Harassment prevention training for NEMT companies: state mandates, rider harassment, and driver reporting

Which states require training, and how often

A handful of states require private employers to train staff on sexual harassment, and each sets its own headcount, hours, and schedule. If your drivers or dispatchers work in more than one of these states, follow each state’s rule for the people who work there.

In the six states below, New York and Illinois cover every employer every year, while California, Connecticut, Delaware, and Maine start at 3 to 50 employees.

The details below each rule change what you buy and what you file:

• California. One hour for non-supervisors and two hours for supervisors, with a section on abusive conduct and one on harassment based on gender identity, gender expression, and sexual orientation. Seasonal and temporary staff hired for under six months train within 30 calendar days or 100 hours worked, whichever comes first. The state Civil Rights Department posts online courses on its website, and using them satisfies the law.
• New York. Every employer adopts the state’s model policy or an equal one, and the training must be interactive. Each employee gets the policy and the training material in writing at hire and at every annual training, in English and in the employee’s primary language when the state has a template in it.
• Illinois. Employers use the state’s free model program or their own that meets its minimums.
• Connecticut. Employers with 3 or more employees also post the law and, when the employee has an email address, email each new hire a copy of the information within three months, with “Sexual Harassment Policy” or similar words in the subject line. The state human rights commission offers its training online at no cost.
• Delaware. Supervisors get additional interactive training on the same two-year cycle. Employees who have worked less than six months in a row are not owed the training, and contractors do not count toward the 50. Every employer with 4 or more employees in Delaware hands new hires the state’s information sheet.
• Maine. Supervisors and managers get extra training within a year of starting. Every employer, whatever its size, posts the state poster and gives each employee written notice every year, and companies that must train hold training records for three years or more.

Brokers ask for it too

Some broker programs require harassment training on top of state law. MTM Health’s Virginia fee-for-service handbook (May 2026) lists a Sexual Harassment Training module, described as “prevention of harassment and appropriate workplace conduct,” among the courses drivers complete before MTM authorizes them to transport members.

Brokers also treat harassment involving a member as an incident to report. Modivcare’s 2025 provider training lists sexual harassment under the sexual misconduct category of critical incidents, which it says must be reported immediately. Modivcare’s attestation separately requires providers to alert Modivcare without delay to any incident involving their drivers or vehicles.

When the harasser is a rider

Harassment law does not stop at your own staff. The EEOC’s sexual harassment regulation, 29 CFR 1604.11(e), says an employer may be responsible for sexual harassment of its employees by non-employees when it “knows or should have known of the conduct and fails to take immediate and appropriate corrective action.” The EEOC weighs how much control the employer had over the non-employee. Its harassment page names customers as one kind of non-employee an employer may have to address.

A driver alone in a van with a rider is exactly that situation. You cannot fire a rider, but you do control the trip: who drives it, whether an attendant rides along, and what gets reported to the broker. The ADA transportation rule at 49 CFR 37.5(h) lets a provider refuse service to a person whose conduct is “violent, seriously disruptive, or illegal.” The same rule bars refusing a rider just because a disability causes “involuntary behavior that may offend, annoy, or inconvenience” others. That distinction matters when a rider’s medical condition affects behavior, and our guide to difficult or unsafe riders covers how to handle it on the road.

Two state rules widen who is protected. California’s harassment ban, Gov. Code 12940(j), applies to employers with even one employee and covers people who provide services under a contract, so it can reach 1099 drivers who meet its definition. California also holds employers responsible for nonemployees’ harassment of employees and contractors under the same knew-or-should-have-known standard. New York’s Executive Law 296-d makes employers liable for discrimination against contractors working in their workplace when they knew or should have known and failed to act.

One federal document has changed. A Texas federal court vacated parts of the EEOC’s 2024 Enforcement Guidance on Harassment in the Workplace on May 15, 2025, and the Commission voted on January 22, 2026 to rescind it entirely. The EEOC said the anti-harassment laws and Supreme Court precedent remain in place, so the regulation above still applies. Any course that presents the 2024 guidance as current needs an update.

A reporting path drivers can use from the road

A driver being harassed needs a short, known path, because there is no supervisor down the hall. Write it into your passenger conduct policy and walk through it in training.

1. Get safe first. If the rider’s behavior makes it unsafe to drive, stop somewhere safe off the road and call dispatch. MTM Health’s Virginia handbook requires exactly that, parking out of traffic and asking dispatch for help, whenever a rider’s behavior interferes with driving safely. Call 911 for threats, assault, or anything a driver cannot safely manage.
2. Tell dispatch right away. The driver says what happened, when, and who was in the van. Dispatch decides whether the trip continues, another driver takes over, or the trip ends.
3. Record it before the shift ends. Plain facts in the driver’s own words, with the trip, the time, and any witnesses. Keep it with the trip record.
4. Report to the broker. Follow the broker’s incident rules. For Modivcare trips that means reporting immediately.
5. Give drivers a second door. Name a person other than the driver’s dispatcher who can take a complaint, in case the dispatcher is part of the problem.
6. Protect the driver who reported. Do not cut hours or hand out worse routes after a complaint. New York’s model policy has to state that retaliation is unlawful, and Delaware and Maine build protection against retaliation into their training and notice rules.

What a course should cover for a van company

The states spell out minimum content. Across them, a course should explain what sexual harassment is with examples, cover the federal and state laws and the remedies available, describe your internal complaint process and the state agency’s process, and state that retaliation is illegal. California adds abusive conduct and harassment based on gender identity, gender expression, and sexual orientation. California, New York, Delaware, and Maine all call for supervisor content on preventing and correcting harassment.

State model courses are written for every kind of workplace, so add a short NEMT section. Cover a rider’s sexual comments or touching, a rider who keeps asking a driver for a date, harassment between drivers and dispatchers over the radio or phone, and the reporting path above. Our cultural competency training guide covers the related point that offensive jokes about riders or coworkers can become harassment complaints. A workplace violence prevention plan covers threats and assaults that go beyond harassment.

Training dates in HealthRide

Yearly and two-year training cycles drift when each employee was hired in a different month. HealthRide keeps each driver’s licenses and certifications in the fleet and credentials registry with expiration dates. Add harassment training as a certification with its renewal date, and HealthRide reminds you before it is due and flags it if it has lapsed when you assign a trip.