NEMT Driver Qualification File Checklist: Every Document, With Renewal Dates

Every state and broker that pays for NEMT rides wants proof that each driver is qualified, and it wants that proof on file before the first ride. This checklist keeps every document in one folder per driver, with the date each item was done and the date it is due again. Use it at hire, at every renewal, and before a broker audit.

How to use this template

1. Start a file before the first ride. Print one checklist per driver, and one per attendant you employ. MTM Health’s standard agreement, in the January 1, 2023 version Pennsylvania posts, bars any driver or attendant from carrying members until fully credentialed, and its file rules cover owner-drivers too.
2. Fill Part 1 from the license. Write the name exactly as it appears on the license. Minnesota requires each driver file to show that name, the address, the birthdate, and the license number and class.
3. Keep a copy of every document behind the checklist. A date on the form is not proof. File the report, certificate, or saved search result itself.
4. Write a next due date for every item. Use the date printed on the card or the schedule in the renewal table below, whichever comes first.
5. Search the exclusion lists every month and save the results. Use Part 4, or one exclusion screening log that covers all staff at once. Print or save each result with the search date showing.
6. Record every accident, ticket, complaint, positive test, and suspension in Part 6. Note whether the driver was at fault and when you told the broker. Minnesota requires a record of each complaint against a driver, with a summary of your investigation and what you did about it.
7. Upload renewals to each broker early. MTM Health in Rhode Island wants credentials uploaded at least 10 business days before they expire, and it can pull trips from the manifest if they arrive less than 5 days before (handbook updated July 1, 2026).
8. Review every file on a set schedule. Take any driver with an expired item off the schedule until it is renewed.

Pair this file with the driver onboarding checklist at hire and the driver training log after that.

The template

Part 1: Driver details

Field	Write the entry here in pen
Full name as it appears on the driver’s license
Home address
Date of birth
Phone
Driver’s license number, state, and class
License expiration date
Endorsements and restrictions
Date hired
Date of first ride for the company
Role (driver, attendant, or owner-driver)
Vehicle types cleared to drive (sedan, wheelchair van, stretcher van)
Broker driver ID, if issued
State Medicaid driver enrollment number, if your state enrolls drivers

Part 2: Before the first ride

Item	Date done	Result or number	Next due	Checked by
Signed job application
Copy of driver’s license, front and back
Driving record from every state that licensed the driver in the last 3 years
Signed background check notice and permission form
Criminal background check (agency and places searched)
Sex offender registry search
OIG exclusion list (LEIE) search, with a saved copy
SAM.gov exclusion search, with a saved copy
State Medicaid exclusion list search, where one exists
Pre-employment drug test (panel and lab)
Medical examiner’s certificate, where required
Road test in each vehicle type
Driver’s signed statement of drug law violations and driving history
Signed code of conduct
Company photo ID badge issued
Broker or state approval to drive

Part 3: Training certificates

Course	Date completed	Hours	Expires or next due	Copy in file (yes or no)
Company orientation, radio or phone use, and emergency steps
Defensive driving
First aid
CPR
Passenger assistance (PASS or an approved course)
Wheelchair and stretcher securement
Fraud, waste, and abuse
HIPAA privacy
Abuse prevention and mandatory reporting
Cultural competency
Child safety seats
Blood spill cleanup and infection control
Broker training modules

Part 4: Monthly exclusion searches

Month	OIG list (LEIE) date	SAM.gov date	State list date	Result (clear or match)	Copy saved, initials
January
February
March
April
May
June
July
August
September
October
November
December

Part 5: Yearly checks

Item	Year 1 date	Year 2 date	Year 3 date	Notes
Driving record pulled and reviewed
Criminal background check rerun
Drug test (yearly or random)
Medical examiner’s certificate renewed
Broker compliance training (fraud, waste, and abuse, HIPAA)
Performance review signed
Broker recredentialing approved

Part 6: Events on the record

Date	What happened	At fault?	Action taken	Broker told

Part 7: File review

Date reviewed	All current?	Missing or expiring	Off schedule?	Reviewer

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 driver it pays:

• the provider and driver are not excluded from federal health care programs or listed on the HHS OIG exclusion list,
• the driver has a valid driver’s license,
• the provider has a process to address any violation of a state drug law, and
• the provider has a process to disclose each driver’s driving history, including traffic violations, to the state Medicaid program.

