driving, and driving under the influence. It files the record with a note of who reviewed it and the date (49 CFR 391.25). The federal rule binds you only when a van counts as a commercial motor vehicle: it runs interstate trips and either is rated at 10,001 pounds or more or is built or used to carry more than 8 people, driver included, for pay (49 CFR 390.5T). For any other van, treat it as the model.

If you need a starting point, borrow TennCare's limits (Attachment XI, A.8.3.13). Its record covers every state the driver has lived in. A conviction for a major violation, such as drunk driving, disqualifies a driver for 10 years. A conviction for reckless driving, leaving the scene of an injury or fatal crash, or a felony involving a vehicle disqualifies for 36 months. A driver may have at most two minor violations, such as speeding, in 12 months, and at most one at-fault crash in 36 months, never paired with a minor violation in that time. The [Tennessee guide](https://nemtguide.com/states/tennessee/) covers the rest of TennCare's driver rules.

Records change between yearly pulls, so ask drivers to tell you about any ticket the same day, and use a state monitoring program where one exists. Virginia's Driver Alert sends an employer notice the day after a conviction posts. The [motor vehicle record guide](https://nemtguide.com/glossary/motor-vehicle-record/) covers how to order records, what each state charges, and how Driver Alert works. Use the annual driving record review form to log each review.

## How to run a monthly safety meeting

A monthly meeting keeps the program alive. Fifteen to twenty minutes is enough: one risk, one recent event or near miss from your own vans, and one thing everyone will do differently. Keep a sign-in sheet and a few lines of notes, because a broker or insurer may ask for proof.

Pennsylvania's rules for certified workplace safety committees show what a formal version looks like. A quorum meets at least monthly, with a written agenda, an attendance list, and minutes (34 Pa. Code 129.1005). A certified committee earns a 5 percent workers' comp premium reduction, renewable for four more years (129.1007 and 129.1008). It needs at least two employer and two employee representatives and six full months of meetings before you apply (129.1003). The [insurance cost guide](https://nemtguide.com/guides/nemt-insurance-cost/) covers other premium credits.

Rotate the topics so each risk comes up at least once a year. A starting fact for each:

- **Backing and parking.** Vans rated 10,000 pounds or less built on or after May 1, 2018 must display a rearview image (FMVSS 111). Heavier cutaways may not, so walk around before backing.
- **Lifts and ramps.** A lift built to FMVSS 403 has interlocks that keep the van from moving unless the lift is stowed and keep the lift from working until the van is in park or held by its brakes. Never bypass one. Log daily checks in the [lift inspection log](https://nemtguide.com/templates/wheelchair-lift-inspection-log/).
- **Wheelchair securement.** A secured chair may move no more than 2 inches in any direction (49 CFR 38.23). See the [securement guide](https://nemtguide.com/guides/wheelchair-securement/).
- **Phones and distraction.** NHTSA counts 3,208 people killed in 2024 in crashes involving distracted drivers. Florida's safety plans must ban personal phone use while the vehicle is moving. See the [driver phone policy guide](https://nemtguide.com/guides/nemt-driver-phone-policy/).
- **Weather.** FHWA says about 12 percent of crashes, nearly 745,000 a year, are weather related, and over 77 percent of those happen in rain or mist (2019 to 2023 averages). The [winter vehicle checklist](https://nemtguide.com/templates/winter-vehicle-checklist/) covers the cold months.
- **Fatigue.** NHTSA estimates drowsy drivers were involved in 91,000 police-reported crashes in 2017, most often between midnight and 6 a.m. or in the late afternoon, and counts 644 deaths in drowsy driving crashes in 2024. See [driver schedules](https://nemtguide.com/guides/nemt-driver-schedules/).
- **Getting riders out.** Run the [wheelchair van evacuation drill](https://nemtguide.com/guides/wheelchair-van-evacuation/) once a year as a meeting.
- **Seat belts.** OSHA calls following a seat belt policy a leading indicator of fewer driving injuries and deaths.

