NEMT Startup Checklist for 2027: Every Step From Entity to First Trip

Opening a NEMT company is a chain of approvals, and most of them depend on the one before. A state license can require insurance and a vehicle first. Medicaid enrollment can require the license, and brokers want the Medicaid ID. Work down this checklist in order and write the date beside each step.

How to use this template

1. Finish Part 1 before you spend money. A freeze on new enrollments or a full broker network can stop the whole plan.
2. Work the parts in order. Where your state puts steps in a different order, follow the state.
3. Fill in the cost and date columns as you go. They become your startup budget and your timeline.
4. Keep every approval, certificate, and receipt in one folder. Brokers and lenders ask for them.
5. Use one legal name and address everywhere. Match the IRS letter on your NPI record, insurance, state filings, and bank account.
6. Start the credentialing checklist once Part 9 is under way. It lists the documents each broker asks for.

For the reasoning behind each step, read how to start a NEMT business. To plan the money side, use the NEMT business plan template and the startup cost calculator.

The template

Part 1: Before you spend money

Step	Where to check	What to look for	Date done
Find out who arranges and pays for NEMT in your state	State Medicaid agency and our state guides	State fee-for-service, a broker, or health plans
Check for a freeze on new NEMT enrollments	State Medicaid provider notices	Minnesota’s metro freeze runs to January 27, 2027
Ask each broker whether it needs providers in your counties	Each broker’s provider page	MediTrans says acceptance depends on regional saturation and fleet needs
Choose your services: ambulatory, wheelchair, stretcher	State license rules and each broker’s vehicle list
Check name rules before you file	Secretary of State and your transportation regulator	In Minnesota, only licensed ambulance services may use “medical,” “emergency,” “life support,” or “ambulance” in the name, though “Non-Emergency Medical Transportation” or “NEMT” is allowed
Write your business plan and startup budget	Business plan template

Part 2: Form the company

Step	Where to file	Cost or wait	Date done
Form an LLC or corporation	Your Secretary of State	State filing fee
Get an EIN	IRS, online	Free. Online: issued at once. Fax: about 4 business days. Mail: about 4 weeks.
Beneficial ownership report	FinCEN	Not required for companies formed in the U.S.
Open a business bank account	Your bank	Bring formation papers and the EIN letter
Elect S corporation tax treatment, if your tax preparer advises it	IRS Form 2553	Within 2 months and 15 days after the start of the tax year it takes effect
Register for state payroll taxes and unemployment insurance	State revenue and labor agencies
City or county business license	Your city or county

Part 3: Provider numbers

Step	Where to file	Cost or wait	Date done
Type 2 (organization) NPI	NPPES, at nppes.cms.hhs.gov	Free. Applying online is the fastest route.
Taxonomy code on the NPI	The NPPES application	343900000X, Non-emergency Medical Transport (VAN)
Keep the NPI record current	NPPES	Within 30 days of any change

Part 4: State license and operating authority

Step	Where to file	Cost or wait	Date done
State NEMT license, permit, or certificate	Your state health department, DOT, DMV, or utility commission	New Jersey: $1,500 plus $100 per vehicle
USDOT number, if needed	FMCSA online registration	Commercial vehicles on interstate trips, and some state programs
Vehicle inspection by the licensing agency, if required	State licensing agency
Local livery or taxi permits, if required	Your city or county

Part 5: Insurance

Step	Where	Cost or limit	Date done
Commercial auto liability, with every vehicle listed	Your insurance agent	MTM Health: at least $500,000 combined single limit. MediTrans: at least $1,000,000 per occurrence.
General liability	Your insurance agent	MTM Health: at least $500,000 per occurrence
Workers’ compensation, or proof of exemption	Your agent or state	Your state’s required amounts
Certificates naming each broker and your licensing agency	Your insurance agent	New Jersey requires its Department of Health as certificate holder
State insurance filings, where required	Your insurer	Minnesota STS: a Form E filing

Part 6: Vehicles

Step	Where	Notes	Date done
Buy or lease each vehicle	Dealer or lender
Title and register in the company’s name	Your state DMV
Lift or ramp, securement, and safety kit	Upfitter and each broker’s vehicle list
Inspection	State agency or broker
Add each vehicle to the auto policy	Your insurance agent	MTM Health wants every addition and removal reported at once
Start a file for each vehicle	Vehicle inspection checklist

Part 7: Drivers and staff

Step	Where	Deadline or wait	Date done
Form I-9 for each hire	You	Section 2 within 3 business days of the hire
New hire report	Your state’s new hire directory	Within 20 days of the hire, or sooner if your state says
Valid license and driving record	Your state DMV	Federal minimum for every NEMT driver
Exclusion search on the OIG list and SAM.gov	oig.hhs.gov and sam.gov	Before hire, then on a set schedule
Background check and drug test	Your state’s and each broker’s vendors	MediTrans: 5 to 7 business days for background checks
Training: first aid and CPR, defensive driving, passenger assistance, securement	Courses each broker accepts
Driver qualification file	Driver file checklist
Payroll set up	IRS Publication 15	2026 employer share: 6.2% Social Security and 1.45% Medicare

