NEMT Compliance Calendar for 2027: Monthly, Yearly, and Renewal Dates

A NEMT company answers to several calendars at once: the state Medicaid agency, every broker and health plan, the IRS, OSHA, and HIPAA. Each one sets its own dates, and a broker can pull trips on the day a driver’s paperwork expires. This calendar puts them in one place: the monthly routine, the federal dates for the year ahead, a tracker for every driver and van, and the deadlines that start when something happens.

How to use this template

1. Fill in Part 1 once. Write down the dates only your company has: Medicaid revalidation, the end of each broker agreement, insurance renewals, your business license, your state’s annual report, and your USDOT update month if you have a USDOT number.
2. Pick one compliance day each month. OIG generally updates its exclusion list by the middle of each month, so a fixed day after that, such as the 20th, works. Print Part 2 for that day.
3. Copy Part 3 onto your office calendar. It lists the federal payroll, tax, HIPAA, and OSHA dates from October 2026 through December 2027 for a company on the calendar year.
4. Choose a month for each yearly task in Part 4, and write it in the last column. Spread them out so no single month is overloaded.
5. Fill in Part 5 from each driver’s file and Part 6 for each van. The driver file checklist lists every document to track.
6. Set a reminder 30 days before every date in Parts 1, 5, and 6.
7. Keep Part 7 by the dispatch phone. Those deadlines start with an event, not a date.
8. Initial and date each task when it is done, and file the proof: search results, certificates, receipts, and confirmations.
9. Update the calendar when a broker or state changes its rules. MTM Health’s standard agreement says changes to its credentialing requirements are posted online.

The template

Part 1: Your company’s fixed dates

Item	Issued by	Due or expiration date	Reminder date	Done (date, initials)
Medicaid enrollment revalidation (each state)
Broker agreement end date and notice deadline (each broker)
Health plan or facility contract end dates
Commercial auto policy renewal
General liability policy renewal
Workers’ compensation policy renewal
Umbrella or other policy renewal
Business license (city or county)
State NEMT, livery, or operating permit
State annual report for your LLC or corporation
USDOT MCS-150 update (if you have a USDOT number)
Broker compliance attestation (each broker)
HIPAA risk assessment review
Yearly compliance program review

Part 2: Every month (print one each month)

Month and year: ______________

Task	Rule or source	Done (date, initials)
Search the company and every person on your roster on the OIG list, SAM.gov, and your state’s list, after OIG’s monthly update. Save each result.	42 CFR 455.436; OIG exclusions FAQ
Deposit last month’s payroll taxes by the 15th, if you are a monthly schedule depositor	IRS Publication 15 (2026)
Check Parts 5 and 6 for anything expiring in the next 60 days, and book the renewal	Broker credentialing rules
Upload renewed documents to each broker at least 10 business days before they expire	MTM Health Rhode Island handbook (July 1, 2026)
Run this month’s random drug and alcohol tests, if your program uses them, at varied days and times	MTM standard agreement 5.C; 49 CFR 655.45
Remove logins for anyone who left, and review who can open each portal and app	45 CFR 164.308(a)(3) and (a)(4)
Read new broker, plan, and state notices, and update policies and this calendar	OIG General Compliance Program Guidance
In March, June, September, and December: compliance contact reports to the owner	OIG guidance, at least quarterly

Part 3: Federal dates, October 2026 to December 2027

Dates already account for weekends and legal holidays. If your company uses a fiscal year, your income tax dates differ.

