Code of conduct template for NEMT companies: the standards every owner, driver, and dispatcher signs

A code of conduct is the short rulebook that sits above every other policy a NEMT company writes: be honest in trip records and billing, never pay or take anything for referrals, treat riders with dignity, keep their information private, and tell the company right away about anything that could put its Medicaid work at risk. HHS OIG’s 2023 compliance guidance lists written standards as the first of seven parts of an effective program, and the guide to building a NEMT compliance program shows where the code fits among the other six. The template below is the code itself, written for owners, drivers, attendants, and dispatchers to sign.

Who asks to see a signed code

Brokers and health plans check for a signed code because regulators and their own clients hold them responsible for the companies they subcontract to.

• Modivcare. Its 2025 attestation has a person with authority to sign vouch that each owner and driver went through its code of conduct “or substantially similar” training, and that the company keeps a conflict of interest policy of its own or adopts the one in Modivcare’s code. Modivcare may pass the signed form to the state agencies and health plans it works for. The remaining requirements on that form are laid out in the compliance program guide.
• WellTrans. It posts an acknowledgment form (a 2022 version) that each employee signs to confirm receiving the yearly training materials on four subjects: WellTrans’s code of conduct, general compliance, HIPAA privacy, and fraud, waste, and abuse.
• Alivi. Its policy on overseeing downstream providers took effect January 1, 2025. It requires an attestation before hire and again each year, and the code of conduct is one of the areas covered. Alivi also audits a sample of its downstream providers each year, no smaller than 5 percent.
• Medicare Advantage plans. CMS guidance has plans distribute their standards of conduct within 90 days of hire, when updated, and yearly, and make sure subcontractors’ employees receive them or have comparable standards of their own.

How to use this template

OIG’s guidance describes a code as the statement of an organization’s mission, goals, and ethical standards, and suggests the CEO sign an introduction to it, which in a small company is the owner. CMS asks that standards of conduct be easy to read and suggests translating them where staff need it. Keep yours to a few pages and put the detail elsewhere: daily driving rules belong in the driver handbook, and billing and screening procedures in your policies.

1. Fill in every bracket and cross out whichever options you will not use.
2. Collect a signature from every owner, employee, and contracted driver before their first trip, again each year, and after any change.
3. Make it part of performance reviews. OIG says following the code and policies should count in the evaluation of every employee and contractor.
4. Store signed pages a decade or longer, matching the longest period in the broker documents cited here.
5. Reread it when the owner or manager changes. OIG notes a code may not need regular rewriting, but a new leader is a good time to check it still fits.

The template

[Company name] code of conduct

Version date: [date] | Compliance contact: [name, phone, email]

A message from the owner

[Two or three sentences in your own words: why riders and payers trust the company, and that you expect everyone to follow this code and to speak up.]

Signed: [owner name, title] | Date: [date]

Who this code covers

Everyone who works for or with [Company name]: owners, officers, managers, employees, contracted drivers and attendants, and [volunteers / subcontractors].

1. Honest records and billing

• Log each trip exactly as it ran: the actual times the rider got in and out, the miles driven, which van and driver handled it, and what level of service was given.
• Never bill, or help anyone bill, a ride that never took place, a rider who was not on board, or a level of service above what was needed and delivered.
• Never sign on a rider’s behalf, and never have a rider sign the manifest for a trip that never ran.
• Drive a reasonably direct route. Extra miles for convenience are not billed.
• Fix a mistake by correcting the record with a note and telling [compliance contact]. Never delete or backdate.

2. Gifts, payments, and referrals

• No one at [Company name] gives, offers, requests, or takes anything of value to win trips or referrals, in either direction, with facility staff, case managers, broker or health plan employees, or riders. That includes cash, gift cards, meals, and favors. Under the federal Anti-Kickback Statute, paying or being paid for referrals of business billed to Medicaid, Medicare, or another federal program is a felony. The maximum penalty is a $100,000 fine, 10 years in prison, or both.
• No gifts of any value to broker or health plan employees.
• No gifts to riders except [none / items approved by (compliance contact) within the limits of each payer’s rules].
• Tips and gifts from riders: [not accepted / accepted only where the payer allows, up to (amount), and reported to (name)].

3. Conflicts of interest

Tell [compliance contact] in writing, before it affects any decision, when:

• You have a family, financial, or close personal relationship with anyone employed by a broker, plan, or facility on our customer list.
• You or a relative own or work for another transportation company.
• A relative or household member receives rides through a program we serve.
• Any other personal interest could affect, or look like it affects, your work for [Company name].