The driver safety meeting topics template lays these out as a 12-month calendar with a sign-in sheet.

## How to review every crash and near miss

The OSHA guidelines say every crash, however small, should be reported to the supervisor as soon as feasible and reviewed for cause and preventability, regardless of fault. OSHA's incident investigation guide (December 2015) adds close calls, the near misses that would have hurt someone under slightly different conditions. Its four steps:

1. **Preserve and document the scene.** Photos, dash camera clips, telematics data, and the trip record.
2. **Collect information.** Talk to the driver and witnesses soon, to find facts, not fault.
3. **Find the root causes.** Keep asking why. OSHA says a conclusion such as "worker was careless" does not get at the root cause.
4. **Fix them.** OSHA warns that weak fixes, like telling workers to remember a rule, rarely prevent the next one.

Look past the driver to the schedule and the van: a run with no slack, a dispatcher calling mid-trip, or a lift nobody checked. OSHA's motor vehicle guidance names the first two, saying workloads should let drivers keep a safe speed and that dispatching and rerouting can distract drivers.

Florida's Rule 14-90 is a useful model for the paperwork. It calls for investigating any event that causes a death, injures two or more people who need medical care away from the scene, damages property, or forces an evacuation for safety. Each investigation ends in a written report with causes and a corrective action plan with a schedule, and the records are kept four years. Record your findings on the [accident review form](https://nemtguide.com/templates/accident-review-form/), and see the [vehicle accident guide](https://nemtguide.com/guides/nemt-vehicle-accident/) for the first hours after a crash.

## Coaching with telematics and cameras

Data only helps when someone talks to the driver about it. OSHA's employer guidance cites a NIOSH study in which an in-vehicle monitoring system with in-cab feedback, plus supervisor coaching using driver-facing and road-facing video, produced a significant drop in risky driving and in driving without a seat belt, compared with a control group of drivers.

A routine that fits a small fleet:

1. **Pull a weekly report** of hard braking, speeding, and unbelted time for each driver.
2. **Coach in private** within a few days, with the clip or the data on screen.
3. **Thank the drivers** with clean weeks, by name.
4. **Explain the system first.** OSHA advises telling drivers why it is being installed and how it will work.

The [telematics glossary](https://nemtguide.com/glossary/telematics/) covers what the devices record and the driver privacy limits, and the [dash camera guide](https://nemtguide.com/guides/nemt-dash-cameras/) covers where cameras are required and the recording consent rules.

## Discipline and rewards that do not hide crashes

The OSHA guidelines say most corrective action programs assign points for moving violations, with progressive discipline for a pattern of violations or preventable crashes and a set action when a driver reaches a set number in a set period. They pair it with recognition and rewards for safe driving, and say results improve when driving is part of each employee's job review.

Rewards can backfire if drivers stop reporting. Federal rules require a reasonable procedure for reporting work injuries, one that does not deter a reasonable employee, and bar retaliation against anyone who reports (29 CFR 1904.35). OSHA's October 11, 2018 memo says rewards for reporting near misses and hazards are always allowed, and rewards based on low injury numbers are allowed if they do not discourage reporting. It adds that a written no-retaliation statement alone may not be enough. Reward the report, not the silence.

## What insurers will see

The OSHA and NHTSA guidelines say following their 10 steps can help keep your motor vehicle insurance costs as low as possible. Ask for your loss runs, the claims history a new insurer uses to underwrite you, before every renewal. Florida requires insurers to send one within 15 calendar days of a written request, covering up to five years, with one free statement a year (Florida Statutes 627.444, 2026). Illinois requires covered insurers to send loss information for the three previous policy years within 30 days of a request (215 ILCS 5/143.10a). Bring the loss runs and your written program to your agent together. The [workers' comp guide](https://nemtguide.com/guides/workers-comp-for-nemt/) covers the driver injury side.