Public transit authorities are exempt. CMS says in its Medicaid Transportation Coverage Guide (SMD 23-006, September 28, 2023) that federal Medicaid law sets no other basic driver standards. States and brokers set the rest, which is why the checklist is longer than four lines.

CMS also asked every state, in letter SMDL #09-001 (January 16, 2009), to require providers to search the OIG list monthly. OIG posts updates to the list every month. Brokers add a second federal list. MTM Health’s agreement names the Excluded Parties List System, which CMS says moved into SAM.gov in 2012 (bulletin of August 1, 2012). For how to search the OIG list and what to do on a match, see the OIG exclusion list.

How to save proof of each search

Modivcare’s credentialing reminder for out-of-network providers, linked from its provider compliance page as of September 2026, spells out what a saved search should show:

1. Search each driver on the OIG list, SAM.gov, and any state exclusion list at hire and every month after.
2. Save a PDF of each result with the search date visible.
3. Make sure the copy shows the driver’s full name, the database name and web address, the result, and any screening company you used.
4. If the OIG search shows a possible match, click verify and enter the driver’s Social Security number. A confirmed match on either list means the driver cannot take the broker’s trips.

Which rule each item meets

No single rule lists every item on this checklist. The table shows where each item is required, using states and brokers with clear written rules as of September 2026. Compare it with your own state manual and broker contract.

Item	Where it is required
Copy of a valid license for the vehicle	Federal minimum; MTM Health’s standard agreement (current, legible copy); Modivcare (out-of-network providers, at hire and when the license expires); Oregon; Minnesota; New Jersey; Georgia; Louisiana (class D or CDL)
Driving record at hire	MTM Health (previous 3 years); Georgia (previous 3 years); Minnesota; Louisiana; New York ambulettes (every state where the driver lived, worked, or was licensed in the last 3 years)
Criminal background check	MTM Health (at hire and yearly); Modivcare (yearly proof of no state drug law violation, such as a background check, for out-of-network providers); Oregon (before hire); Louisiana (yearly); MTM Health in Rhode Island (at hire and yearly); MTM Health in Virginia (before any rides); Minnesota (state background study); Georgia; Verida
Sex offender registry search	MTM Health in Virginia (before any rides); MTM Health in Rhode Island (no registry listing in the last 10 years)
Exclusion searches	Federal minimum; CMS (monthly OIG search); MTM Health (OIG list and the federal excluded parties list, now in SAM.gov); Modivcare (OIG, SAM.gov, and state lists at hire and monthly, for out-of-network providers); Oregon (before hire)
Drug testing	MTM Health (before hire, after accidents, on suspicion, and random); MTM Health in Rhode Island (five-panel, random tests on more than 25 percent of drivers a year); Louisiana (five-panel, yearly and on suspicion); Verida (current tests for owners and drivers)
Medical examiner’s certificate	Minnesota (every driver); New York ambulettes (at hire and every 2 years); drivers under federal motor carrier rules
Road test	Minnesota (behind-the-wheel evaluation before service); CareOregon (vehicle orientation and road test); New York ambulettes (every 2 years)
Defensive driving	Oregon; Louisiana; Minnesota; MTM Health in Virginia; Georgia
First aid and CPR	Oregon (before driving); Wisconsin (before driving); Louisiana (CPR, in person); New Jersey (CPR card in the file); Minnesota (first aid within 45 days); Georgia (first aid certificates in the file)
Passenger assistance and securement	Louisiana (PASS and securement every 2 years); Oregon (every 3 years); Minnesota; MTM Health in Virginia (PASS); Georgia
Fraud, waste, and abuse, and HIPAA	MTM Health’s standard agreement (part of your training program); Modivcare (within 30 days of hire, then yearly); MTM Health in Rhode Island (fraud, waste, and abuse before the first trip, then yearly); MTM Health in Virginia; Louisiana (HIPAA)
Cultural competency	Modivcare; MTM Health in Virginia; CareOregon
Child safety seats	Louisiana (child passenger restraint training before any rides); Minnesota (3 hours for drivers who carry children in car seats)
Abuse prevention or mandatory reporter training	Minnesota (4 hours, then 2 hours every 3 years); MTM Health in Virginia
Driver’s statement of drug law violations and driving history	Federal minimum (the provider’s process); Oregon (drivers must disclose, including later changes)
Signed code of conduct	CareOregon
Performance reviews	CareOregon (signed and kept in the personnel file)
Complaint and incident records	Minnesota; Georgia
Photo ID badge	MTM Health’s standard agreement (picture ID badge with the driver’s and company’s names); MTM Health in Rhode Island (photo nametag); New Jersey (photo ID in the file); MTM Health in Virginia (company shirt or program ID badge)

