NEMT Complaint Log: A Free Printable Record of Complaints, Responses, and Fixes

Complaints about NEMT rides come from every direction: a rider who waited an hour, a dialysis center whose patient came back late, a broker forwarding a grievance, a state reviewer. Each one has a deadline, and each one can count against you on a broker’s scorecard. This log follows every complaint from the day it arrives to the day it closes, with the proof you sent and the fix you made.

How to use this template

1. Log every complaint the day it arrives, from anyone. Georgia’s NEMT manual (July 1, 2026) says complaints may come from members, their representatives, providers, the state, or any person or group. Texas counts complaints from members, attendants, and health care providers. Write down what the person said in their own words.
2. Give each complaint a number. Use the same number on the detail sheet, in the driver’s file, and in the driver training log if it leads to retraining.
3. Decide whether it is also an incident. An injury, crash, assault, abuse allegation, or missing rider needs an incident report and a call to the broker right away. Log the service complaint here as well.
4. Report it to the broker. CareOregon’s manual (version 1.3, February 2024) requires providers to report a rider’s dissatisfaction to the brokerage and to tell the rider how to file a grievance. When the complaint comes from the broker, write its reference number on the detail sheet and its due date in Part 2.
5. Gather the facts before you answer. Pull the trip record, the pickup and drop-off times, GPS data, and any video, and get a written statement signed by the driver. CareOregon asks for objective documentation: what was seen, heard, or measured.
6. Answer by the deadline. CareOregon’s brokerages want your response within 3 business days for general grievances, and within 1 business day for serious ones when they ask. Tell the broker before the deadline if you will be late, and why.
7. Record the finding and the fix. Write whether the complaint was confirmed, what you changed, and when you told the person who complained.
8. Review the month in Part 4. Count complaints by type, driver, and vehicle, and act on repeats before the broker does.

The template

Part 1: Complaint log

No.	Date and time	From	How received	Rider and trip date	Driver and vehicle	Type	What the complaint says

From: rider, family, facility, broker, state, or other. How received: phone, email, broker portal, or in person.

Type key: L, late pickup. A, late to the appointment. N, driver no-show. C, driver conduct or rudeness. V, vehicle cleanliness, heat, or air conditioning. S, securement or level of assistance. W, wrong vehicle type. P, privacy. D, discrimination. B, billing or charges. O, other.

Part 2: Response and resolution

No.	Person called back	Broker told (date, name)	Response due	Response sent	Finding	Fix or corrective action	Closed (date, initials)

Finding: confirmed, not confirmed, or not our trip.

Part 3: Complaint detail sheet (one per complaint you investigate)

Field	Write the entry here in pen
Complaint number
Date and time received, and who took it
Name and phone number of the person complaining
Relationship to the rider (self, family, facility, broker, other)
Rider’s name and broker trip number
Broker’s complaint reference number
Date of service, scheduled pickup time, and actual pickup time
Driver and vehicle
The complaint, in the person’s own words
What the records show (times, GPS, video, trip log)
Driver’s signed statement attached (yes or no)
Other proof attached (police report, photos, insurance record)
Finding and the reason for it
Fix (coaching, retraining, schedule change, vehicle repair, policy change)
Response sent to the broker (date and how)
Answer given to the person who complained (date and how)
Broker’s decision, if it sent one
Date closed and signature

Part 4: Monthly summary

Month	Trips completed	Complaints	Confirmed	Percent confirmed	Top type	Repeat driver or vehicle	Action taken

To get the percent confirmed, divide confirmed complaints by trips completed and multiply by 100. One confirmed complaint in 1,000 trips is 0.1 percent, which already misses MTM Health’s Virginia standard of fewer than 0.1 percent.

Complaint, grievance, appeal, or incident

The words overlap, and each one routes differently. Federal managed care rules define the first two (42 CFR 438.400).

