Emergency preparedness for NEMT companies: hurricanes, floods, outages, and evacuations

What the plan covers and where it stops

An emergency plan decides in advance how your company keeps riders safe when normal operations break: a hurricane, a flood, a long power or phone outage, a fire at your lot, or an order to evacuate. Daily weather calls, like whether to run on an icy morning, belong in a narrower bad weather policy. This plan picks up where that one ends, when the office, the phones, the fuel supply, or the facilities you serve stop working normally.

Some payers already require one. CareOregon’s transportation provider manual (February 2024), the standard it sets for the brokerages serving its members, says brokerages and the providers they contract with need written procedures for bad weather, disaster events, business continuity, and recovery. Those procedures must at least address staff training, how notices go out, and educating members. Georgia’s NEMT policy manual, in its July 1, 2026 version, requires its brokers to have a continuity and disaster recovery plan approved before operations begin, update it every contract year, and run a yearly drill with a written report to the state.

Ready.gov breaks continuity planning into six steps: prepare, define objectives, identify and rank risks, develop strategies, set up teams, and test. The sections below follow that order for a NEMT company.

Start with your hazards and the work you cannot lose

List the events likely where you operate, then the functions that must survive them.

• Hazards. Hurricanes and storm surge near the Gulf and Atlantic coasts, river and flash floods, wildfire smoke and road closures, ice storms, and grid failures. The National Weather Service advises coastal residents to find out from local emergency management whether they live in a hurricane evacuation zone. Check your lot, your office, and the facilities you serve.
• Functions. Taking ride requests, dispatching, reaching drivers, keeping trip records, and paying for fuel. For each one, name who does it, who backs them up, and how it works with no power or internet at the office.

Decide in advance which rides keep running as conditions get worse. CareOregon’s manual asks each brokerage to set levels of event severity and group trips by type (life-sustaining rides must be one of the groups), then tell providers which rides may continue at each level. Plan to keep dialysis rides and similar life-sustaining trips going longest.

Decide who is in charge if the owner cannot be reached. Federal rules require hospitals, nursing homes, and dialysis centers to write delegations of authority and succession into their own plans, and the same idea works for a transportation company. One named person sets the service level, and one backup takes over.

The federal rule that makes facilities plan transport

CMS’s emergency preparedness rule, published September 8, 2016, took effect that November, and providers had to comply by November 15, 2017. It now applies to 18 types of Medicare and Medicaid providers and suppliers. For a NEMT company, the key point is that several of your customers must plan how their patients will leave the building.

• Hospitals, nursing homes, and PACE organizations must have policies for safe evacuation that address transportation, the care needs of evacuees, where they will go, and how staff reach outside help (42 CFR 482.15, 483.73, and 460.84).
• Dialysis facilities must plan safe evacuation and arrange other facilities to take their patients if they cut back or close (42 CFR 494.62). Their staff must tell patients what to do, where to go if the area is evacuated, and who to contact, with a backup emergency number for the facility.
• Review cycles. Nursing homes review their plans at least every year. Hospitals, dialysis facilities, and PACE organizations review theirs at least every 2 years.
• Outside companies are in the plan. Nursing home and dialysis communication plans must list contact information for entities providing services under arrangement, and their training must reach those individuals too.
• Drills. Nursing homes must test their plans at least twice a year, and dialysis facilities at least once a year, with full-scale or facility-based exercises on a set cycle.

CMS’s interpretive guidance for surveyors (Appendix Z) goes further. Facility transfer agreements should include pre-arranged transportation between facilities, in writing, such as memorandums of understanding. Surveyors are told to ask facility leadership to explain the transportation arrangements for an evacuation. The same guidance suggests triaging evacuees by acuity and by mobility (stretcher, wheelchair, or ambulatory), and sending a short hard-copy health summary with each patient.

Some states add their own layer. Florida’s nursing home planning criteria (AHCA Form 3110-6006, April 2025) ask each facility to name its evacuation transportation, say whether it is owned or contracted, attach the transportation agreements, and describe how records, medications, and equipment will travel. They also ask how residents will get back to the home facility when the event is over.