Date	What is due	Who it applies to
October 15, 2026	Form 1040 or Form 1120 for 2025, if you filed for a six-month extension	Owners and C corporations with an extension
November 2, 2026	Form 941 for July to September 2026	Employers
December 15, 2026	Fourth 2026 estimated tax payment	C corporations
January 15, 2027	Last 2026 estimated tax payment	Owners who pay estimated tax
February 1, 2027	W-2s to employees and the Social Security Administration, Form 940 for 2026, Form 941 for October to December 2026, and Form 1099-NEC to each contractor paid $2,000 or more in 2026 and to the IRS	Employers, and anyone paying contract drivers
February 1 to April 30, 2027	Post the OSHA Form 300A summary for 2026	Companies with more than 10 employees at any time in 2026
March 1, 2027	Report 2026 breaches affecting fewer than 500 people to HHS	HIPAA covered entities
March 2, 2027	Submit 2026 Form 300A data to OSHA online, plus Form 300 and 301 data at 100 or more employees	Ground passenger transportation locations with 20 or more employees in 2026
March 15, 2027	Form 1065 or Form 1120-S for 2026	Partnerships, multi-member LLCs, S corporations
April 15, 2027	Form 1040 or Form 1120 for 2026, and the first 2027 estimated tax payment	Owners (Form 1040) and C corporations (Form 1120)
April 30, 2027	Form 941 for January to March 2027	Employers
June 15, 2027	Second 2027 estimated tax payment	Owners and C corporations that pay estimated tax
August 2, 2027	Form 941 for April to June 2027	Employers
September 15, 2027	Third 2027 estimated tax payment, and Form 1065 or Form 1120-S for 2026 with an extension	Owners and C corporations that pay estimated tax, and partnerships and S corporations with an extension
October 15, 2027	Form 1040 or Form 1120 for 2026, if you filed for a six-month extension	Owners and C corporations with an extension
November 1, 2027	Form 941 for July to September 2027	Employers
December 15, 2027	Fourth 2027 estimated tax payment	C corporations

Your state’s withholding, unemployment, and annual report dates follow the state’s own schedule. Add them in Part 1.

Part 4: Yearly and longer cycles

Task	How often	Rule or source	Month you will do it
Criminal background check, each driver and attendant	Before hire, then every year	MTM standard agreement 5.C
Driving record covering the last three years, each driver	Every year	MTM standard agreement 5.C; 49 CFR 391.25 for commercial vehicle drivers
Fraud, waste, and abuse training and HIPAA training, everyone	At hire, then every year	MTM Virginia handbook; WellTrans agreement; Modivcare attestation
Broker compliance attestation and training roster	Every year	Modivcare attestation (2025)
Broker vehicle inspection	Before first use, then twice a year in MTM Virginia	MTM Virginia handbook (August 10, 2026)
Wheelchair lift and ramp service	On the lift maker’s schedule	FMVSS 403 owner’s manual insert; 49 CFR 37.161
New insurance certificates to each broker	At every policy renewal	MTM standard agreement 9.A
HIPAA risk assessment review	On a cycle you set, such as yearly, and after major changes	HHS Guidance on Risk Analysis
HIPAA policy review	Periodically	45 CFR 164.316(b)(2)(iii)
Compliance risk assessment, policy review, and claims audit	At least once a year	OIG General Compliance Program Guidance
Compliance training for all staff	At least once a year	OIG General Compliance Program Guidance
Mileage reimbursement rate	When the IRS changes it	IRS standard mileage rates
Random testing rates	Once a year, when FTA publishes them	FTA’s yearly notice; MTM standard agreement 5.C
Medical certificate, commercial vehicle drivers	At least every 24 months	49 CFR 391.45
USDOT MCS-150 update	Every 24 months	49 CFR 390.19T
Medicaid revalidation	At least every 5 years	42 CFR 455.414
Broker agreement renewal	At the end of each term	Each agreement

Part 5: Driver renewal tracker

Driver	Hire date	License expires	Driving record due	Background check due	First aid or CPR expires	PASS or passenger training expires	Yearly training due

Part 6: Vehicle renewal tracker

Vehicle (unit and last 4 of VIN)	Registration expires	State inspection due	Broker inspection due	Lift or ramp service due	Added to auto policy (date)	Notes