How often each item renews

Item	Common schedule	Examples, as of September 2026
Driver’s license	Before it expires	Every rule above
Driving record	Every year	MTM Health; Modivcare (out-of-network providers); Minnesota; New York ambulettes (with a personal interview)
Criminal background check	Every year	MTM Health; Louisiana; MTM Health in Rhode Island
Exclusion searches	Every month	CMS SMDL #09-001; Modivcare (out-of-network providers)
Drug test	Random, after accidents, and on suspicion, plus yearly in some programs	MTM Health; Louisiana (yearly); MTM Health in Rhode Island
Medical examiner’s certificate	By the date on the card	Minnesota; New York ambulettes (every 2 years)
Broker compliance training	Every year	Modivcare; MTM Health in Rhode Island
Defensive driving	Every 3 years	Oregon (first course within 3 months of hire); Louisiana (at least 4 hours); Minnesota (2-hour refresher)
First aid	Every 3 years, or sooner if the card expires	Wisconsin; Minnesota (4-hour refresher)
CPR	Keep certification current	Wisconsin; Louisiana; Oregon
Passenger assistance and securement	Every 2 or 3 years	Louisiana (every 2 years); Oregon (every 3 years); Minnesota (2 hours of securement every 3 years)
Road test and written test	Every 2 years	New York ambulettes

State rules that spell out the driver file

Minnesota. Every NEMT provider must meet the state’s special transportation service standards, and every driver must be enrolled individually with the Department of Human Services and named on the claim (Minnesota Statutes 256B.0625, subdivision 17, as of September 2026). Drivers must be at least 18. Before a driver starts, you review the license and driving record, receive a DHS background study result through the state’s NETStudy system, and collect a valid medical examiner’s certificate under the federal standard. You pull the driving record again every year.

Minnesota Rules 8840.6100 lists the file: name, address, and birthdate; license number and class; whether the record meets the standards, the date of the latest record check, and who did it; the first date of service; every training certificate; a signed statement of the criminal and driving record review; the medical certificate; and the background study result. Training starts before the first ride, with first aid, defensive driving, abuse prevention, and passenger assistance due within 45 days and refreshers every 3 years. Keep the records at least 3 years.

Georgia. The broker keeps a record for each driver with the name, birthdate, and Social Security number; a copy of the license; a driving record for the previous 3 years; background check results; first aid and driver training certificates; and every complaint, incident, accident, and moving violation (Part II NEMT manual, version dated July 1, 2026). Drivers must be at least 21, with no conviction for a sexual crime or crime of violence, no conviction for driving under the influence of alcohol or drugs in the 5 years before hire, and no suspended or revoked license in the last 5 years. A felony within 5 years needs review by the broker and the state. Two at-fault moving violations or accidents on NEMT trips remove the driver. Accident reports go in both the vehicle’s file and the driver’s file, and police reports for moving violations go in the driver’s file.