Term	What it means	Where it goes
Grievance (brokers often say complaint)	Dissatisfaction with anything other than a benefit decision, such as the quality of service, a rude driver, or a failure to respect a rider’s rights	This log
Appeal	A request to review an adverse benefit determination, such as a denied or reduced trip	The broker or health plan decides it. Log any part you are asked to answer.
Incident	An injury, accident, theft, property damage, harassment, drug or alcohol use, or abuse (Georgia manual, section 920.9)	An incident report, reported to the broker at once

Georgia’s manual tells its broker to treat complaints and incidents as different things. It lists complaints about the look, cleanliness, or function of a vehicle, sending the wrong type of vehicle, driver behavior, and staff performance. Some service problems are incidents too. MTM Health in Rhode Island treats a verbal argument between a driver and a rider, or a securement problem, as a Tier 2 incident that needs a written report within 24 hours (handbook updated July 1, 2026). When a complaint is also an incident, file both.

Federal grievance rules and how they reach you

Federal Medicaid rules put the grievance system on health plans, not on you directly. You feel it through the deadlines and records that plans and brokers pass down.

• Health plans must run a grievance system. Every managed care organization and prepaid health plan needs one (42 CFR 438.402). A rider may file a grievance at any time, by phone or in writing. The plan must acknowledge each grievance and resolve it within the state’s timeframe, which can never be more than 90 calendar days from receipt (42 CFR 438.406 and 438.408).
• Each grievance record has required fields. It must show a general description of the reason, the date received, the date of each review, the resolution, the date of the resolution, and the name of the person it was filed for (42 CFR 438.416). Plans keep these records at least 10 years and require their subcontractors, such as a broker, to do the same (42 CFR 438.3(u)). Parts 1 to 3 capture every one of those fields.
• NEMT-only plans are exempt. An entity that provides only NEMT under a state contract, paid by capitation or other rates that are not state plan rates, is not subject to the federal grievance rules (42 CFR 438.9 and 438.402(a)). Its complaint rules come from its state contract and the state’s NEMT manual instead. When a health plan hires a broker for rides, the plan stays responsible for its whole state contract and passes duties down in writing (42 CFR 438.230).
• State broker programs must monitor complaints. Under the federal NEMT brokerage option, the broker must have oversight procedures to monitor rider access and complaints (42 CFR 440.170). CMS adds that the state, the broker, and the transportation company should all monitor complaints about courteous drivers and schedulers, clean vehicles, and timely rides (SMD 23-006, September 28, 2023).

In Oregon, where coordinated care organizations run rides, the grievance rules in OAR 410-141-3835 to 410-141-3915 apply to NEMT (OAR 410-141-3920, amended effective July 1, 2026). For how a grievance moves through a plan, see member grievance.

Response deadlines by program

Program	Deadline	Who it binds
CareOregon brokerages (manual version 1.3, February 2024)	Your response within 3 business days for general grievances, or within 1 business day for serious ones when the brokerage asks. Tell it if you will be late, and why.	You
MTM Health standard agreement (January 1, 2023, as Pennsylvania posts it)	Complaints go to you for immediate attention and response, and service problems must be resolved promptly	You
Georgia (Part II NEMT manual, July 1, 2026)	The broker calls the person back within 24 hours, sends the state its findings and corrective actions within 5 business days, and answers the person in writing	The broker, so it needs your side fast
Oregon Health Plan (OAR 410-141-3880)	The plan decides within 5 business days, or sends notice of a delay of up to 30 days from receipt	The plan and its brokerage
Texas Medicaid health plans (NEMT Services Handbook, section 4100, effective August 1, 2021)	98 percent of member complaints resolved within 30 days of receipt	The plan or its broker
Federal limit (42 CFR 438.408)	Each grievance resolved within the state’s timeframe, never more than 90 calendar days	Managed care plans

The broker deadlines are much shorter than the federal limit, and they are the ones you live with. When a broker’s request gives no due date, ask for one, and write it in Part 2.

How complaints count against you

Brokers score complaints, and a few bad weeks can cost trips.