Part 7: Deadlines that start with an event

When this happens	Deadline	Rule or source
You hire anyone	Form I-9 Section 2 within 3 business days of the start date	8 CFR 274a.2
You hire anyone	New hire report to your state within 20 days, or sooner if your state requires	42 U.S.C. 653a
A new driver or staff member will work Modivcare trips	Modivcare’s required training within 30 days of hire	Modivcare attestation (2025)
A new driver starts on MTM trips	Fully credentialed before the first trip	MTM standard agreement 5.D
You add or remove a van	Tell MTM immediately, and update your auto policy	MTM standard agreement 9.D
A driver or the company is investigated or charged with a crime	Tell MTM immediately	MTM standard agreement 2.R
An accident, incident, or moving violation involving a Modivcare driver or van	Tell Modivcare immediately	Modivcare attestation (2025)
Your company’s ownership changes	Disclose the new owners to Medicaid within 35 days. MTM requires a new agreement.	42 CFR 455.104; MTM standard agreement 2.C
Your NPI record changes, such as your address	Update NPPES within 30 days	45 CFR 162.410
A breach of rider information	WellTrans: one business day. HIPAA: a business associate tells the covered entity without unreasonable delay and within 60 days of discovery.	WellTrans agreement; 45 CFR 164.410
You find a Medicaid overpayment	Report and return it within 60 days of identifying it	42 U.S.C. 1320a-7k(d)
A worker dies from a work incident	Report to OSHA within 8 hours	29 CFR 1904.39
A worker is hospitalized, loses an eye, or has an amputation from a work incident	Report to OSHA within 24 hours	29 CFR 1904.39
A search confirms someone is excluded	Keep the person off all work paid by Medicare or Medicaid, office work included, and check OIG’s Self-Disclosure Protocol for any past work	HHS OIG exclusions FAQ

Monthly: exclusion checks and payroll deposits

Your state Medicaid agency must check the OIG exclusion list and the federal excluded parties list, now part of SAM.gov, at least monthly for every provider and every owner, agent, and managing employee (42 CFR 455.436). Broker agreements add their own ban: MTM Health’s standard agreement bars any driver or attendant whose name appears on the OIG list or the federal excluded parties list. No federal health care program pays for work an excluded person does, whoever bills it, so a match on a driver or dispatcher can turn months of claims into overpayments.

OIG says both versions of its list are generally updated by the middle of each month, covering the prior month’s actions. As of September 30, 2026, the last update posted September 10, 2026. Search on a fixed day after the update and save the results in the exclusion screening log.

Payroll taxes run on their own monthly clock. A monthly schedule depositor, which every new employer is in its first calendar year, deposits each month’s payroll taxes by the 15th of the next month (IRS Publication 15, 2026). Semiweekly depositors follow the schedule in Publication 15 instead.

Yearly: driver files, training, inspections, and insurance

Most driver renewals come from broker contracts, not federal law. MTM Health’s standard agreement, in the January 1, 2023 version Pennsylvania posts, keeps these in every driver and attendant file, owner-drivers included:

• A criminal background check before hire and every year after.
• A driving record covering the previous three years, pulled every year.
• Drug and alcohol results before hire, after an accident, on suspicion, and at random under current FTA rates. For calendar year 2026, FTA’s minimum random rates are 50 percent of covered employees for drugs and 10 percent for alcohol. The FTA rules the agreement points to require random tests to be unannounced and spread reasonably through the year (49 CFR 655.45).
• Training certificates, with fraud, waste, and abuse and HIPAA in every driver program.

Training repeats every year at the large brokers. MTM’s Virginia handbook (approved August 10, 2026) requires fraud, waste, and abuse training before a provider starts and every year after. WellTrans’s agreement (revised October 16, 2025) requires HIPAA and fraud, waste, and abuse training at hire and every year. Modivcare’s 2025 attestation has you certify the training for the calendar year, have new employees finish it within 30 days of hire, and keep the records at least 10 years. Log each session in the driver training log.

Vans renew too. MTM’s Virginia handbook requires every vehicle to be inspected before it carries members and again twice a year, and a van out of compliance can be pulled from service until it is fixed. Wheelchair lifts must be kept working and repaired promptly (49 CFR 37.161), and every lift built to FMVSS 403 comes with a maintenance schedule in its owner’s manual insert, based partly on the lift’s cycle counter. Run each van through the vehicle inspection checklist the week before the broker’s inspector comes.

