# NEMT Employee Termination Checklist: Final Pay, Broker Rosters, and Rider Data

Canonical URL: https://nemtguide.com/templates/nemt-employee-termination-checklist/ · Updated 2026-10-02

An employee termination checklist lists every step, in order, when a driver, dispatcher, or biller leaves. For a NEMT company that means final pay by your state's deadline, the separation notice your state requires, health coverage notices, ending access to broker portals and rider data the same day, removal from every broker roster, returned keys and fuel cards, and a file kept for years.

- Look up your state's final pay deadline first. California makes a fired employee's wages due immediately, Connecticut by the next business day, and Texas within 6 calendar days.
- Cut off broker portals, the dispatch app, email, and door codes the same day, and collect phones, keys, badges, and fuel cards.
- Tell every broker the driver is gone. MTM asks you to contact your vendor account manager to remove a driver from your account.
- Hand over the separation notice your state requires, such as the DOL-800 on the last day in Georgia or the IA 12.3 in New York.
- Keep the file after the job ends: at least 3 years for a federal driver qualification file and 6 years for HIPAA sanction records.

When a driver leaves, the job is not over at the last trip. The final paycheck has a state deadline, the broker portal can still show riders' names and addresses, and every broker still counts the driver as yours. This checklist runs in the order things come due, from the day you learn someone is leaving to the day you may shred the file. It is the mirror of the [driver onboarding checklist](https://nemtguide.com/templates/nemt-driver-onboarding-checklist/).

## How to use this template

1. **Start it the day you learn someone is leaving.** Use one for each driver, attendant, dispatcher, or biller, whether they quit, are fired, or are laid off.
2. **Find the final pay deadline first.** It sets the pace for everything else. The table below covers seven states. For any other state, ask your state labor office before the last day.
3. **Cut access in the same hour you tell them, if you can.** Do Part 3 before the person leaves the building or the van. A dispatcher or biller may hold more logins than a driver, so list them all.
4. **Tell every broker the same day.** Part 5 holds the steps, and the broker section below lists what MTM Health, Verida, and Modivcare ask for.
5. **Hand over your state's notice on the last day.** Georgia, New Jersey, and New York want it at separation, California on a discharge or layoff, and Massachusetts within 30 days. See the notice table below.
6. **If you are firing someone, finish the paperwork first.** The last [driver write-up](https://nemtguide.com/templates/driver-write-up-form/) belongs in the file. If the decision rests on a background or driving record report from a screening company, follow the FTC's notice steps before and after you act.
7. **Close the file with a destroy-after date.** The retention table at the end gives the longest rules that commonly apply.

For a contractor, follow the contract's notice and payment terms. Collect the same property and close the same logins. Send Form 1099-NEC if you paid them $2,000 or more for services in 2026.

## The template

### Part 1: Departure details

| Field | Write the entry here in pen |
|---|---|
| Full name | |
| Role (driver, attendant, dispatcher, biller, office) | |
| Employee or contractor | |
| Reason (quit, fired, laid off, contract ended) | |
| Date notice was given or the decision was made | |
| Last day worked | |
| State where they worked | |
| Final pay due date in that state | |
| Brokers and health plans they served | |
| Mailing address for the final pay stub and Form W-2 | |
| Person responsible for this checklist | |

### Part 2: Pay, notices, and benefits

| Step | Date done | Initials |
|---|---|---|
| Resignation letter or written termination notice filed | | |
| Copy of the termination notice given to the employee | | |
| Final timesheet approved, including waits, cleaning, and last-day hours | | |
| Final pay figured: hours, overtime, and earned vacation where policy or state law requires | | |
| Any deduction checked against federal and state wage rules | | |
| Final pay paid by the state deadline (date and method) | | |
| State separation notice handed over (form number) | | |
| Health plan administrator told the job ended (within 30 days for COBRA) | | |
| Retirement plan or other benefit providers told | | |
| Workers' compensation claim open (yes or no), and adjuster told | | |
| | | |

### Part 3: Access to rider information

| Login or access | Date and time ended | Ended by |
|---|---|---|
| Each broker's provider portal | | |
| Each broker's driver app, on company and personal phones | | |
| Your dispatch and scheduling app | | |
| Company email, shared drives, and cloud folders | | |
| Phone, text, and voicemail accounts that show rider details | | |
| Billing, clearinghouse, and Medicaid portal logins | | |
| Shared and administrator passwords changed | | |
| Rider data cleared from a personal phone, where your policy allowed it | | |
| Door, gate, and key box codes changed | | |
| Paper manifests and trip sheets collected | | |
| | | |