Part 8: Policies and records

Step	Where	Why	Date done
HIPAA privacy and security policies	HIPAA policy template	Required once you bill electronically
Drug and alcohol policy	Drug and alcohol policy	Federal minimum: a process for state drug law violations
Process to disclose each driver’s driving history to Medicaid	You	Federal minimum
Written operating procedures	You	New Jersey wants a manual with its license application
Incident, complaint, and emergency procedures	Incident report form
Trip log with rider signatures	Trip log template
Renewal calendar	Compliance calendar

Part 9: Medicaid enrollment

Step	Where to file	Cost or wait	Date done
Enrollment application	Your state Medicaid portal	$750 for applications in 2026, unless you paid it to Medicare or another state
Ownership disclosure	The same application	Each person with an ownership or control interest, and managing employees
Fingerprints for each 5 percent owner, if your state rates NEMT high risk	Your state’s fingerprint vendor	Indiana: done before you submit
Site visit, if your state rates NEMT moderate or high risk	State Medicaid agency or its contractor	Before and after enrollment
Approval letter and Medicaid ID	State Medicaid agency	Indiana: allow at least 15 business days
Revalidation date on your calendar	State Medicaid agency	At least every 5 years

Part 10: Broker, health plan, and facility contracts

Step	Where	Cost or wait	Date done
Letter of intent or application	Each broker	MediTrans: 2 to 4 weeks from letter of intent to activation
Credentialing file	Credentialing checklist
Signed agreement and rate sheet	Each broker
Health plan contracts, where plans arrange rides	Each plan’s provider relations team	A plan may contract while your state enrollment is pending, for up to 120 days
Facility and private pay agreements	Dialysis centers, nursing homes, families
Portal logins for dispatch and billing	Each broker	MediTrans: trip offers begin within 24 to 48 hours of active status

Part 11: First trip and first claim

Step	Where	Rule	Date done
Confirm the driver and vehicle are approved	Broker portal	MTM Health pays nothing for uncredentialed drivers or vehicles
Complete the trip record	Trip log template	MediTrans: documentation within 24 hours of the trip
Submit the claim before the deadline	Broker portal or state billing system	MTM Health: 90 days, unless the state or plan sets another limit. MediTrans: 365 days.
Track the payment	Remittance advice	MTM Health: within 30 days of electronic submission. MediTrans: every other Friday.
Set a reminder for every renewal	Compliance calendar

How long each step takes

These are the waits agencies and brokers state in writing. Most steps cannot start until the one before is done, so the waits add up.

Step	Wait	Source and date
EIN online	Issued at once	IRS, page updated August 19, 2026
EIN by fax	About 4 business days	IRS Form SS-4 instructions, December 2025
EIN by mail	About 4 weeks	IRS Form SS-4 instructions, December 2025
Medicaid enrollment, Indiana	Allow at least 15 business days before checking status	Indiana Medicaid, September 2026
Correcting a rejected Indiana online application	21 business days, or the application expires	Indiana Medicaid, September 2026
Medicaid enrollment, Colorado	8 business days on average for new applications	Colorado HCPF, September 2026
New Jersey license, after the application is complete	6 months to request the first audit and vehicle inspections	N.J.A.C. 8:40-2.1
Minnesota STS provider education	Within 90 calendar days of the certificate of compliance	MnDOT, September 2026
Broker onboarding, MediTrans	2 to 4 weeks	MediTrans provider page, September 2026
Background checks, MediTrans	5 to 7 business days	MediTrans provider page, September 2026
First trip offers after activation, MediTrans	24 to 48 hours	MediTrans provider page, September 2026
Health plan contract while enrollment is pending	Up to 120 days	42 CFR 438.602

The slowest parts are the ones you control least: license audits and inspections, Medicaid screening and site visits, and whether a broker needs you at all. The guide to how long it takes to start a NEMT business walks through a full timeline.

Check for enrollment freezes before you buy a van

Federal rule 42 CFR 455.470 lets a state Medicaid agency pause enrollment of new providers of a type that the Secretary of HHS has found to be at high risk of fraud, waste, or abuse, with the Secretary’s agreement. Each pause lasts 6 months at first and can be extended 6 months at a time. Two states show how it plays out for NEMT.

• Minnesota. The state is not enrolling new NEMT providers located in the seven-county metro area: Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties. The freeze began January 27, 2026 and was extended to January 27, 2027. Providers in other Minnesota counties can enroll. See the Minnesota enrollment freeze.
• Colorado. A moratorium on new NEMT enrollments has been in effect since October 1, 2023 and was extended through September 30, 2026. Colorado says new companies can start enrolling on October 1, 2026. Under 42 CFR 455.450(e), a provider kept out by a moratorium that applies within 6 months after it lifts is screened as high risk, which adds a criminal background check, fingerprints, and site visits. From January 1, 2027, no provider can run Colorado NEMT trips without a contract with the statewide broker, MediDrive.