Insurance renews on the policy’s date, but each broker needs proof. MTM’s agreement requires certificates at signing and at every renewal, and immediate notice when a van is added to or removed from a scheduled auto policy.

The office has yearly tasks as well. OIG’s General Compliance Program Guidance (November 2023) recommends a compliance risk assessment, a policy review, and compliance training for everyone at least once a year, and in a small company a compliance contact who reports to the owner at least quarterly. HIPAA sets no fixed cycle for the risk analysis, but HHS’s guidance notes that some organizations do it yearly. The HIPAA risk assessment template is built to be redone on that date. See the NEMT compliance program for what each review covers.

If your vans are commercial motor vehicles under federal rules, two more cycles apply: a driving record review at least every 12 months (49 CFR 391.25) and a medical certificate at least every 24 months (49 CFR 391.45). DOT numbers for NEMT explains when federal rules reach your fleet.

Every two to five years: USDOT, revalidation, and contracts

USDOT updates. An interstate motor carrier with a USDOT number files an updated Form MCS-150 every 24 months (49 CFR 390.19T). The last digit of the USDOT number sets the month: 1 is January, 2 is February, and so on to 9 for September, with 0 for October. The next-to-last digit sets the year: odd digits file in odd years, even digits in even years. A number ending in 57 files by the end of July 2027. Missing it can deactivate the USDOT number.

Medicaid revalidation. Your state must revalidate every enrolled provider at least every five years (42 CFR 455.414), and it can ask for your ownership disclosures again during revalidation. Some states run shorter cycles for NEMT: as of February 2026, Minnesota classes NEMT as high risk and revalidates it every three years, with background checks and site visits. See Medicaid revalidation for how the notice and screening work.

Broker agreements. MTM Health’s standard agreement runs three years and renews only by mutual written agreement. Put each agreement’s end date, and any notice deadline before it, in Part 1.

Tax, HIPAA, and OSHA dates in 2027

The dates in Part 3 follow three rules:

• Payroll returns. Form 941 is due on the last day of the month after each quarter, and Form 940 on the last day of January (IRS Publication 509, 2026). When a date falls on a weekend or a legal holiday, it moves to the next business day. That is why the 2026 W-2s, Forms 940 and 941, and Forms 1099-NEC are all due February 1, 2027: January 31 is a Sunday. For payments after 2025, Form 1099-NEC is required for each contractor paid $2,000 or more. NEMT business taxes covers the rest of the tax year.
• HIPAA breach log. A covered entity keeps a log of breaches affecting fewer than 500 people and reports each calendar year’s breaches to HHS within 60 days after the year ends (45 CFR 164.408). For 2026, that is March 1, 2027. A business associate reports each breach to the covered entity instead, without unreasonable delay and within 60 days of discovery, and a broker agreement can be much stricter.
• OSHA injury records. A company with 10 or fewer employees at all times last year does not keep OSHA’s injury log unless OSHA asks in writing. Ground passenger transportation is not on OSHA’s list of partially exempt industries, so a larger NEMT company keeps the log and posts the Form 300A summary from February 1 to April 30 (29 CFR 1904.32). Transit and ground passenger locations with 20 or more employees also submit the 300A data online by March 2, and locations with 100 or more send their Form 300 and 301 data too (29 CFR 1904.41). Every employer reports deaths and serious injuries on the Part 7 clocks.

Two federal rates change during the year. The IRS standard mileage rate for business use is 76 cents a mile from July 1 to December 31, 2026, up from 72.5 cents in the first half. FTA publishes its random testing rates once a year, and its notice for 2026 came out January 15, 2026.

Where your state and brokers set their own dates

This calendar holds the federal dates and the dates in three brokers’ published documents. Your own schedule is the strictest rule among the state, each broker, and each health plan you work with. Inspection cycles, training lists, and background check rules differ from one to the next, so read the handbook for each program and add what it requires. NEMT recredentialing compares the cycles across brokers, and your state guide lists the agency and licensing rules where you operate.