NEMT Compliance Checklist: What Brokers Actually Audit

NEMT — non-emergency medical transportation — pays reliably because brokers and Medicaid programs demand reliability in return. The operators who win broker contracts are not the biggest; they are the ones who can produce documentation on demand. This checklist covers what brokers actually audit.

Driver credentialing

• Valid license with state-appropriate classification
• Clean MVR (motor vehicle record) pulled within the last 12 months
• Background check — most brokers require within 90 days of contracting
• CPR/first-aid certification where the state or broker requires it
• HIPAA awareness training — passengers' medical details are protected health information
• Defensive driving or passenger-assistance (PASS) certification for wheelchair/stretcher work

Vehicle requirements

• Current registration and commercial insurance meeting broker minimums (commonly $1M liability)
• ADA-compliant wheelchair lifts and securement systems for WAV work
• Documented maintenance records — brokers ask for them at audit
• Daily pre-trip inspection logs (DVIR) signed by the driver

Trip documentation that gets you paid

The difference between a paid trip and a denied claim is documentation. Brokers and state Medicaid programs expect: pickup and drop-off timestamps with GPS confirmation, driver and vehicle identity per trip, rider signature or electronic proof of service, wait times, and any no-show or cancel-at-door events logged contemporaneously — not reconstructed later.

Paper logs are the number-one cause of audit failures. If a trip is not documented at the moment it happens, treat it as undocumented.

The operational stack brokers look for

• GPS-verified trip records — arrival and completion timestamps
• Digital proof-of-service — signature capture, photo, or rider PIN
• Driver credential files with expiry alerts (licenses, certs, insurance)
• Incident reporting with timestamps — accidents, injuries, service refusals
• Retrievable trip history — most audits request a sample month of records

Common audit failures

Expired driver credentials discovered mid-audit, inspection logs with gaps, trips billed without GPS or signature evidence, and vehicle records that do not match the dispatched vehicle. Every one of these is a process problem, not a driver problem — and all of them are preventable with software that enforces documentation at the point of work.

PRIME was built around exactly this workflow: GPS-verified trips, digital proof of delivery/service, driver document expiry alerts, and incident reporting baked into the driver app. If a broker asked for your last 90 days tomorrow, you could export it in minutes.