Evacuation agreements: what to put in writing

When a facility asks you to be in its plan, write down what you can deliver. The facility transportation agreement template covers routine work; an evacuation addendum should add these points:

1. Committed capacity. Vehicles by type, wheelchair stations, stretcher capacity, and drivers, plus how many hours of notice you need to deliver them.
2. Activation. Who at the facility can activate the agreement, the primary and alternate numbers on both sides, and what happens if phones are down. Appendix Z mentions satellite phones as one alternate means facilities may use.
3. Who rides along. Appendix Z says critically ill evacuees should be accompanied by facility staff who can provide care on the way when the transportation service does not supply trained medical professionals. Your drivers transport; they do not provide care.
4. What travels with each resident. Records, medications, supplies, and equipment such as oxygen, packed by the facility. Florida’s criteria make facilities plan how records, medications, supplies, and medical equipment move.
5. Tracking. Nursing homes must record the name and location of the receiving facility for each relocated resident. Give the facility your manifest for every run so its list matches yours.
6. Payment. CMS’s 2023 coverage guide lets Medicaid NEMT relocate a beneficiary whose nursing home or other medical facility a disaster has left unsafe to another facility that can still serve them, including one in a different state. Ask each broker how it authorizes these trips, and set a private rate for the rest.
7. Drills and review. Join the facility’s exercises, and review the addendum when the facility reviews its plan.

Do not sell the same van twice. Nursing homes in one evacuation zone are likely to call at the same time. The OIG’s nursing facility compliance guidance (November 2024) tells facilities that hire a transportation company for emergencies to make sure the company has the capacity to move their residents in a disaster covering a wide area. Appendix Z also warns facilities that contracts may go unfulfilled in a disaster. Keep a running total of what you have committed by zone, and turn down agreements that exceed it.

Vans, fuel, drivers, and the office before the storm

Most of the work happens in the days before landfall, and the groundwork happens earlier. The National Weather Service says the best time to prepare is before hurricane season starts on June 1.

• Fuel. Fill every van and top off again as the forecast firms up. Keep fuel cards and some cash, because outages can close stations and ATMs.
• Where the vans sleep. Move vans off low-lying lots and away from trees and flood-prone streets, and split the fleet between two locations if you can.
• Phones and power. Give each driver a power bank. Ready.gov’s outage guidance recommends planning for portable chargers and other backup power. If you run a generator at the office, keep it outdoors and at least 20 feet from windows, doors, and attached garages.
• Drivers’ own families. Drivers who are still securing their own homes may not be able to come in. Ask early who can work, and plan shifts around it.
• Flood water. No van enters it. Ready.gov warns that fast-moving water only 6 inches deep can knock a person off their feet, and that a foot of moving water can carry a vehicle off.
• Evacuation orders. Ready.gov tells people in a mandatory evacuation zone to leave immediately when officials order it. Stop routine pickups there, finish getting riders home, and route further requests to the broker and emergency management.

The breakdown response plan covers a van stranded with riders aboard, and the guide to rider medical emergencies explains what to do when a trip turns into a 911 call.

Reaching the riders who depend on you

Power outages turn some riders into emergencies. A free HHS map, updated monthly, shows how many Medicare beneficiaries in a state, county, or ZIP code rely on electricity-dependent medical equipment, with separate counts for those who also rely on facility dialysis or oxygen services. It is a quick way to size the demand your area could see.

Point riders to their local registry for evacuation help. Florida law has the state emergency management division, with each local agency, keep a registry of people who would need help evacuating or sheltering because of a disability or impairment. Texas runs the free State of Texas Emergency Assistance Registry, which people can join online or by dialing 2-1-1. Registration lasts one year, and the state is clear that it does not guarantee a specific service. Your company is part of a rider’s evacuation plan only if you have agreed to be.

For dialysis riders, call each center before the storm. Ask for its alternate emergency number, whether it will change shifts or close, and which center its patients will use if it does. Then text riders early with their new pickup times; Ready.gov advises texting and saving phone calls for emergencies during a hurricane.

After the event: reopening and recovery

Reopen in stages. Check every van, the roads in each zone, and which facilities are open before you accept routine trips again. Under CareOregon’s manual, a provider that has cut back tells the brokerage how much capacity it lost, and the same call should go out when capacity returns.

Keep a record of every cancelled and delayed trip, with the reason and who was told, for the broker, your insurer, and any later audit. If you suffered damage in a declared disaster area, the SBA offers business physical disaster loans of up to $2 million for uninsured losses to real property, machinery, equipment, and inventory, and economic injury loans for working capital to small businesses that cannot get credit elsewhere. The combined maximum is $2 million, with payments deferred for the first 12 months.

Finally, meet with your staff within a week, write down what failed, and update the plan and your policies and procedures binder while the lessons are fresh.

When the office goes dark

HealthRide’s driver app keeps working without cell service, and what drivers record offline syncs when the signal returns. Dispatchers can move or cancel trips on the dispatch board from any connected laptop, and announcements in team chat reach every driver at once.