### Part 4: Company property returned

| Item | Date returned | Condition or note |
|---|---|---|
| Vehicle keys and fobs | | |
| Fuel card (also cancelled with the card company) | | |
| Company phone or tablet | | |
| Photo ID badge | | |
| Uniform shirts | | |
| Building keys, gate cards, and garage remotes | | |
| Toll tag and parking pass | | |
| First aid kit, spill kit, or other gear issued to the person | | |
| | | |

### Part 5: Brokers, insurer, and schedule

| Step | Broker, insurer, or agency | Date done | Initials |
|---|---|---|---|
| Driver removed from the broker's account or roster | | | |
| End date sent to brokers that track it | | | |
| Next monthly driver roster updated | | | |
| Standing and recurring rides reassigned | | | |
| Insurer told, if your policy lists drivers | | | |
| Driver taken out of your random drug testing pool | | | |
| Any state or county driver list updated, where one exists | | | |
| | | | |

### Part 6: After the last day

| Step | Due | Date done |
|---|---|---|
| Form W-2 sent on request | Within 30 days of the request or the final pay, whichever is later | |
| Form W-2 for the year | By February 1, 2027 for 2026 wages | |
| Unemployment claim notice answered | By the date on the state's notice | |
| Personnel file request answered | By your state's deadline | |
| Safety history request from a new employer answered, if federal motor carrier rules cover you | Within 30 days | |
| File marked with the separation date and a destroy-after date | | |

### Part 7: Sign-off

| Field | Write the entry here in pen |
|---|---|
| Every line in Parts 2 to 6 done or marked not needed (yes or no) | |
| Owner or manager's printed name and signature | |
| Date | |

## Final pay deadlines in seven states

Federal law does not require you to hand over a final paycheck right away, but some states do. When the regular payday passes without pay, the U.S. Department of Labor tells workers to contact its Wage and Hour Division or their state labor department. Here is the rule in seven states, as of October 2026. In five of them, the deadline for a fired employee differs from the one for an employee who quits.

| State | Fired | Quit |
|---|---|---|
| California | Immediately (Labor Code 201) | Within 72 hours, or on the last day if they gave 72 hours' notice (202) |
| Massachusetts | In full on the day of discharge (c. 149, sec. 148) | On the next regular payday |
| Connecticut | By the next business day (sec. 31-71c) | By the next regular payday |
| Arizona | Within 7 working days or the end of the next pay period, whichever is sooner (23-353) | By the regular payday for the period in which they left |
| Texas | Within 6 calendar days (Labor Code 61.014) | By the next regularly scheduled payday |
| New York | By the regular payday for the period in which the job ended (Labor Law 191) | The same |
| Illinois | At separation if possible, and no later than the next regularly scheduled payday (820 ILCS 115/5) | The same |

Check how your state treats a layoff. Texas counts it as a firing, with pay due within 6 calendar days, while Connecticut pays a laid-off employee by the next regular payday (sec. 31-71c).

Three details catch owners:

- **Penalties.** In California, if you willfully fail to pay on time, the employee's daily wages keep running as a penalty from the due date until paid, for up to 30 days (Labor Code 203).
- **Vacation.** California and Illinois treat earned vacation under your policy as wages owed at the end, paid at the final rate, and bar policies that forfeit it (Labor Code 227.3 and 820 ILCS 115/5).
- **Deductions.** Federal wage law lets no deduction for damage to your property, theft, or tools cut pay below the minimum wage or into overtime for the workweek (29 CFR 531.35 and DOL Fact Sheet 16). State law can be stricter.

Hours that count, such as waiting at a clinic and the morning vehicle check, are in [NEMT driver overtime](https://nemtguide.com/guides/nemt-driver-overtime/), and the [driver timesheet](https://nemtguide.com/templates/nemt-driver-timesheet/) gives you the record to pay from.

## Ending access to rider information

A driver's phone can hold a day of riders: names, addresses, and where they are going. A dispatcher or biller can reach far more. HIPAA's Security Rule asks covered entities and business associates to have procedures for ending a workforce member's access to electronic rider information when the job ends (45 CFR 164.308(a)(3)(ii)(C)). It also requires a sanction policy for workforce members who break security rules.