New York ambulettes. To enroll as a Medicaid ambulette, a company sends the DMV’s Letter of Compliance with Article 19-A, dated on or after the most recent July 1 (eMedNY). Article 19-A is the state’s bus driver law. Its driver file, per the DMV guide CDL-15 (February 2026), holds the DS-870 application, a driving abstract and a medical exam before hire, a yearly abstract, record review, and defensive driving observation, and a medical exam, road test, and written test every 2 years. Keep files for the current year and the past 3 years.

New Jersey mobility assistance vehicles. Each crew member’s file holds the name and home address, a copy of the driver’s license, a photo ID, the MAV or PAT technician card or EMT card, and a CPR card (N.J.A.C. 8:40-3.8, readopted effective September 25, 2023). Files stay at your main place of business, ready for Department of Health staff on demand. Records other than patient records are kept at least 5 years.

Oregon. Before hiring, a driver needs a license of the right class, no listing on the OIG exclusion list, and a passed criminal background check under ORS 181A.195 (OAR 410-141-3925, effective January 1, 2022). Drivers must disclose any state drug law violation and changes in their driving history. Defensive driving and passenger service courses are due within 3 months of hire and every 3 years, and first aid, CPR, and blood spill training before the first ride. CareOregon’s manual (version 1.3, February 2024) adds a signed code of conduct and signed performance reviews kept in the personnel file.

Wisconsin. A specialized medical vehicle driver needs an unrestricted license, apart from a vision restriction corrected to 20/30 (DHS 105.39, as of September 2026). Before driving, the driver needs first aid and CPR training, instruction on caring for a rider having a seizure, and instruction on every ramp, lift, and restraint you use. First aid is refreshed at least every 3 years, CPR is kept current, and you keep a current list of all drivers with license numbers, violations, and restrictions.

Louisiana. Drivers must be at least 21, with no more than two moving violations and no drunk driving conviction in the past 3 years (Medicaid Services Manual chapter 10, issued July 14, 2025). The Louisiana State Police, an agency it authorizes, or the FBI runs a criminal history check every year, and a five-panel drug test is due every year and on suspicion. The agency and the lab send results straight to the broker, so the driver signs a written consent for the release. A driver who fails a drug test returns only after a substance abuse professional clears them, then completes three follow-up tests in the six months after returning. Training before any rides covers defensive driving, in-person CPR, child passenger restraints, PASS and securement, and HIPAA.

For each state’s full rules, see our state guides and NEMT driver requirements.

Broker rules to check in your contract

MTM Health’s standard agreement (January 1, 2023, as Pennsylvania posts it) requires drivers and attendants to be at least 21 and able to read, write, and communicate in English. It bars drivers with a suspended, expired, or revoked license, three or more at-fault moving violations in 36 months, two or more at-fault accidents with injury or damage in 36 months, or any conviction for a sexual crime or crime of violence. A felony in the last 7 years needs approval from MTM’s client, and drug or alcohol treatment or a positive drug test in the last 5 years disqualifies a driver. A driver is presumed at fault in an accident unless shown otherwise, and police reports are required to prove a no-fault accident, so keep them in the file.

The same agreement defines a background check as a federal and FBI check or the equivalent, with a national criminal database search, a Social Security number trace, and county court searches for past addresses and names. Its drug screen is a urine test for marijuana, cocaine, amphetamines, opioids, and PCP at a minimum.

MTM Health in Virginia (handbook approved August 10, 2026) asks for drivers at least 21 with two years of driving experience. The record may show no more than two chargeable accidents or moving violations in 3 years, a DMV point balance no lower than minus 2, and no suspension for moving violations in 5 years. MTM tracks each driver’s training dates, license expiration, last background check, last drug test, and last record review. Each expired credential on a driver or vehicle costs 2 points, and trips by drivers with expired documents can go unpaid.

MTM Health in Rhode Island (handbook updated July 1, 2026) bars drivers on any sex offender registry within the last 10 years and anyone convicted of another felony in that time. It requires a state or national criminal check at hire and every year, and fraud, waste, and abuse training before the first trip and every year after.

