Setting up a NEMT phone system: lines, routing, after-hours, and call recording
A NEMT phone system needs one public number that stays with the company, direct lines for brokers, facilities, and drivers, and routing that sends anyone asking about today's rides straight to dispatch. Keep it answered until the last trip ends. Federal law lets one party consent to recording, but states such as California, Florida, Pennsylvania, and Washington require every party's consent, so announce recording on every call.
On this page
What your phones have to cover
A NEMT phone system has four kinds of callers, and each one needs a different path. Riders and families call to book, change, or ask where the van is. Facilities call about discharges, dialysis chairs, and standing orders. Broker staff call about trip offers, reroutes, and complaints. Your own drivers call about delays, no-shows, and problems at the curb. A single number that rings one desk phone works for a two-van company. It breaks down once one person is handling a rider at the curb and a broker offer at the same time.
Brokers write reachability into their contracts:
- MTM’s Pennsylvania transportation provider agreement (January 2023) says the provider’s dispatch or office has to respond immediately during normal business hours, and requires working computers and internet to support the service.
- WellTrans’s provider agreement (revised October 2025) has the provider keep dispatch and recovery staffed until the last assigned trip is done. Your line stays open until the last rider is home, not until 5 p.m.
- Louisiana’s Medi Trans operations manual (revised February 2025) asks each provider for dedicated phone numbers that reach a manager at its dispatch center, along with an email inbox that staff watch closely.
- For trips on or after October 1, 2026, MTM Health arranges Virginia’s fee-for-service Medicaid rides. Its Virginia handbook (approved August 2026) has MTM dispatchers calling providers four or five days ahead of each appointment to confirm the trip is accepted. Someone has to pick up.
Numbers to set up, and who gets each one
Plan your numbers around who calls, not around your org chart. For a small company, one cloud phone account can carry every line below.
| Number | Who gets it | Where it appears |
|---|---|---|
| Main public number | Riders, families, the public | Website, vehicles, confirmation texts, invoices |
| Broker and facility line | Broker staff, hospital discharge planners, dialysis clinic social workers | Broker profiles, facility agreements |
| Driver line | Your drivers only | Driver app, driver handbook |
| On-call number | Brokers and facilities after hours | After-hours greeting, broker profiles |
| Outbound caller ID | Shown when staff call riders | Set to the main number so riders recognize it and call back |
Pick the main number carefully, because it gets painted on your vans. MTM’s Virginia handbook requires the company’s name and phone number on each side of the vehicle, in permanently attached letters no shorter than 3 inches. Louisiana’s Medi Trans manual wants the provider’s name and phone number plus the vehicle number shown on the driver and passenger sides, plus the back of any van. Our guide to vehicle markings covers the other lettering rules.
The number can outlive any phone company. Under FCC rules you can move a number between wireline, internet, and wireless providers as long as you stay in the same geographic area. The old company cannot refuse the port even if you owe it a balance, and simple ports are processed in one business day. Open the new account first, then request the port, and cancel the old service only after calls arrive on the new one.
Two more setup details matter:
- 911 from every phone. Kari’s Law applies to multi-line phone systems installed after February 16, 2020. Under 47 CFR 9.16, anyone installing or operating one must let users dial 911 directly, with no 9 or other prefix. The system must also alert a central point where someone will notice, and send a dispatchable location with the call. Phones used away from the office must send location too: automatically where that is feasible, otherwise from an address the user keeps updated or the best location the system can find. That covers a dispatcher’s softphone at home. Ask your provider to confirm all three.
- Company numbers for drivers. When drivers call riders from personal phones, riders see a number they do not know, and the call history walks out the door with the driver. Our comparison of company and personal phones for drivers covers cost and reimbursement laws.
