Vehicle Replacement Plan for a NEMT Fleet: Age Limits, Miles, and a Monthly Reserve

Every van in your fleet has a date it has to leave service, and the date comes from rules you do not control: a broker’s mileage cap, a city’s age limit, a grant’s useful life. This worksheet puts every van’s dates, price, and savings on one calendar, so the replacement is paid for before the day it is forced. To decide whether one van is worth another repair, use when to replace a NEMT vehicle. This page is the fleet-wide plan that guide leads to.

How to use this template

1. Collect the limits in writing (Part 1). Ask each broker, each city or county permit office, and each grant manager for the vehicle age limit and the mileage limit, how age is counted, and whether a waiver exists. NEMT vehicle requirements lists many of them. A rule you only remember is a rule you will miss.
2. Read every odometer on the first of the month (Part 2). Take the average of the last three months for miles per month. A van that runs twice as much as the others reaches its limit in half the time.
3. Work out each retirement date (Part 3). For every program a van serves, find the date it reaches the age limit and the date it reaches the mileage limit: miles left divided by miles per month. The earliest of all those dates is the retirement date.
4. Back up to the order date. Subtract the delivery time your dealer gives you in writing, plus a few weeks for insurance, the broker’s or city’s inspection, and permits and decals.
5. Price the replacement from two written quotes (Part 4). Match the seating, lift, and engine your work needs. Add taxes, tags, signs, and equipment so the total is the real cost. For the sale value, use a dealer or auction offer on the old van, not the price you hope for.
6. Set the monthly amount. If you will finance, save the down payment and closing costs. If you will pay cash, save the whole gap. The lease vs buy calculator shows what each choice costs over the years you keep the van.
7. Move the money on payday (Part 6). Open a separate savings account, deposit the fleet total every month, and write each deposit in the ledger so a lean month shows.
8. Check the tax on the sale (Part 5) and review twice a year (Part 7). Do the tax line the year before you sell, with your preparer. Redo the odometers, quotes, and limits each January and July.

The template

Part 1: Limits that apply to your fleet (fill in once, update when a contract or permit changes)

Program, permit, or grant	Age limit and what it counts from	Mileage limit	Waiver or extension (how and by when)	Where it is written (document, section, date)

Part 2: Where each van stands today

Van number	Year, make, model, last 6 of VIN	Date it entered service for you	Odometer today and date read	Miles per month (3-month average)	Lift cycle count and lift warranty end date	Who holds the title or a lien (you, lender, grant)

Part 3: When each van has to leave service

Van number	Programs it serves	Date it reaches the age limit	Miles left to the mileage limit	Months left (miles left divided by miles per month)	Date it reaches the mileage limit	Retirement date (the earliest date)	Delivery time for a replacement (months)	Order by (retirement date minus delivery and set-up time)

Part 4: What each replacement costs and what to set aside every month

Van number	Quoted price and quote date	Taxes, tags, signs, equipment	Total cost	Expected sale or trade value of the old van	Part you will finance or a grant will pay	Amount to save (total cost minus sale value minus financed or grant part)	Months until the order date	Set aside per month
Fleet total

Part 5: Tax check on each sale (fill in the year before you sell, with your tax preparer)

Van number	Original cost	Depreciation taken, or the mileage-rate depreciation	Tax basis today (cost minus depreciation)	Expected sale price	Expected gain or loss (sale price minus basis)	Tax to set aside (from your preparer)

Part 6: Reserve ledger (one line for each deposit or withdrawal)

Date	Deposit	Withdrawal	What it was for	Balance after	Initials

Part 7: Twice-a-year review

Review date	Odometers updated	Quotes refreshed	Limits rechecked with each program	What changed	Initials

Example: one van through Parts 3 and 4

Every number here is an example, so use your own. Say today is October 6, 2026. The van was built in June 2014 and its odometer reads 205,000. It runs 2,500 miles a month. It serves one program that retires vans at 250,000 miles and another that bars vans 15 years after the date they were manufactured.

1. Mileage date. 250,000 minus 205,000 leaves 45,000 miles. At 2,500 a month, that is 18 months, so the van reaches the mileage limit in April 2028.
2. Age date. June 2014 plus 15 years is June 2029.
3. Retirement date. The earlier of the two is April 2028.
4. Order date. The dealer says delivery takes 4 months, and the broker’s inspection, the decals, and the insurance change take about a month. April 2028 minus 5 months is November 2027, which is 13 months away.
5. Cost. The quote is $78,000 with taxes, tags, signs, and equipment. The old van should sell for $6,000. You will finance 80 percent, which is $62,400.
6. Amount to save. $78,000 minus $6,000 minus $62,400 leaves $9,600.
7. Monthly set-aside. $9,600 divided by 13 months is $738 a month. Paying cash instead would mean saving $72,000 over the same 13 months, which is $5,538 a month. Seeing that number early is the reason to have a plan.

How each program counts a van’s age

No federal rule caps a NEMT van’s age or miles. Each program sets its own limit and its own way of counting, and the counting changes the date. Write the counting rule in Part 1, not only the number. The programs below are a sample; NEMT vehicle requirements lists more, and when to replace a NEMT vehicle has the waiver and extension steps for Massachusetts and New York City.