Modivcare has every provider sign a yearly compliance attestation (2025 version). Owners and drivers complete its code of conduct and compliance training, covering fraud, waste, and abuse, HIPAA, the ADA, health, safety, and welfare, and cultural competency, within 30 days of hire and every year. You keep the training records at least 10 years and hand them over on request. Out-of-network providers also keep the exclusion searches and license copies described above, a yearly driving record, and yearly proof that the driver has no state drug law violation, such as a criminal background check.

Verida lists driver credentials, criminal background checks, and current drug tests for all owners and drivers among its contracting documents.

Your broker agreement holds the full credential list. MTM points providers to Appendix B of its service agreement. See NEMT broker credentialing for the steps.

If your drivers need a CDL or drive commercial vans

Federal motor carrier rules cover a van used in interstate commerce that is rated at 10,001 pounds or more, or is designed or used to carry more than 8 people, driver included, for pay (49 CFR 390.5T). The same rules list an exception for “the transportation of human corpses or sick and injured persons” (49 CFR 390.3T). Ask FMCSA whether it covers your trips before you rely on it.

When the rules apply, 49 CFR 391.51 requires a driver qualification file with the application, the driving record from each licensing state at hire, the road test certificate, each yearly driving record with a note of your review, and the medical examiner’s certificate. It may be combined with the personnel file. Keep it for the whole job and 3 years after, though yearly records and old medical certificates can come out 3 years after they were made.

Drug and alcohol testing under 49 CFR part 382 covers drivers who need a commercial driver’s license, and the sick-and-injured exception does not apply to it (49 CFR 382.103). Federal Transit Administration testing (49 CFR part 655) covers recipients of its urbanized, capital, and rural area grants and their contractors, so it can reach you when you drive under contract with a transit agency. See do NEMT drivers need a CDL and NEMT driver drug testing.

Background checks and consumer report law

When a screening company runs the check, the Fair Credit Reporting Act applies. The FTC says you must:

1. Give the applicant a written notice that you may use a consumer report for job decisions. It must stand alone, not sit inside the job application.
2. Get the applicant’s written permission. Say so clearly if the permission covers checks during the whole job, such as yearly reruns.
3. Before you turn someone down because of the report, give them a copy of it and the “Summary of Your Rights Under the Fair Credit Reporting Act.”
4. After you decide, send an adverse action notice with the screening company’s contact details and the person’s right to dispute the report.

Keep the signed notice and permission in Part 2. Some states limit the use of consumer reports for jobs, so check your state law. For what to search and how far back, see NEMT driver background checks.

How long to keep driver files

Rule	How long
MTM Health’s standard agreement (full records of your operations)	10 years
Modivcare (training records for all providers, and driver credential records for out-of-network providers)	At least 10 years, produced within 3 business days of a request for out-of-network providers
New Jersey N.J.A.C. 8:40-3.9 (required records other than patient records)	At least 5 years
Minnesota Rules 8840.6100 (records under the special transportation rules)	At least 3 years
New York Article 19-A driver files	The current year and the past 3 years
49 CFR 391.51 (federal driver qualification file)	The whole job, plus 3 years
Form I-9 (USCIS)	3 years after hire or 1 year after the job ends, whichever is later

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

Getting ready for a broker audit

Brokers can check these files without warning. Modivcare audits a sample of out-of-network providers every quarter, and a failed audit brings a corrective action plan and a repeat audit the next quarter.

1. Match your roster to the broker’s. Every driver who took a trip needs a file, and every file needs the broker’s approval date.
2. Check every date in Parts 2 to 5. Renew anything due in the next 60 days.
3. Pull drivers with expired items off the schedule. Minnesota requires you to stop using a driver immediately when the driver no longer meets the standards, and to report it to the state.
4. Make copies readable. MTM Health requires a current, legible copy of each license.
5. Keep files at your main office. Minnesota and New Jersey require records you can show there on request, and both allow electronic files when you can produce them.
6. Close out Part 6. Every accident, ticket, and complaint should show what you did and when you told the broker.

For what auditors look for beyond driver files, see how to pass a NEMT broker audit.