Passenger conduct policy template: the rules riders agree to and the steps before a ride is refused

What the policy covers, and whose rules come first

A passenger conduct policy does two jobs. It tells riders, escorts, and companions what they agree to when they book, and it tells drivers and dispatchers what to do, in order, when someone breaks a rule. The guide to handling difficult or unsafe riders covers calming a tense ride and stopping one safely, and the guide on when a provider can refuse a ride covers the legal limits. This page is the written policy that sits behind both.

On Medicaid broker trips, the broker’s member rules come first, and your policy should repeat them rather than invent stricter ones. MTM Health’s Virginia fee-for-service member handbook (last updated June 23, 2026) shows what riders are told. Belts stay on. No eating, drinking, or smoking, including e-cigarettes, vaping, and chewing tobacco. No alcohol or illegal substances. No profane or vulgar language aimed at the driver or other riders, no sexual advances or harassment, and no bullying or intimidation. No weapon of any size or kind, including a gun carried with a permit, and no hazardous materials. Bags must fit on the rider’s lap or beside them, and the driver makes no extra stops.

Georgia’s NEMT manual (version dated October 1, 2026) bans smoking on vehicles, requires “No Smoking” signs every passenger can see, and tells drivers to contact the broker immediately when a passenger smokes anyway. For private-pay riders and facility contracts, the policy is yours to write, inside the same federal limits.

The template

[Company name] rider conduct policy

Applies to: riders, escorts, companions, and anyone riding with them | Effective date: [date] | Approved by: [owner name] | Next review: [date]

1. Why we have these rules

These rules keep riders, drivers, and everyone else on the road safe, and they keep each ride on time. On trips arranged by a Medicaid broker or health plan, that program’s rider rules also apply. Where the two differ, the program’s rules win.

2. Before the ride

• Tell us when you book about a wheelchair, scooter, walker, oxygen, a service animal, a car seat, or anyone riding with you. [Only one companion may ride with each rider.]
• Be ready at the door at the pickup time we give you.
• Bring a child safety seat for any child who needs one. [On broker trips, the broker’s rule on car seats applies.]

3. Rules on board

1. Everyone wears a seat belt for the whole ride. The vehicle does not move until every belt is fastened and every wheelchair is secured. The driver will help with the buckle or bring a belt extender.
2. No smoking, vaping, e-cigarettes, or chewing tobacco in the vehicle.
3. No alcohol, illegal drugs, or open containers.
4. No guns, knives, or other weapons of any kind, including weapons carried with a permit.
5. No fuel, fireworks, or other hazardous items. Medical oxygen rides under our oxygen policy.
6. [No eating or drinking, except when a rider needs to for a medical reason.]
7. Stay seated while the vehicle moves. Do not touch the doors, the lift, the controls, or the driver.
8. Keep bags and belongings on your lap or beside you. The driver is not responsible for personal items left in the vehicle.
9. Treat the driver and other riders with respect. Threats, hitting, spitting, sexual comments or touching, harassment, and slurs are not allowed.
10. The driver goes only to the pickup and drop-off on your trip. [Extra stops are not allowed.] [Extra stops booked in advance cost (amount).]

4. Disability is never a rule violation

We never treat behavior caused by a disability as misconduct. A rider whose condition causes involuntary movements, sounds, or words is welcome on every ride. A rider who needs a rule changed because of a disability, such as eating on a long ride for a medical reason or riding with a personal care attendant, can ask at booking or ask the driver. We handle those requests under our ADA policy.

5. What staff do when a rule is broken

1. Remind once. The driver states the rule calmly and offers help, such as a belt extender or a different seat.
2. Stop safely. If the behavior makes driving unsafe, the driver parks out of traffic and calls dispatch. The driver does not argue, threaten, or leave anyone at a stop that is not on the trip.
3. Call 911 for violence, a weapon, or a threat to anyone’s safety, then call dispatch.
4. Tell the broker first. Dispatch calls the broker before a broker trip is refused or ended early, and records the name of the person reached and the time.
5. Write it up the same day on our incident report, with the rider’s exact words in quotes and what the driver saw and did.
6. Leave restrictions to the payer. The broker or health plan decides any change to a member’s future rides. We never stop serving a broker rider on our own.

6. Riders who pay us directly

For private-pay riders, [owner or manager] may limit or end service only after:

1. a written warning naming the date, the trip, and the conduct;
2. a written notice of the proposed action (for example, rides only with an attendant, or no rides for [] days), with [] days to respond by phone, in writing, or in person;
3. a written decision giving the reasons.

Violence, a weapon, or a threat may end service at once. The rider then receives a written notice within [__] business days.

