Brokers

How to become a NEMT broker: federal rules, state bids, and the business model

Updated 6 min read

To become a Medicaid NEMT broker, you win a state competitive bid or a health plan subcontract to manage rides for a whole member population. Federal rule 42 CFR 440.170(a)(4) requires brokers to oversee providers, handle complaints, and avoid financial ties to the fleets they send trips to. Most broker contracts pay a fixed amount per member per month.

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What a NEMT broker does

A NEMT broker manages the ride benefit for a group of Medicaid members. It does not usually drive anyone. It takes ride requests, confirms the member and the trip qualify, assigns each trip to a transportation provider, watches quality, and pays the providers.

Virginia’s Medicaid agency describes the job in one line: each broker “enrolls providers, trains drivers, inspect vehicles, negotiates contracts and rates, assigns trips, and pays providers.” The broker sits between the payer and the fleets.

States use brokers under an option in federal Medicaid rules, 42 CFR 440.170(a)(4), which lets a state contract with a broker “in order to more cost-effectively provide non-emergency medical transportation services.” Health plans that run Medicaid managed care hire transportation vendors for the same job.

If you want the full definition first, see what a NEMT broker is. Our broker directory profiles the major brokers.

The federal rules every Medicaid broker must meet

Under 42 CFR 440.170(a)(4), a state broker must be:

  1. Chosen by competitive bid. The process must follow federal procurement standards and weigh the broker’s “experience, performance, references, resources, qualifications, and costs.”
  2. Responsible for oversight. The broker needs procedures to monitor member access and complaints and to make sure “transportation is timely and that transport personnel are licensed, qualified, competent, and courteous.”
  3. Audited by the state. The broker is subject to regular auditing and oversight by the state.
  4. Bound by a written contract. The contract must ban prohibited referrals and conflicts of interest, and make the broker liable for the full cost of any prohibited referral or subcontract.

Two more rules protect the benefit. Transportation providers may not give the broker any payment, rebate, gift, or service in kind. The broker may not withhold necessary transportation for financial gain.

Health plans that subcontract transportation fall under 42 CFR 438.230. The plan keeps ultimate responsibility for its contract with the state, and the state, CMS, and the HHS inspector general can audit the subcontractor’s records for 10 years after the contract period ends. Louisiana’s managed care manual puts it plainly: a plan “may elect to contract with a transportation broker but shall maintain ultimate responsibility.”

The conflict of interest rule for fleet owners

This is the rule that stops most operators. A Medicaid broker, including its owners, investors, officers, and employees, may not provide the trips itself. It also may not send trips to a provider it has a financial relationship with, or one where an immediate family member has a financial relationship.

The exceptions are narrow, and each one must be documented:

ExceptionWhen it applies
Rural areaNo other qualified provider is available except the broker
Specialized transportThe service is so specialized that no other qualified provider exists
Insufficient supplyOther qualified providers cannot meet the need
Government brokerThe broker is a government entity, with separate accounting and payment at actual cost

In practice, if you own a van company and want to become the Medicaid broker for the same area, expect to give up your financial ties to the fleet or keep it out of that program’s trips. Government brokers are the main exception, and even they must keep the brokerage’s accounts separate and document why their own service is the most appropriate, lowest-cost choice.

How states pick brokers: recent examples

Broker contracts change hands through procurements, and 2025 and 2026 were busy years.

StateWhat changedDate
GeorgiaVerida took over the Central, East, and Southwest regions from Modivcare and now serves all five regionsApril 1, 2026
ColoradoMediDrive became the single statewide broker, after an appeal of the first award and a second evaluationDenver metro July 1, 2026; statewide January 1, 2027
MontanaThe state signed a new NEMT broker contract with Modivcare, which takes over provider enrollment and billingAnticipated start October 1, 2026

Plans change vendors too. In Texas, Blue Cross and Blue Shield of Texas Medicaid members move from Modivcare to MTM Health on October 1, 2026. In Indiana, MDwise left the Healthy Indiana Plan and Hoosier Healthwise on January 1, 2026, and its broker, Modivcare, stopped serving those members. They now ride through WellTrans with Anthem, CareSource, or MHS.

What a state asks of a broker

A broker contract is a large operating commitment. Rhode Island’s contract with MTM Health (the version effective July 1, 2025) shows the scale:

  • Call center. Answer 95% of calls on average within 30 seconds, keep call abandonment at 5% or less, and let no more than 1% of calls get a busy signal.
  • Open network. Contract with any transportation provider “who is willing and able to meet program requirements.”
  • Trip assignment rules. Use an algorithm that weighs the right vehicle, member and facility preferences, provider capacity, geography, quality, and equitable distribution.
  • Service standards. For example, will-call return pickups within 45 minutes of the call.
  • Provider rates. One standard fee schedule for every provider, approved by the state each year and posted on a public page.
  • Prompt payment. Pay clean provider claims within 30 days, with 12% annual interest on late clean claims.
  • Remedies. Liquidated damages for missed standards and possible forfeiture of the performance bond.