HHS's Office for Civil Rights (November 2017) suggests a written exit checklist, the job Part 3 does. Its tips:

1. End electronic and physical access as soon as possible.
2. Deactivate or delete user accounts, and change or disable user IDs and passwords.
3. Take back laptops, phones, removable media, ID badges, and keys, and change lock combinations and security codes.
4. Clear rider information from personal devices if you allowed them, and end remote access and third-party or cloud accounts.
5. Change the passwords of any administrator account the person could use.
6. Keep a log of access granted and equipment issued, so you can show what was taken back.

A tighter rule may come. HHS proposed on January 6, 2025 that access end no later than 1 hour after the job ends, and that you tell any other covered entity or business associate within 24 hours when a worker you authorized to use its systems loses that access. As of October 2, 2026, HHS had not issued a final rule. Ending access the same hour meets both today's rule and the proposed one. The full policy is in the [HIPAA policy template](https://nemtguide.com/templates/nemt-hipaa-policy/), and [HIPAA for NEMT](https://nemtguide.com/guides/hipaa-for-nemt/) explains which rules reach a small company.

## Telling brokers the driver is gone

Brokers approve drivers one by one, so their records have to change when your staff does. The broker's own login for the driver is part of your Part 3 list too.

- **MTM Health.** MTM's portal tips, still linked from its Wisconsin provider page in October 2026, say that when a driver no longer drives for you, contact your vendor account manager to remove the driver from your company. See [MTM Health in Wisconsin](https://nemtguide.com/brokers/mtm-health/wisconsin/).
- **Verida in Tennessee.** The BlueCare Tennessee provider manual effective October 1, 2026 lists a monthly driver roster among the documents Verida collects. Failing to submit them can suspend your trip authorizations.
- **Criminal charges.** If the driver left over a criminal investigation, charge, or proceeding, MTM Health's standard agreement (January 1, 2023 version) requires immediate notice to MTM. Verida's Tennessee manual requires the same for an arrest, charge, or conviction for a disqualifying offense.
- **Accidents.** If the driver is leaving after a crash, remember that Modivcare's 2025 attestation requires immediate notice of any accident, incident, or moving violation involving a driver serving its trips.

Then move the driver's standing rides to someone else before the next trip date. How brokers add and approve drivers is in [NEMT broker credentialing](https://nemtguide.com/guides/nemt-broker-credentialing/).

## Separation notices and health coverage

Several states require a notice in the employee's hand when the job ends, so they can file for unemployment benefits. These rules were current as of October 2026. Most apply whatever the reason for leaving.

| State | What to hand over | When |
|---|---|---|
| California | For Your Benefit (DE 2320), with a written notice of the change | Immediately on a discharge, layoff, or leave of absence. Not required for a voluntary quit. |
| Georgia | Separation Notice (DOL-800), signed, with the reason | On the last day, for any reason. Within 3 days if the employee is not there. |
| Massachusetts | How to Apply for Unemployment Insurance Benefits (Form 0590A) | As soon as practicable, and within 30 days of the last day worked |
| New Jersey | Instructions for Claiming Unemployment Benefits (BC-10) | At separation, permanent or temporary, for any reason |
| New York | Record of Employment (IA 12.3) | To each worker who quits, is discharged or laid off, or has hours cut to 30 or less a week |

Georgia's Department of Labor said on August 12, 2026 that it now encourages employers to send the notice electronically, though a signed paper copy still works. In other states, check the unemployment agency's employer page.

**COBRA.** COBRA generally covers group health plans of employers that had at least 20 employees on more than half of their typical business days in the previous calendar year, with part-time workers counted as fractions. Losing a job for any reason other than gross misconduct is a qualifying event, so quits count. You tell the plan within 30 days, the plan sends an election notice within 14 days, and the employee gets at least 60 days to elect. Coverage after a job ends usually lasts 18 months, at up to 102 percent of the plan's cost (EBSA guide, October 2021). In California, Cal-COBRA covers plans sold to employers with 2 to 19 eligible employees (Health and Safety Code 1366.21).