Routing each caller to the right person
Route by what the caller needs in the next hour. A rider standing outside a clinic cannot wait behind someone booking a trip for next Tuesday.
| Caller | Best route | Why |
|---|---|---|
| Rider asking about a ride today | Menu option straight to the dispatch ring group | The only person who can answer sees the live board |
| Rider booking or changing a future ride | Scheduling queue, with voicemail after a set wait | Bookings can wait minutes, not hours |
| Broker staff | Direct line that skips the menu | Reroutes and offers are time limited |
| Facility staff | Direct line or the same priority group as brokers | Discharges and chair times cannot sit in a queue |
| Driver | Separate number or company chat, never the public menu | Drivers need an answer while parked, fast |
| Billing questions | Office voicemail or a billing extension | Rarely urgent, easy to batch |
Keep the menu to three or four choices. Set each ring group to roll to a second person after a fixed number of rings, and send overflow to a named voicemail box that someone owns. A voicemail box that belongs to nobody fills up and stays full.
Read the call report once a week. Four numbers tell you most of what you need: how long callers wait for an answer, how many hang up before anyone picks up, how many missed calls got a callback, and which hours bring the most calls. When most calls ask where the van is, the fix is usually better rider updates, not another person on the phones.
Plan for callers who cannot use the menu the usual way. The Justice Department’s ADA guidance says businesses covered by the ADA must accept calls made through the telecommunications relay service (dial 711) and video relay service, and staff must treat relay calls like any other call. Train people not to hang up when an operator introduces the call. For riders who speak little English, add a phone interpreter service your staff can conference in. Our guide to language access covers what Medicaid-funded providers owe those riders.
After-hours coverage and voicemail
Decide what “closed” means before the phones decide for you. For example, a company that closes the office at 5 p.m. may still have dialysis returns at 7 p.m., and WellTrans’s agreement expects dispatch coverage until those trips are done. There are three practical ways to cover evenings: forward the dispatch group to an on-call phone, use the phone app on a dispatcher’s cell, or hire an answering service. Our guides to after-hours coverage and outsourcing the phones weigh the options.
Set the schedule in the phone system itself so it switches at the same time every day, with a separate holiday schedule. Then write a greeting that tells callers four things:
- Your service hours
- How to reach dispatch about a ride already on the road
- When you will call back
- What to do in an emergency (call 911)
Voicemail is a promise. Assign one person to clear it at set times, log every message into the trip or a call log, and call back within the time the greeting states.
Messages you leave for riders need care too. HIPAA’s safeguard rule (45 CFR 164.530(c)) calls for reasonable steps to limit incidental disclosures. In practice, a message should give the company name, the time of the pickup, and a number to call back, and nothing about the appointment or the rider’s condition.
Outbound confirmations are part of the job. The July 2026 Rhode Island handbook from MTM tells providers to reach each member 24 hours ahead of the trip and confirm the scheduled pickup time. Calls that show your main number are easy for riders to recognize, and riders who miss one know which number to call back.
Call recording and consent
Recording calls helps you train staff and settle “nobody told me” disputes, but the consent rules depend on where the callers are. Federal law (18 U.S.C. 2511(2)(d)) allows a recording when one party to the call consents. These states require more:
| State | Statute | What it requires |
|---|---|---|
| California | Penal Code 632 | Consent of all parties to record a confidential communication. Section 637.2 lets an injured person sue for the greater of $5,000 per violation or three times actual damages. |
| Connecticut | Gen. Stat. 52-570d | All parties’ consent in writing or at the start of the recording, a recorded verbal notice at the start, or a warning tone about every 15 seconds |
| Florida | Stat. 934.03(2)(d) | Prior consent of all parties |
| Illinois | 720 ILCS 5/14-2 | No surreptitious recording of a private conversation unless every other party consents |
| Maryland | Cts. & Jud. Proc. 10-402(c)(3) | All parties’ prior consent |
| Massachusetts | G.L. c. 272, s. 99 | No secret recording unless every party gave prior authority |
| Montana | MCA 45-8-213(1)(c) | No recording with a hidden device without the knowledge of all parties |
| New Hampshire | RSA 570-A:2 | Consent of all parties |
| Pennsylvania | 18 Pa.C.S. 5704(4) | All parties’ prior consent |
| Washington | RCW 9.73.030 | Consent of all participants, including calls between points inside or outside the state |
That list covers the statutes above, not every state or every court ruling. Rules for in-person conversations differ in some states. Take a specific legal question to your attorney.
