What are Medicaid provider risk levels, and which one does a NEMT company get?
Each state sorts Medicaid providers into three screening tiers set by 42 CFR 455.450. Limited covers license checks and database searches. Moderate adds on-site visits before and after approval. High adds a criminal background check, with fingerprints from the provider and anyone owning 5 percent or more. Transportation has no federal tier, so the state assigns one, and several assign high.
On this page
What each tier adds
The tiers stack. Every level includes everything below it, and when a provider could fit more than one, the state must use the highest. Screening runs on first applications, on applications for a new practice location, and at revalidation.
| Tier | Screening the state performs | What the provider notices |
|---|---|---|
| Limited | Confirms federal and state requirements are met, verifies licenses (including licenses held in other states), and checks federal databases both before and after approval | Paperwork only. The database checks include the Social Security death file, NPPES, and the federal exclusion lists, and the state reruns the exclusion lists at least monthly. |
| Moderate | Limited screening plus on-site visits | Someone from the state or its contractor comes to your location, before approval and after |
| High | Moderate screening plus a criminal background check and fingerprints | Owners with 5 percent or more get fingerprinted, and the site visit still happens |
The monthly checks look at owners and managing employees as well as the company, which is why the OIG exclusion list matters from the first day. The site visit guide covers what the inspector looks at.
Who sets the level for transportation
For Medicare, CMS assigns the tiers itself in 42 CFR 424.518, which places ambulance suppliers at moderate. A state may not screen a provider type Medicare also enrolls at a lower tier than Medicare uses, so ambulance companies start at moderate in Medicaid too. Non-emergency transportation has no Medicare counterpart, so CMS leaves the choice to each state. Its November 2025 enrollment compendium suggests states weigh GAO and OIG reports, what law enforcement partners report, the volume of enforcement actions, and how much oversight a provider type already gets.
States land in different places:
- Arizona rates non-emergency transportation (provider type 28) high. The AHCCCS packet requires a site visit, a fingerprint-based background check, and the enrollment fee.
- Indiana screens bus, taxi, and common carrier companies (ambulatory and nonambulatory) at high for first enrollment and moderate at revalidation. Ambulance and air ambulance stay moderate both times.
- Ohio puts wheelchair vans, and supplemental transportation sold through a waiver, in the high tier for new applicants. Both drop to moderate when they revalidate, and ambulances sit at moderate throughout.
- Texas screens every provider by risk category. A moderate or high risk provider cannot bill for services at a new practice location until that location is approved.
Look up your own state’s matrix before you apply, since the tier decides how long enrollment takes and who has to show up.
What moves a company to high
A state must raise a limited or moderate provider to high when any of these happen:
- The state suspends the provider’s payments because of a credible allegation of fraud, waste, or abuse. CMS keeps the provider at high for 10 years after the suspension.
- The provider has an existing Medicaid overpayment when it applies or revalidates. CMS counts a debt of $1,500 or more, interest included, that is over 30 days old, unpaid, not under appeal, and not on an approved repayment plan. The high rating lasts while the debt does.
- OIG or another state’s Medicaid program excluded the provider within the previous 10 years.
- A moratorium on the provider type was lifted in the past 6 months, and the provider it had blocked applies within 6 months of the lift.
Moratoria are their own hurdle. A state that imposes one on a provider type starts with 6 months and may extend it in 6-month steps, documenting each extension. NEMT has faced them this year. North Dakota’s statewide moratorium on new NEMT agency enrollments took effect June 11, 2026, and applications short of final approval that day were denied. Minnesota has barred new NEMT companies based in its seven-county metro area since January 27, 2026, an order now extended through January 27, 2027. Both orders stop new enrollments only, not companies already billing.
Fees and follow-ups
The 2026 application fee is $750 for institutional providers enrolling or revalidating in Medicare, Medicaid, or CHIP, and states collect it before signing the provider agreement. States revalidate every provider at least once every five years and screen again at the current tier, so a company that passed as high risk once should expect another round. See Medicaid revalidation for the cycle, and what to do when enrollment is denied or stuck.
Staying inspection-ready
Moderate and high tiers bring site visits after approval as well, and any enrolled provider has to let the state or CMS inspect any of its locations without notice. HealthRide tracks driver licenses and vehicle insurance and registration with their expiration dates in one credentials registry, with reminders before they lapse, and each driver inspects the van in the app before starting a shift.
Frequently asked questions
- Do rideshare and family drivers screen at the same level as van companies?
- Not necessarily, because states rate each provider type separately. Indiana's 2026 matrix puts taxi, bus, and both ambulatory and nonambulatory common carriers at high risk for first enrollment, while transportation network companies, family member drivers, and broker fleets screen at limited risk.
- Who gets fingerprinted at the high level?
- The provider itself, plus every person who owns 5 percent or more of it, directly or indirectly. The state sets the form and manner, and prints are due within 30 days of a request from the state or CMS. An owner who never submits them can cause the application to be denied or the enrollment to be terminated.
- Does my level stay the same when I revalidate?
- It can drop. Indiana and Ohio both screen their high risk transportation types at moderate for revalidation. It can also rise. The state must move any provider to high after a fraud-based payment suspension, an existing Medicaid overpayment, or an exclusion in the past 10 years.
- Does every NEMT company pay the $750 enrollment fee?
- Not every one. The 2026 fee is for institutional providers, and CMS counts transportation companies billing the state directly, claim by claim, as institutional entities that owe it. You are exempt if Medicare or another state already collected it from you. Indiana does not charge its family member or broker fleet transportation types.