A bidder has to show it can staff, fund, and run all of that from the first day.

The business model: capitation and its risk

Most brokers are paid per member per month, not per trip. Georgia pays its brokers “a monthly capitated rate based on the number of eligible Medicaid members residing in their contracted region(s).” Modivcare reported that 80.9% of its NEMT revenue in 2024 came from capitated contracts.

Rhode Island publishes its rates. Its contract for state fiscal year 2026 (July 2025 through June 2026) paid MTM $1.21 per member per month for children, $12.65 for adults 19 to 64, and $29.64 for members 65 and older.

A worked example

The utilization figures below are illustrative, not Rhode Island data.

Suppose a broker covers 100,000 adults at $12.65 per member per month. Revenue is $1,265,000 a month, whether anyone rides or not.

ScenarioTrips per monthAverage paid per tripTrip costLeft for operations and margin
Plan25,000$38$950,000$315,000
Rides up 15%28,750$38$1,092,500$172,500
Rides up 15%, rates up 5%28,750$39.90$1,147,125$117,875

A 15% rise in rides cuts the money left for the call center, staff, technology, and profit by almost half. Brokers carry that risk until the contract is repriced. Modivcare, which called itself the nation’s largest NEMT manager in its 2024 annual report, filed for Chapter 11 on August 20, 2025 and emerged on December 29, 2025.

Realistic paths into brokerage

  1. Bid on a state contract. Watch your state Medicaid agency’s procurement page and your state’s bid portal for NEMT requests for proposals. Expect to show experience, a network plan, a call center, systems, and financial strength.
  2. Subcontract with a Medicaid health plan. Plans hire transportation vendors for their members. The plan keeps responsibility, so it will audit you like the state would.
  3. Take one piece of the broker job. Some programs split the work. CareOregon’s NEMT manual lists Health Share of Oregon’s setup: Ride Connection as network manager, ComTrans of Oregon as dispatch manager, and Transdev as call center manager.
  4. Coordinate non-Medicaid rides. Arrange rides for hospitals, senior living communities, and families, and pass them to partner fleets. This needs no Medicaid broker contract.

For a fleet owner, the conflict rule makes more contracts the more direct way to grow. Our guides to broker contracts and facility contracts cover both sides.

Running the fleet side in HealthRide

HealthRide is built for the transportation companies that complete the trips. Facilities can request rides and track vehicles live through their own portal. Dispatch assigns every trip on one board, and completed trips turn into invoices priced from each payer’s rates.

Frequently asked questions

Does a NEMT broker need a license?
There is no federal NEMT broker license. A Medicaid broker needs a contract: either a state award through competitive bidding or a subcontract with a Medicaid health plan. The state or plan sets the requirements in its request for proposals and contract, including call center standards, a provider network, reporting, and sometimes a performance bond.
Can a NEMT provider also be a broker?
Generally not for the same program. Federal rules bar a Medicaid broker from providing trips itself or sending trips to a provider it has a financial relationship with. The exceptions are narrow and documented: rural areas with no other qualified provider, transport so specialized that no one else can do it, too few other providers to meet the need, or a government broker.
How do NEMT brokers make money?
Most are paid a fixed amount per enrolled member per month, whether members ride or not. The broker pays transportation providers for each trip and keeps what is left after trips and operating costs. If members ride more than expected, the broker absorbs the cost.
How big are the largest NEMT brokers?
Very large. Modivcare reported about 29.5 million average monthly eligible members and about 36.8 million trips in 2024, across 48 states and the District of Columbia. MTM Health describes itself as serving 24 million members a year with 35 million annual trips in all 50 states and the District of Columbia.
How is a NEMT broker different from a NEMT provider?
A broker manages the benefit. It takes ride requests, checks eligibility and authorization, assigns trips, oversees providers, and pays them. A provider owns or runs the vehicles and drivers that complete the trips. The broker is paid by the state or plan, and the provider is paid by the broker.
Can I broker private pay or facility trips instead of Medicaid?
Yes. Arranging rides for hospitals, senior living communities, or families and passing them to partner fleets does not need a Medicaid broker contract. It does need written agreements with each fleet and customer, insurance, care with patient information, and a check of any state or local rules on arranging transportation. The federal Medicaid broker rules apply only to Medicaid broker programs.

Official resources

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