The practical answer is the same everywhere: announce it. Play a short recorded message at the start of every inbound call (“Calls are recorded for quality and training”). Have staff say the same thing at the start of outbound calls, or have the system play it. Washington’s statute treats an announcement to all parties as consent, as long as the announcement is recorded too. Connecticut’s accepts a recorded verbal notice at the beginning.
Recordings raise a HIPAA question as well. A call about a rider’s dialysis schedule is protected health information, and so is the recording. HHS limits the conduit exception to services that only transmit data. It says a cloud provider that stores health information is a business associate even when the data is encrypted and it holds no key. If your phone provider keeps voicemail, recordings, transcripts, or texts, get a signed business associate agreement. Also decide how long recordings are kept and who can play them. Our HIPAA guide for NEMT explains the other duties.
Then use the recordings. Medi Trans holds its own Louisiana call center to a monthly check: supervisors review a minimum of two calls for each representative, scoring policy, procedure, courtesy, and whether trip authorization details were right, and they document any corrective action. The same routine works for a two-person office, and it fits into a broader quality assurance program.
Questions to ask a phone provider
Put these to every provider before you sign:
- Does the contract include a business associate agreement that covers voicemail, recordings, and texts?
- Does the system meet Kari’s Law (direct 911 dialing and notification) and send a dispatchable location, including from the mobile app?
- Can routing change by time of day, with a separate holiday schedule?
- Can staff answer from desk phones, computers, and cell phones while showing the main number?
- Can ring groups roll over to a second person and then to a named voicemail box?
- Can recordings play an announcement, and can we set retention and access by user?
- Do call reports show answered, abandoned, and missed calls by hour?
- Can texts go out from the main number? Texting riders brings its own consent rules, covered in our guide to TCPA rules for text reminders.
Fewer calls with HealthRide
Riders get reminder texts from HealthRide before the ride, and another text when the driver is on the way. Riders and families can follow their driver live from a text link, so they see where the van is without calling to ask. Dispatch and drivers talk through built-in team chat with read receipts, so trip changes stay in company conversations instead of on personal phones.
Frequently asked questions
- Is it legal for a NEMT company to record phone calls?
- Yes, if you get the consent the law requires. Federal law (18 U.S.C. 2511(2)(d)) allows recording when one party to the call consents. Several states set a stricter rule that calls for every party's consent or at least their knowledge, including California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania, and Washington. A recorded announcement at the start of each call is the usual way to meet the stricter rule, and Washington's statute counts an announcement as consent when the announcement is recorded too.
- Is a business associate agreement required from our phone provider?
- If it stores voicemail, call recordings, transcripts, or texts that contain rider information, yes. HHS limits the conduit exception to services that only transmit information, and says a cloud provider that stores health information is a business associate even when the data is encrypted and it holds no key. Ask for the agreement before you port your numbers.
- Can we keep our phone number if we switch providers?
- Usually. FCC rules let you port a number between wireline, internet, and wireless providers as long as you stay in the same geographic area. Your old company cannot refuse the port even if you owe it money, and simple ports are processed in one business day. Start service with the new provider before you cancel the old one.
- What does Kari's Law require of a business phone system?
- Any multi-line phone system installed after February 16, 2020 must let a caller dial 911 directly, with no 9 or other prefix. If the system can do it without new hardware or software, it must also alert a place where someone is likely to see or hear it, such as a front desk or a manager's phone. The FCC rule at 47 CFR 9.16 also requires the system to send a dispatchable location with the call, including for phones used away from the office.
- Should drivers call riders from their personal cell phones?
- Not if you can avoid it. Calls from a personal number show a caller ID the rider does not recognize, and the call history leaves with the driver. Give drivers a company line or an app that shows your main number. MTM's Virginia fee-for-service handbook requires providers to make sure drivers can reach dispatch and MTM by phone or another device throughout service hours.
- How should staff handle a call from a relay operator?
- Treat it like any other call. The Justice Department's ADA guidance says businesses covered by the ADA must accept calls placed through telecommunications relay service (reached by dialing 711) and video relay service, and that staff must treat relay calls like other calls. Speak to the caller, not the operator, and allow extra time for the typed or signed replies.