7. Records

Each warning, notice, decision, and incident report is kept with the rider’s trip records for [__] years, or longer if a broker contract requires it.

Rider acknowledgment

I have received the [Company name] rider conduct policy.

Part B: Conduct record (staff use)

Where the ADA line sits

The line is conduct, never the disability behind it. 49 CFR 37.5(h) allows a refusal for “violent, seriously disruptive, or illegal” conduct or a direct threat to others, and forbids one made solely because a disability causes appearance or involuntary behavior that offends, annoys, or inconveniences staff or other riders. The ride refusal guide explains what counts as a direct threat and how to judge one.

DOT’s guidance in Appendix D to Part 37 gives two examples worth reading to every new driver. Some people with Tourette’s syndrome make involuntary profane exclamations, and however offensive other riders find them, they are not grounds for refusal. A rider with HIV may not be turned away because staff or other passengers are afraid to sit near them. The same guidance says an entity may refuse a rider with a disability for violent, seriously disruptive, or illegal conduct using the same standards it would apply to anyone else who acted that way.

Two rules for writing the policy follow from that:

• Write rules about conduct, never about conditions. “No threats” is a conduct rule. “Riders with behavioral health conditions must bring an escort” is a rule about a condition, and it breaks 37.5(e).
• An attendant can be a condition only after a lawful refusal. Where a provider could legitimately refuse a rider, Appendix D lets it offer service with an attendant instead.

Who decides when a Medicaid rider keeps breaking the rules

The broker or the state does, and your written report is the evidence it acts on. CMS’s 2023 coverage guide (SMD 23-006) describes a rider whose past conduct affected a driver’s ability to drive safely, or who was not respectful, and lists steps a state may take short of ending rides:

• one assigned provider who can handle the situation, when no other provider will take the rider;
• specialized transport that fits the rider’s behaviors and needs;
• special prior authorization procedures for the rider’s trips;
• the option to arrange their own ride, as a reasonable accommodation;
• a consultation with the rider’s treating practitioners.

CMS adds that, before any limit takes effect, the state should send the rider a letter that lays out what was done to accommodate them and the behaviors behind the change.

Georgia writes its process out in Appendix L of its manual. A provider’s complaint about a member’s abuse or misconduct brings a warning letter from the broker, sent by certified mail. Its sample letter tells the member that a provider reported verbal or physical abuse toward the driver or other passengers, and that a provider has the right to refuse service to unruly individuals. After two warnings, the broker sends a denial letter with the right to reconsideration and appeal, and keeps providing rides during the appeal unless documented unsafe behavior continues.

Missouri’s NEMT manual (posted April 2026) lets a transportation provider complain about a participant’s behavior. The complaint goes through the broker’s Where’s My Ride line, and the broker’s quality staff look into it. Brokers also expect a call before any refusal, and the refusal guide covers that step and what a lawful restriction looks like.

Suspending private-pay riders the way paratransit does

The ADA paratransit rule is written for transit agencies, not for a private NEMT company suspending its own private-pay riders, but it gives a tested model. A transit agency that suspends a rider for a pattern of missed trips must first send a written notice citing the specific basis and the proposed sanction, give the rider a chance to be heard and to present information, and send a written decision with the reasons (49 CFR 37.125(h)). Section 6 of the template uses the same three steps for conduct.

That paper trail answers the question a civil rights complaint turns on: whether the rider was judged on what they did rather than on a disability. It also gives a family or case manager time to fix the problem, for example by sending an escort. The guide to repeat no-shows covers missed trips, which follow their own rules.

Putting the rules where riders see them

A rule riders never heard is hard to enforce. Read the short version of section 3 aloud when a new rider books, include it in your new rider welcome letter, and post signs in each vehicle.

Virginia’s fee-for-service vehicle requirements (updated May 26, 2026) call for two signs that passengers can easily see inside every vehicle: a “NO SMOKING” sign that covers vapor and e-cigarettes, and one that says “ALL PASSENGERS WILL USE SEAT BELTS.” MTM Health’s provider agreement, in the version Pennsylvania posts, adds interior signage telling riders that drivers and attendants do not take responsibility for their personal items. Weapons rules for drivers themselves, as opposed to riders, are covered in the guide to guns in NEMT vans.

Keeping the record straight in HealthRide

A conduct report holds up better when the trip record already shows what happened. HealthRide keeps pickup and drop-off times and GPS-recorded miles on every trip, and drivers can reach dispatch through team chat instead of a personal phone, so the conversation about a problem ride stays with the company. When a trip has to move to another driver, dispatch reassigns it on the board in one motion.