Check your state Medicaid agency’s provider notices and ask your broker before you sign a vehicle loan. A van you cannot use for Medicaid trips still has a monthly payment.

What a state license can require: two examples

States license NEMT through different agencies, and the order of steps differs. Two states show the range.

New Jersey: a license before the first ride

The Department of Health licenses mobility assistance vehicle services under N.J.A.C. 8:40, readopted effective September 25, 2023. Any company providing mobility assistance on a trip that starts in New Jersey must be licensed first. The application needs:

• Every owner’s name, home address, and phone number
• A principal place of business at a real street address, not a post office box or mail drop
• A standard operating procedures manual and crew personnel files
• At least one licensable vehicle for each class of service
• Insurance in force, with the Department as certificate holder: at least $500,000 per occurrence for each vehicle and $300,000 of general liability
• A criminal history request for each person owning 5 percent or more
• Incorporation papers and a photo ID
• The fee: $1,500 plus $100 per vehicle, by cashier’s check or money order

Once the application is complete, you have 6 months to request the first provider audit and vehicle inspections. Licenses last up to 24 months.

Minnesota: Medicaid enrollment inside the license steps

MnDOT certifies Special Transportation Service (STS) providers. Its steps, as of September 2026:

1. Register the business with the Minnesota Secretary of State, following the name rule in Part 1.
2. Get a USDOT number from FMCSA. An intrastate number has no fee.
3. Send MnDOT the STS packet for a MnDOT number, including a workers’ compensation form.
4. File Form E commercial vehicle insurance.
5. Start Department of Human Services background studies for each person who needs one.
6. Enroll with Minnesota Health Care Programs (MHCP) at the Department of Human Services.
7. Pass the STS vehicle inspection and send the driver, non-driver, and vehicle forms.
8. Complete MnDOT’s initial STS provider education within 90 days of your certificate of compliance, or the certificate is canceled.

MnDOT says you cannot legally provide STS rides until you receive the certificate of compliance. For your own state, see NEMT license requirements and the New Jersey and Minnesota guides.

The federal rules behind the checklist

• Driver minimums. Since the Consolidated Appropriations Act, 2021, each state must make sure every NEMT provider and driver is not excluded from federal health programs and every driver has a valid license. Each provider must also have a process for state drug law violations and for disclosing each driver’s driving history to the state (SMD 23-006, September 28, 2023).
• Screening by risk level. Every applicant gets license and database checks. Moderate risk adds site visits before and after enrollment, and high risk adds a criminal background check and fingerprints (42 CFR 455.450). CMS says states may raise transportation above the minimum limited level. Indiana rates ambulatory and non-ambulatory common carriers high risk at enrollment and moderate at revalidation (matrix version 6.5, April 10, 2026).
• Application fee. CMS set it at $750 for applications submitted in 2026. States collect it before signing a provider agreement, unless you are enrolled in, or already paid it to, Medicare or another state (42 CFR 455.460).
• Ownership disclosure. You report each person with an ownership or control interest, and your managing employees, when you apply and within 35 days after any ownership change (42 CFR 455.104).
• Revalidation. The state revalidates every provider at least every 5 years (42 CFR 455.414).
• Health plans. A Medicaid plan may sign you while your state enrollment is pending, for up to 120 days (42 CFR 438.602).
• HIPAA. A provider that sends health information electronically in a covered transaction, such as an electronic claim, is a covered entity (45 CFR 160.103). See HIPAA for NEMT.
• NPI. Report changes to NPPES within 30 days (45 CFR 162.410). Indiana does not require an NPI for transportation specialties, which it treats as atypical providers. The NPI is free, so get one if any payer asks. See how to get an NPI number for NEMT.
• Hiring. Complete Section 2 of Form I-9 within 3 business days of a hire (8 CFR 274a.2). Report each new hire to your state within 20 days, unless your state sets a shorter time (42 U.S.C. 653a).
• USDOT registration. It covers commercial motor vehicles in interstate commerce, which 49 CFR 390.5 defines as vehicles rated 10,001 pounds or more, or designed or used to carry more than 8 passengers, including the driver, for pay. See DOT numbers for NEMT.

Mistakes that delay the first trip

• Buying vans before checking for a freeze. Minnesota and Colorado both paused new NEMT enrollment in the last three years.
• Names that do not match. The IRS letter, NPI record, insurance, and state filings all need the same legal name.
• Certificates that leave out the broker or the state. Ask your agent for each one’s exact wording before you send them.
• An owner left off the disclosure. Every person with an ownership or control interest is reported and screened.
• An application left to lapse. Indiana gives 21 business days to fix a rejected online application. New Jersey gives 6 months to request inspections.
• A ride before approval. MTM Health pays nothing for rides by drivers or vehicles it has not credentialed, and New Jersey and Minnesota bar rides before the state license.