4. Riders’ dignity and safety

• Treat every rider with respect and consideration for their dignity and privacy, whatever their condition, background, language, or behavior.
• Never use restraint or seclusion to punish, control, or make a ride easier. Securing a rider with a seat belt or wheelchair tie-down for their safety is part of the job, not restraint used as coercion or discipline.
• Never abuse, neglect, or exploit a rider, or take their money or belongings.
• If you think a rider is being harmed, neglected, or taken advantage of by anyone, tell [name] at once. [Name] reports it to the broker and to the agencies the law requires.
• Keep professional boundaries: no personal phone numbers, side rides for cash, or relationships with riders.

5. Privacy

• Use a rider’s information only for the trip you are working on, and share it just with the people that trip requires.
• Never photograph a rider or post anything about one online.
• Lock phones and tablets, keep manifests out of view, and tell [name] the same day if a device goes missing or a message reaches the wrong person.
• Sign and follow the confidentiality agreement.

6. Safe and lawful work

• Never drive or assist riders while impaired by alcohol, drugs, or medication.
• Follow traffic laws and the company’s phone, seat belt, and securement rules.
• Follow every law and contract rule that applies to our work, and ask [compliance contact] when you are unsure.

7. What you must tell us right away

Tell [compliance contact] within [24 hours] if any of these happens to you:

• You are excluded, suspended, or barred from Medicare, Medicaid, or any other government health care program, or you are told an exclusion is coming.
• You are arrested, charged, investigated, or convicted for any crime.
• Your driver’s license is suspended, revoked, or restricted, or you get a moving violation.
• You are in an accident or incident while working.

Excluded people may not drive, dispatch, or do management work paid for by federal health care programs, and contracts such as MTM’s and Modivcare’s make the company pass several of these events on to the broker at once. Telling us early protects you, your coworkers, and the riders.

8. Raising concerns

• Report a possible violation of this code, a law, or a contract to [compliance contact], to the owner, or anonymously through [drop box / form].
• You may also call [broker compliance lines], or go to the federal Office of Inspector General: 1-800-HHS-TIPS by phone, or tips.oig.hhs.gov online.
• No one will be disciplined, threatened, or treated differently for reporting in good faith. Retaliation against someone who reports is itself a violation of this code.

9. When the code is broken

Reports are looked into promptly and kept as confidential as the investigation allows. Violations lead to [coaching, written warning, suspension, or termination], with the same steps for every person regardless of role, and may be reported to brokers, payers, or law enforcement where contracts or the law require it.

10. Acknowledgment

I read the [Company name] code of conduct (version [date]) and I understand it. I will follow it, and I will speak up when I learn of a violation.

Where each section comes from

• Section 1 mirrors the provider fraud examples in Modivcare’s 2025 training: billing rides that never happened, upcoding to a higher level of service, ignoring the most efficient route, and letting a member sign a manifest for a trip that was never given.
• Section 2 reflects 42 U.S.C. 1320a-7b(b); MTM’s contract promise that nobody pays its staff money or gifts in return for trip assignments; Modivcare’s ban on trading anything of value with riders, its staff, or vendors; and OIG’s nominal value limits for gifts to beneficiaries ($15 an item, $75 a year). The anti-kickback guide covers the safe harbors.
• Section 3 tracks Modivcare’s conflict of interest policy, which asks partners to disclose relationships with its staff and any relative who receives a transportation benefit it may manage.
• Section 4 uses the Medicaid managed care rights in 42 CFR 438.100(b)(2): respect and due consideration for dignity and privacy, and freedom from restraint or seclusion used for coercion, discipline, convenience, or retaliation. The boundary rules are explained in professional boundaries for drivers.
• Section 7 reflects OIG’s May 2013 exclusion bulletin, which says a person on the exclusion list cannot provide transportation that a federal program pays for, and names “ambulance drivers or ambulance company dispatchers” as examples; MTM’s notice terms for criminal matters; and Modivcare’s requirement to report accidents, incidents, and moving violations straight away. Screening everyone each month is covered by the exclusion screening log.
• Section 8 follows the non-retaliation policy Medicare Advantage plans must have under 42 CFR 422.503(b)(4)(vi)(A)(7), and OIG’s suggestion that small companies post the OIG hotline where anonymous reporting inside the company is hard.

Records that make the code easy to keep

Section 1 is easier to follow when the trip record writes itself. In HealthRide, every leg of a trip records GPS miles, run times, and a signature taken on the driver’s screen. Every change is recorded. The yearly code acknowledgment can be tracked as a dated credential with a reminder before it lapses. See reports and fleet and credentials.