Two-way radio license for a NEMT fleet: FCC business radio, license-free radios, and push-to-talk on phones

A NEMT company can run FRS or MURS radios with no FCC license, cannot get a new GMRS license at all, and needs an FCC station license only for a radio system on its own business channels. Push-to-talk over cellular needs no license either, but it stops when the cell network does. A radio is usually a choice and not a payer requirement, and the broker rules are in dispatcher and driver communication. This page covers what a radio adds, which kind needs a license, and what each costs.

Does a payer require a radio?

Usually no, and a phone satisfies the manuals that name a device. New York’s Medicaid transportation manual (effective August 25, 2023) lists “two-way radio or cellular phone communication capability” among its vehicle requirements. Modivcare’s Mississippi manual (February 2024) says drivers must be equipped with a cell phone and/or a two-way radio, that pagers are not acceptable, and that a vehicle with an inoperative two-way system is out of service until the system is repaired or replaced.

The case for a radio is a carrier failure. AT&T’s February 22, 2024 outage lasted at least 12 hours, and the FCC found that all voice and 5G data service was unavailable to AT&T customers and to customers of other providers who were using or roaming on its network. A radio talks directly between units or through a repeater, so it does not depend on a carrier’s network. The longer plan for a day without phones or software, with the outage figures, is in what to do when dispatch software is down.

The four radio services side by side

Four radio services are worth comparing for a fleet, and two of them need no license of your own:

Citizens band radio is a fifth option. The rules authorize it without an individual license, for voice at up to 4 watts on AM or FM (47 CFR 95.967). Channel 9 is reserved for emergencies and traveler assistance (47 CFR 95.931).

FRS and MURS: the license-free options

FRS and MURS are licensed by rule, which means the FCC itself authorizes eligible users to run compliant radios without applying. Under 47 CFR 95.305, the FCC accepts no individual-license application for a Personal Radio Service unless a subpart requires one, and the FRS and MURS subparts do not.

FRS is made of 22 shared channels. Radios may transmit at up to 0.5 watt on channels 8 to 14 and 2 watts on channels 1 to 7 and 15 to 22. The antenna has to be a non-removable part of the radio, which rules out an outside antenna. The FCC says FRS is for personal or business use, that it may not connect to the telephone system, and that its channels are shared with GMRS, so users may hear licensed GMRS stations.

MURS has five VHF channels: 151.820, 151.880, 151.940, 154.570, and 154.600 MHz. Radios may transmit at up to 2 watts. A MURS antenna may be as high as 60 feet above the ground or 20 feet above the structure it sits on, and the FCC says an external antenna can stretch the range to ten miles or more. MURS stations may not be used as repeaters or signal boosters, and may not connect to the public telephone network.

For both, the radio must be an FCC-certified model, and no one may modify it to change its frequencies, power, or modulation. A modification voids the radio’s certified status, and an operator may not use a transmitter that lacks FCC certification.

GMRS: why a company cannot hold the license

An individual can hold a GMRS license, and a business cannot get a new one. The FCC limits new GMRS licenses to individuals at least 18 years old so that the service stays available to personal users. A license lasts ten years. The licensee and the licensee’s immediate family members may operate the station. The rule lists spouse, children, grandchildren, stepchildren, parents, grandparents, stepparents, siblings, aunts, uncles, nieces, nephews, and in-laws. It does not list employees or coworkers, so one owner’s license does not cover a roster of drivers. A licensee may let anyone operate the station to send an emergency message.

GMRS systems licensed to a business before July 31, 1987 are still valid, and they let a corporation’s officers, directors, members, and employees operate the station, but the FCC no longer accepts applications to modify, assign, or transfer them. For a company, the realistic choices are the license-free services or a Part 90 license.

A business radio license from the FCC

The Industrial/Business Pool is open to persons primarily engaged in the operation of a commercial activity, and also to hospitals, clinics, and medical associations (47 CFR 90.35). The FCC describes the pool as radio that supports day-to-day business, including dispatching personnel and work vehicles, which is what a NEMT dispatcher does. Operating on those frequencies requires a station license.

The steps, from the FCC’s licensing page (updated September 17, 2025):

1. Gather the technical details of your system, such as where the stations will sit and how many mobile units you need. The FCC’s “Preparing to License” guide lists what to have ready.
2. Hire a frequency coordinator. An application for a new frequency in the 25 to 470 MHz range needs a statement from a coordinator recommending the most appropriate frequency (47 CFR 90.175). The FCC lists the certified coordinators for the pool on its licensing page.
3. File through the coordinator. New applications that require coordination are normally filed with the FCC by the coordinator. Minor modifications and administrative updates can be filed by the licensee in the FCC’s Universal Licensing System.
4. Start operating conditionally. An applicant whose operation meets 47 CFR 90.159 may begin on a conditional basis for up to 180 days after filing a complete application. For a new station below 470 MHz, the rule asks for evidence of frequency coordination with the application and at least ten business days between filing and the first transmission.
5. Build and report within 12 months. The licensee must tell the FCC the system is built and operating within 12 months of the grant, or the license cancels automatically (47 CFR 90.155).
6. Renew on time. A license runs for up to ten years (47 CFR 90.149). The renewal, on Form 601 in the Universal Licensing System, may be filed no sooner than 90 days before the license expires.

For a small fleet, a coordinator filing and a construction report are a lot of paperwork for what MURS does with no license. The Part 90 route fits a fleet that needs a repeater or more coverage than the license-free services give.

Push-to-talk over cellular

Push-to-talk over cellular puts a talk button on a smartphone and carries the voice over a carrier’s network. The company has no radio to license, and the user needs a cell signal. That is also the weakness: during the February 2024 outage, a push-to-talk app that depended on AT&T’s network would have been cut off with everything else.

AT&T’s business page for Enhanced Push-to-Talk lists pricing “starting at” $5.00 per user per month for its standard tier and $20.00 for its advanced tier. The page says the advanced tier links broadband talk groups to land mobile radio systems, so a company with a licensed radio system could add phones to the same talk group.

What each option costs

The FCC’s fee filing guide, effective May 23, 2025, sets the government fees:

• FRS and MURS. No FCC fee. The only cost is the radios.
• GMRS. A $35 application fee for a new license and $35 for a renewal, with no regulatory fee.
• Business radio. A $105 application fee plus a $100 regulatory fee for new licenses in the common bands below 470 MHz, and $250 instead of $100 for 470 MHz and above. A renewal costs a $35 application fee plus the same regulatory fee. The frequency coordinator charges its own fee, which the FCC’s guide does not list.
• Push-to-talk over cellular. A monthly per-user charge, starting at $5.00 on the AT&T page above.

Keep rider details off open channels

Treat every FRS, GMRS, and MURS channel as one anyone nearby can hear. The FCC says no FRS or MURS channel is assigned to a single user and that users must share and listen before they talk. Since December 2017, the FCC has not certified new personal-radio models with voice scrambling or other obscuring features (47 CFR 95.381), so a newer radio has no privacy setting to switch on.

If HIPAA applies to your company, it asks you to limit protected health information to the minimum necessary (45 CFR 164.502) and to safeguard against incidental disclosures (45 CFR 164.530). A radio rule that follows from that is short: a trip number and a first name over the air, and the address, the diagnosis, and anything about the rider’s condition by phone or in the app. HIPAA for NEMT covers who the rule applies to.

Keeping dispatch and drivers in touch with HealthRide

HealthRide’s team chat gives every driver one conversation with dispatch, in the portal and the driver app, with read receipts and a full history that stays with the company. Push notifications never include passenger details, and the driver app keeps working without cell service. See team chat and the driver app.