NEMT driver file checklist: what to keep on every driver

How to use this template

Open one file for every person who drives or rides as an attendant for you, including owners who drive and volunteer drivers. The office manager or whoever handles compliance keeps the file. Brokers can ask for any piece of it during credentialing or an audit.

• At hire. Complete every item in the first three sections before the person transports a rider.
• Every month. Run the exclusion check and log the date.
• Every year. Pull a new driving record, review training dates, and confirm the driver still meets your broker’s standards.
• Keep it for the longest period that applies to you. FMCSA-covered motor carriers keep driver qualification files for the length of employment plus three years. Form I-9 is kept three years after hire or one year after the job ends, whichever is later. Modivcare providers attest they keep training records for at least 10 years.

The driver onboarding checklist covers the training steps in order. This checklist is the proof you file once each step is done.

The template

Driver details

Hiring and identity

• Signed employment application
• Form I-9 completed and filed
• Copy of the driver’s license, with the right class and endorsements for the vehicles they drive
• Proof of age and years licensed, if your state or broker sets a minimum
• Signed code of conduct acknowledgment
• Signed confidentiality and HIPAA acknowledgment
• Signed drug-free workplace policy acknowledgment
• NPI and taxonomy code, if your state enrolls individual drivers

Screening

• Motor vehicle record pulled at hire and checked against your broker’s standard
• Criminal background check that meets your state’s rule, including the sex offender registry if required
• Pre-employment drug screen result, if your broker or state requires one
• HHS-OIG exclusion list check at hire, with the date and result printed or saved
• State Medicaid exclusion list check, if your state keeps one
• Driving history disclosed to the state Medicaid program or broker, if they ask for it
• Road test or vehicle orientation in the type of vehicle they will drive, signed by the evaluator
• Medical examiner’s certificate, only if the driver operates a commercial motor vehicle under FMCSA rules

Training certificates

• First aid
• CPR
• Defensive driving
• Passenger assistance and safety (such as CTAA PASS)
• Hands-on wheelchair securement, for drivers of accessible vehicles
• Stretcher loading and transfer, for stretcher crews
• Bloodborne pathogens and spill kit procedures
• HIPAA privacy
• Fraud, waste, and abuse
• ADA and passenger sensitivity
• Each broker’s required training or orientation

Ongoing records

• Monthly exclusion check log
• Annual motor vehicle record and a signed note of the review
• Performance evaluations, signed by the driver and the reviewer
• Incident reports, complaints, and the corrective action taken
• Retraining records after any incident
• Separation date and reason, when the driver leaves

Renewal tracker

What brokers and auditors look for

Auditors want to see that every driver met the rules before their first trip, and still meets them today. Dates matter as much as documents. A CPR card that expired in March is a finding even if it is in the file.

The federal floor is short. Section 1902(a)(87) of the Social Security Act requires states to make sure that NEMT providers and drivers are not excluded from federal health care programs, that each driver has a valid license, and that each provider has processes for state drug law violations and for disclosing drivers’ driving history. CMS says federal Medicaid law sets no other basic driver standards. States and brokers fill in the rest, and they vary a lot:

Two more rules catch providers out:

• Monthly exclusion checks. CMS guidance tells states to require providers to search the HHS-OIG exclusion list every month and report any match right away. Use the OIG exclusion search and save a dated result.
• Training records. Modivcare providers attest that new employees finish its compliance training within 30 days of hire and that records are kept for at least 10 years. MTM requires fraud, waste, and abuse training and HIPAA training for every employee every year.
• Bloodborne pathogens. When a driver’s duties can reasonably bring contact with blood, such as cleaning up a spill, OSHA’s bloodborne pathogens standard requires training at assignment and every year after. Training records are kept for three years.
• Lapses stop trips. CareOregon lets brokers suspend a driver immediately when a required credential lapses. MTM’s system will not assign trips to a provider whose credentials are not current.

If your vehicles are commercial motor vehicles under FMCSA rules, the driver qualification file in 49 CFR 391.51 also applies: the application, the motor vehicle record, the road test certificate, the annual record review, and the medical examiner’s certificate. More detail on state rules is in our guide to NEMT driver requirements.

Common mistakes

• Checking exclusions once. A driver who was clear at hire can be excluded later. Monthly checks are the standard.
• Letting training lapse. CTAA’s PASS driver certification lasts two years. A driver who has not renewed within 90 days after it expires loses certification and has to retake the basic online course and an in-person wheelchair class. Track the date, not just the certificate.
• Background checks that do not match the state rule. A county-only search does not satisfy a state that requires state police or national databases.
• No proof of when. A file with a clean driving record but no date on it does not prove the driver was cleared before their first trip.
• Skipping attendants and owners. Virginia applies the same rules to attendants. Verida asks for drug screens for all owners and drivers.
• Starting before approval. Some brokers approve each driver individually. Put the approval date in the file and keep new drivers off that broker’s trips until it arrives.

When you apply to a new broker, the driver files become part of your packet. The broker credentialing checklist lists what else goes with them.

Tracking the expiration dates

HealthRide tracks each driver’s licenses, certifications, and training records with their expiration dates and sends reminders before anything lapses. An expired credential is flagged when dispatch assigns a trip, so an unqualified driver does not slip onto the schedule. See fleet and credentials.