## Start your program this month

1. **Write and sign** a one-page safety commitment that names who runs the program.
2. **Collect each broker's standards** in writing and adopt the strictest driving record limits.
3. **Pull every driver's record now,** log the review, and put the next one on the calendar.
4. **Have every driver sign** the driver agreement and your phone and seat belt rules.
5. **Schedule twelve monthly meetings** and pick each month's topic.
6. **Set up crash and near miss reporting** with the [incident report form](https://nemtguide.com/templates/nemt-incident-report-form/) and review each one within a week.
7. **Put each van on a maintenance schedule,** with a mechanic's inspection at least once a year.
8. **Review the whole program every year,** and after any serious crash.

## Frequently asked questions

### Does a small NEMT company legally need a written fleet safety program?

OSHA's motor vehicle guidelines say they are advice and create no new legal duties, though OSHA's General Duty Clause still requires a workplace free from recognized hazards. Contracts and state rules require the parts: TennCare's health plans require driver training, road tests, and yearly driving records, and Florida requires operators paid with transportation disadvantaged funds to follow Rule 14-90, which calls for a written System Safety Program Plan.

### How often should I check my drivers' driving records?

At hire and at least every 12 months. Federal rules for commercial motor vehicle carriers require a yearly record pull and review, with a note of who reviewed it and when (49 CFR 391.25). TennCare requires a record before the first ride and every year after, and MTM Health's standard agreement wants a three-year record updated annually. A state monitoring program, such as Virginia's Driver Alert, tells you about new convictions in between.

### What should a monthly safety meeting cover?

One risk, one recent event, and one action. Rotate the risks that hurt NEMT riders and drivers: backing, lifts and ramps, wheelchair securement, phones, weather, fatigue, and evacuation. Keep a sign-in sheet and short notes. Pennsylvania's certified safety committees must keep a written agenda, an attendance list, and minutes for every meeting.

### Can I pay drivers a bonus for going a year without a crash?

Yes, if it does not keep drivers from reporting. OSHA's October 11, 2018 memo says incentive programs based on injury rates are allowed if they are not run in a way that discourages reporting, and that rewarding drivers who report near misses or hazards is always allowed. Federal rules bar retaliation against an employee who reports a work injury (29 CFR 1904.35).

### Will a fleet safety program lower my insurance?

It can. Pennsylvania gives a 5 percent workers' comp discount to employers with a certified workplace safety committee. For auto coverage, the OSHA and NHTSA guidelines say following their 10 steps can help keep motor vehicle insurance costs as low as possible. Bring your written program and your loss runs to every renewal.

### Do I have to tell drivers about telematics and cameras?

OSHA advises it. Its guidance for employers says to explain to workers why an in-vehicle monitoring system is being put in place and how it will work. Audio is stricter than video. Federal law allows recording a conversation when one person in it agrees (18 U.S.C. 2511), but Washington, for one, requires the consent of everyone in a private conversation (RCW 9.73.030).

## Official resources

- [OSHA, NETS, and NHTSA: Guidelines for Employers to Reduce Motor Vehicle Crashes](https://www.osha.gov/sites/default/files/publications/motor_vehicle_guide.pdf)
- [OSHA: Motor vehicle safety guidance for employers](https://www.osha.gov/motor-vehicle-safety/employers)
- [OSHA: Incident investigation guide for employers](https://www.osha.gov/sites/default/files/IncInvGuide4Empl_Dec2015.pdf)
- [CDC NIOSH: Motor Vehicle Safety at Work](https://www.cdc.gov/niosh/motor-vehicle/)
- [Virginia DMV: Driver Alert driving record monitoring](https://www.dmv.virginia.gov/records/voluntary)
- [Pennsylvania Code: Workplace safety committee rules (34 Pa. Code Chapter 129, Subchapter J)](https://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/034/chapter129/subchapJtoc.html)