• MTM Health in Virginia (handbook approved August 10, 2026) expects substantiated complaints on fewer than 0.1 percent of completed trips. A complaint about a vehicle safety problem, such as a torn seat belt or broken heat or air conditioning, costs 2 points. So does a substantiated complaint about wheelchair or stretcher securement or a missing required attendant. A substantiated complaint of rider abandonment, including a drop-off at the wrong place or at the wrong level of assistance, costs 3. At 3 points you lose access to the trip marketplace until points come off, at 5 you are suspended 5 days, at 8 you are suspended 10 days and lose recurring trips, and at 10 you are terminated. Points last one year.
• MTM Health in Rhode Island (handbook updated July 1, 2026) rates complaints below 0.09 percent as green, 0.1 to 0.49 percent as yellow, and 0.5 percent or more as red.
• Vehicles. In Texas, a vehicle with two substantiated complaints about cleanliness, temperature, or other problems within 10 days may not be used until the corrective action is documented (section 2620). In Georgia, two or more rider complaints about cleanliness, heat, air conditioning, or other problems within 5 days require an inspection and corrective action, recorded in the vehicle’s permanent record (section 913.2).
• Drivers. CareOregon’s brokerages record each finding to spot patterns by provider and driver, and trends can lead to a driver’s suspension or disqualification or a corrective action plan for your company. In Georgia, after a policy violation, the state may require the broker to remove a provider or driver right away for an investigation or for retraining that fits the complaint. See corrective action plan.
• The state itself. Minnesota may inspect a special transportation vehicle when it receives a complaint about it, and it records the corrective action the provider must take (Rules 8840.5700).

Minnesota also requires every provider of special transportation service to keep a record of each complaint, report, or allegation of misconduct against a driver or attendant. The record holds a copy or detailed summary of the complaint, a summary of your investigation, and any action taken, in the driver’s file or a separate file (Rules 8840.5900, subpart 17). Part 3 is built for that. For late pickups, the most direct fix is in improving on-time performance.

What drivers must do when a rider complains

1. Never discourage the complaint. MTM Health’s Rhode Island handbook bars drivers from trying to stop members, families, attendants, escorts, or medical providers from complaining, including by refusing to give contact information.
2. Tell the rider how to file it. CareOregon requires providers to explain the rider’s right to file a grievance and how to submit it, then report it to the brokerage.
3. Point to the posted procedure. Virginia requires each vehicle to display the vehicle license number, the broker’s toll-free and TTY numbers, and the complaint procedure inside, with a written copy for riders who ask (DMAS, updated May 26, 2026). Texas requires a “How is my driving?” sticker with a phone number the public can use to report driver behavior (section 2620).
4. Never retaliate. CareOregon bars retaliation against a rider or anyone who reports a complaint under any circumstances. MTM Health’s Virginia handbook lists the right to complain without fear of penalty or retaliation among member rights.
5. Write it down the same day. The driver’s own account, signed and dated, is the first thing a broker will ask for.

Scripts for these calls are in NEMT customer service, and the broker side of the process is in how to handle rider complaints filed with a broker.

Privacy and discrimination complaints

Two federal rules add their own record requirements.

• Privacy. A HIPAA covered entity must give people a way to complain about its privacy policies or its compliance with them, and must document every complaint and how it was resolved (45 CFR 164.530). Keep that documentation 6 years. See HIPAA for NEMT providers for whether the rules cover your company.
• Discrimination. Section 1557’s rule covers health programs that receive HHS funding directly or indirectly (45 CFR 92.2). As of September 2026, a covered entity with 15 or more employees must have written grievance procedures for discrimination complaints (45 CFR 92.8). It keeps each record at least 3 years from resolution, with the grievance, the complainant’s name and contact details, the alleged action and basis, the dates filed and resolved, and the resolution. It must also keep the complainant’s identity confidential except as the law or an investigation requires.

Mark these types P or D in Part 1, and keep their detail sheets in a locked file.

When you are the one complaining

Log complaints you make to a broker too, with the date, who you told, and the answer. MTM Health’s Virginia and Rhode Island handbooks (updated July 2026) invite providers to complain through their field monitor or vendor account manager, the contact page at mtm-inc.net, or a letter to MTM Health, Attention: Quality Management, 16 Hawk Ridge Circle, Lake Saint Louis, MO 63367.

How long to keep complaint records

Rule	How long
MTM Health standard agreement (complete records of your operations)	10 years, or longer if a law or client requires it
Managed care plans and their subcontractors (42 CFR 438.3(u))	At least 10 years
Oregon managed care grievance logs (OAR 410-141-3915, effective January 1, 2025)	10 years
HIPAA complaints and their resolution, for covered entities	6 years
Discrimination grievances (45 CFR 92.8)	At least 3 years from resolution
Minnesota Rules 8840.6100 (special transportation records)	At least 3 years

The longest rule that applies to you wins. For every record type in one table, see NEMT record retention.