## How long to keep the file

A former employee's records still have work to do: audits, unemployment claims, and lawsuits arrive months later. Keep each record for the longest rule that applies to you. The common rules run 3 years after the job ends, 6 years for HIPAA records, and 10 years for MTM Health operations records and Modivcare training records.

| Record | How long |
|---|---|
| Form I-9 (USCIS Handbook M-274) | 3 years after hire or 1 year after the job ends, whichever is later |
| Driver qualification file under federal motor carrier rules (49 CFR 391.51) | 3 years after the job ends |
| New Mexico driver file, with hire and separation dates (18.3.7.9 NMAC) | 3 complete calendar years, starting the first January after the driver leaves |
| Personnel file, California (Labor Code 1198.5) | 3 years after the job ends |
| Personnel record, Massachusetts employers with 20 or more employees (c. 149, sec. 52C) | 3 years after the job ends |
| Personnel file, Connecticut (Gen. Stat. 31-128b) | At least 1 year after the job ends |
| HIPAA policies, training, and sanction records (45 CFR 164.316 and 164.530) | 6 years from creation or the date last in effect, whichever is later |
| Records of your work under an MTM Health agreement (section 2.S) | 10 years |
| Modivcare training records (2025 attestation) | At least 10 years |

A former employee may ask to see the file. California allows 30 calendar days to answer a written request, and Connecticut 10 business days for a former employee who asks within a year of leaving. If federal motor carrier rules cover your vans, answer a new employer's safety history request about a former driver within 30 days, even when you have nothing to report (49 CFR 391.23). The documents that go in each driver's file are listed in the [driver file checklist](https://nemtguide.com/templates/nemt-driver-file-checklist/).

## Frequently asked questions

### How fast do I have to pay a NEMT driver who was fired?

It depends on your state. Federal law does not require an immediate final paycheck. California makes wages due immediately on discharge, Massachusetts on the day of discharge, Connecticut by the next business day, and Texas within 6 calendar days. New York allows the regular payday for the last pay period, and Illinois the next regularly scheduled payday. In California, a willful delay keeps the wages running as a penalty for up to 30 days.

### Can I take the cost of unreturned keys or a fuel card out of the last paycheck?

Be careful. Under federal wage law, deductions for damage to your property, theft, or other costs that are mainly for your benefit may not cut an employee's pay below the minimum wage or into required overtime for the workweek (DOL Fact Sheet 16). State law can be stricter, so check yours before you deduct anything.

### When should I cut off a departing driver's access to rider information?

As soon as the job ends, before the driver leaves the building if you can. HIPAA's Security Rule calls for procedures to end access when employment ends, and HHS's guidance says to end electronic and physical access as soon as possible. A rule HHS proposed on January 6, 2025 would set a limit of 1 hour, but it was still only a proposal as of October 2, 2026.

### Do I have to offer COBRA to a driver who quits?

If your group health plan is subject to COBRA, yes. COBRA covers employers that had at least 20 employees on more than half of their typical business days last year, and leaving a job for any reason other than gross misconduct is a qualifying event. You tell the plan within 30 days, and the plan sends the election notice within 14 days. Smaller California employers may fall under Cal-COBRA.

### Do I have to tell the broker when a driver leaves?

Yes. Brokers approve drivers one by one, so a former driver should not stay on your account. MTM's portal tips tell you to contact your vendor account manager to remove the driver. BlueCare Tennessee's manual lists a monthly driver roster among the documents Verida can suspend your trips over. Reassign the driver's standing rides the same day.

### How long do I keep a former driver's file?

Use the longest rule that applies to you. Form I-9 stays 3 years after hire or 1 year after the job ends, whichever is later. A federal driver qualification file stays 3 years after the job ends. New Mexico keeps driver files 3 complete calendar years after the driver leaves. MTM Health's standard agreement asks for 10 years of operations records.

## Official resources

- [U.S. Department of Labor: State labor offices, for your final pay rule](https://www.dol.gov/agencies/whd/state/contacts)
- [EBSA: Employer's guide to COBRA continuation coverage](https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/an-employers-guide-to-group-health-continuation-coverage-under-cobra.pdf)
- [HHS OCR: Insider threats and termination procedures (exit checklist tips)](https://www.hhs.gov/sites/default/files/november-cybersecurity-newsletter-11292017.pdf)
- [Georgia DOL-800 Separation Notice](https://dol.georgia.gov/document/separation-notices/separation-notice-individual-dol-800/download)
- [New York Record of Employment (IA 12.3)](https://forms.labor.ny.gov/UI/IA12.3.pdf)
- [New Jersey BC-10, Instructions for Claiming Unemployment Benefits](https://www.nj.gov/labor/forms_pdfs/ui/BC10.pdf)
- [California DE 2320, For Your Benefit](https://edd.ca.gov/siteassets/files/pdf_pub_ctr/de2320.pdf)