Enrollment moratorium: when Medicaid stops accepting new transportation providers
A Medicaid enrollment moratorium stops new sign-ups for one provider type judged high risk for fraud. Under 42 CFR 455.470, it needs CMS agreement and a finding that members keep access to care, and it lasts six months, renewable in six-month steps. Minnesota's seven metro counties and North Dakota have NEMT freezes, and Colorado reopens NEMT enrollment on October 1, 2026.
On this page
How a freeze gets approved
A moratorium comes from one of two places under 42 CFR 455.470:
| Route | How it starts | What the state must do |
|---|---|---|
| CMS-imposed | CMS identifies a provider type as an increased risk and consults the state | Impose it, unless the state finds members would lose access and tells CMS so in writing |
| State-imposed | The state picks a type with significant potential for fraud, waste, or abuse that CMS already rates high risk | Find that access will not suffer, send CMS the details, and get its agreement |
Either way, the first period is six months. The state can extend in six-month steps, and it has to document in writing why each extension is necessary. CMS asks for a state’s request at least 30 days before the proposed start date or the end of the current period. A state may also use a numerical cap or other limit instead of a full freeze.
NEMT freezes in 2026
| State | Who is frozen out | Dates |
|---|---|---|
| Minnesota | New NEMT providers located in Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, or Washington county | Effective January 27, 2026, extended to January 27, 2027 |
| North Dakota | New NEMT agencies statewide | Effective June 11, 2026, for six months, extendable |
| Colorado | New NEMT providers statewide | October 1, 2023 through September 30, 2026, with enrollment open again from October 1, 2026 |
Arizona shows how a freeze can end. Its statewide freeze on NEMT and four other provider types expired on December 9, 2024.
Waiver rides can be caught too. Indiana’s statewide freeze on 1915(c) waiver providers, effective August 1, 2026 for an initial six months, lists the waiver Transportation service. That is waiver transportation, a separate benefit from NEMT.
Colorado’s reopening comes with a new order of steps: enroll with the state, then complete credentialing, then enroll with MediDrive, which becomes the single broker for the whole state on January 1, 2027.
Who is exempt
The fine print decides who a freeze actually covers. Check four details in your state’s notice:
- Enrollment status. Companies already enrolled keep operating in Minnesota, North Dakota, and Colorado.
- Location. Minnesota’s test is where the company is located. A NEMT company based outside the seven metro counties can still enroll.
- Access exceptions. Minnesota may admit new providers where capacity falls short, with written CMS approval for each one. Arizona’s freeze let applicants seek a case-by-case exemption for underserved areas, state initiatives, or when a contracted health plan needed the provider to keep up with its time and distance standards. That last reason ties directly to network adequacy.
- Timing. North Dakota let applications already at final approval finish. Minnesota stopped processing pending ones.
What a new company can do meanwhile
A freeze closes Medicaid enrollment, not the business.
- Work payers outside Medicaid. Riders who pay for themselves and facilities that buy rides for patients do not depend on your Medicaid enrollment. See private pay NEMT and facility contracts.
- Get the file ready. Keep insurance, vehicle inspections, and driver checks current so you can apply the week enrollment reopens.
- Expect high-risk screening. Minnesota, for one, lists NEMT among its high-risk services, and applicants right after a lifted freeze can be moved to high risk anyway. The provider risk levels page explains fingerprints and site visits.
- Watch the end date. Extensions are decided every six months, so read the agency’s provider news near each end date.
While Medicaid is closed to you
If facility and private-pay rides are your work during a freeze, HealthRide builds the invoices for the facilities and payers you serve straight from the trips you ran, priced from your own rates. Facilities can pay online, and unpaid invoices stay tracked until they are settled. See invoicing.
Frequently asked questions
- Are NEMT companies that are already enrolled affected?
- Usually not. North Dakota's 2026 freeze applies only to new enrollments, and Colorado's applied only to new NEMT providers. Minnesota lets enrolled providers keep working and even add new locations for services they are already enrolled to provide. Read your state's notice anyway. Indiana's 2026 freeze on certain home and community-based services, for example, also blocks changes of ownership and added counties for existing agencies.
- What happens to an application that is pending when a freeze starts?
- It depends on the state. North Dakota lets applications that had reached final approval go through and denies the rest. Minnesota stopped processing new enrollment submissions for frozen services, including ones already waiting in its queue. Either way, plan on applying again once enrollment reopens.
- Will I be screened differently when enrollment reopens?
- Possibly. When a state lifts a moratorium, a provider it kept out that applies within six months is screened as high risk, which brings fingerprint background checks and site visits (42 CFR 455.450). CMS says a state that lets a freeze expire, rather than lifting it, may choose whether to raise the level. Colorado is letting its freeze expire, but it already places enrolling NEMT providers in its high-risk group, so expect fingerprints and a site visit there either way.
- Can I join a broker network while my state is frozen?
- Not where the network depends on state enrollment. Under 42 CFR 438.602, a health plan may contract with a company whose state enrollment is still in process, but only for one 120-day period, and it must end the contract if the state cannot enroll the company. That rule is not among those that apply to brokers the state pays only for rides, so for those, the state's broker contract decides. Colorado requires state enrollment before a company can credential and contract with its broker. Driving under another company's broker contract needs the broker's written consent, and MTM's standard agreement forbids subcontracting without it.