Program	Age counted from	Limit
Rhode Island NEMT, vans added after July 31, 2024	Model year, checked at the first inspection	No more than 4 model years old and 150,000 miles at the first inspection, then in service until 250,000 miles
Rhode Island NEMT, vans added before July 31, 2024	Odometer (the policy states no age limit)	Out of service at 300,000 miles
Massachusetts HST (MART)	Date of manufacture	Demand-response vehicles under 15 years. Program-based rides: vans under 7 years, lift vans under 9
New York City paratransit	Date first licensed	Retired 7 years after it was first licensed
Portland, Oregon NEMT	Manufactured date, whatever the purchase date	May not operate 15 years after the manufactured date

Rhode Island’s EOHHS policy (updated September 16, 2024, effective October 31, 2024) applies the four-year test only when a van is first inspected, so a van added at three years old keeps running, as long as it passes its yearly inspections, until its odometer reaches 250,000. See Rhode Island.

Massachusetts and Portland count from the date of manufacture, so a van leaves on the anniversary of that date, not at the end of its model year. Massachusetts brokers can grant age waivers in six-month steps for up to two more years. MART’s Attachment G (revised July 1, 2025) also requires one fully operational spare vehicle comparable to the ones in primary use, which a retirement plan should count. See MART.

New York City’s rule (TLC section 60A-34) retires a paratransit van on its retirement date even if it still passes the state inspection, and an extension request is due at least two months ahead. See New York City. Portland’s code (16.40.750) lets wheelchair-accessible vehicles that meet section 16.40.935 apply for an age exemption, which lasts two years and covers the vehicle categories an administrative rule names. See Portland.

Nashville has an age and mileage limit in its metro code and a yearly waiver. Under rule 501 of the Metropolitan Transportation Licensing Commission (amended August 18, 2026), the waiver request is due by December 1 each year, and a waived vehicle needs a mechanical inspection every six months. See Nashville.

Section 5310 vans: when you can replace them and what a sale returns

If a state Section 5310 grant paid for a van, FTA keeps a financial interest in it, and the replacement date is not yours alone. See Section 5310 grants for how NEMT companies take part.

• Useful life. Circular 5010.1F (applicable November 1, 2024) sets a minimum useful life of at least 4 years or 100,000 miles, whichever comes first, for light-duty vehicles such as regular and specialized vans and sedans. A medium-size light-duty bus is at least 5 years or 150,000 miles. Useful life starts the day the vehicle enters revenue service. Miles driven out of service and long periods off the road do not count.
• Replacement. Property being replaced must have reached its minimum useful life. Oregon applies this to its Section 5310 program: a van to be replaced must meet its useful life in miles or years, and the state will not reimburse the new van until it does (2027 to 2029 application instructions, March 2026). Oregon’s own table lists modified vans and modified minivans at 4 years or 100,000 miles (revised January 3, 2024).
• Selling early. Any disposition before the end of useful life needs FTA’s prior written approval, and FTA is entitled to its share of the remaining value. A trade counts as a sale.
• Selling after the useful life. If the van sells for $10,000 or less, you keep the proceeds and owe FTA nothing. Above $10,000 on a van sold after November 15, 2021, you keep $5,000 plus, of the rest, a percentage equal to the local share you paid when you bought it. The remainder goes back to FTA, and you may not deduct selling costs. Under 2 CFR 200.313(e), a subrecipient asks the pass-through entity for disposition instructions when its award terms require it, so call your state grant office before you list the van.

For example, a van bought on an 80 percent federal and 20 percent local split sells for $14,000 after its useful life. By the circular’s formula you keep $5,000 plus 20 percent of the remaining $9,000, which is $1,800, for a total of $6,800, and $7,200 goes back to FTA. A state grant office can give a subrecipient its own disposition steps, so put the figure it gives you in Part 4, not the sale price.

Taxes on the old van: what goes in Part 5

The old van leaves a tax result behind. NEMT business taxes covers depreciation choices in full. These are the points the worksheet uses.

• Recovery period. Automobiles, taxis, buses, and trucks are 5-year property under MACRS (IRS Publication 946, 2025).
• Gain. The sale of business property is reported on Form 4797. A van held more than a year and sold at a gain goes in Part III as section 1245 property, and the gain is ordinary income up to the depreciation allowed or allowable. Any gain above that is a section 1231 gain (Publication 544 and the Form 4797 instructions, both 2025 editions). A sale at a loss held more than a year goes in Part I.
• Zero basis. If you took a 100 percent first-year write-off, the van’s basis is zero. The whole sale price is gain, and because it is less than the depreciation you took, all of it is taxed as ordinary income.
• Mileage-rate vans. If you used the standard mileage rate, part of each business mile lowers the van’s basis: 35 cents a mile for 2026 and 33 cents for 2025 (IRS Notice 2026-10, which the July 2026 rate change in Announcement 2026-11 left in place).
• Trade-ins. For 2018 and later years, like-kind exchange treatment applies only to real property, so a van traded in toward a new one is a sale for tax purposes (Form 8824 instructions, 2025).

Your preparer figures the actual tax. The sheet only needs a number to set aside, so you are not surprised by the bill.