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Starting & scaling →How to Start a NEMT Business in Minnesota (2026)
Minnesota froze new metro NEMT providers and voted to hand every Medicaid ride to one administrator. Here's how to build anyway.
By James O'Donnell, Cofounder and COO, Duet ·
To start a NEMT business in Minnesota, form an LLC, get a free USDOT number, and earn MnDOT’s Special Transportation Service certificate: background studies, a Form E policy at the state’s $500,000 floor, a vehicle inspection, a $45 decal. Buy the $1 million of auto and general liability the contracts expect. Then enroll the company and every driver with Minnesota Health Care Programs, $750 for the application. Outside the seven-county metro, Medicaid enrollment is open at high-risk screening, per DHS’s July notice. Inside it, DHS has frozen new NEMT providers since January 2026, so a metro company starts on facility and private-pay work. Plan on $40,000 to $60,000 for one used wheelchair van and two to four months to first Medicaid trips where the door is open.
Minnesota at a glance:
- State NEMT license: none by that name. The state operating authority is MnDOT’s STS certificate of compliance, and a certificate holder needs no city or county permit for those vans by state statute. Minneapolis’s medical transport vehicle license is the one open question.
- Who runs Medicaid rides: nobody statewide. Counties arrange ambulatory rides (MTM runs that job for 17 counties under two county consortium contracts), the state pays fee-for-service wheelchair, stretcher, and protected trips directly, and each health plan runs its own ride line. A 2025 law orders one contracted administrator for all of it, on a date DHS hasn’t set.
- How you enroll: with DHS through the MPSE portal as provider type 82, at high-risk screening since January 2026: a $750 fee, fingerprints for every owner, an unannounced site visit. Every driver enrolls too.
- Insurance the contracts expect: $1 million auto and $1 million general liability, the bar MTM writes down; the state floor is $500,000 a vehicle.
- Cost to launch one van: $40,000 to $60,000 used, toward $100,000 with a new conversion, mostly the van and the insurance. State fees total about $1,000.
- Time to first Medicaid trips: two to four months outside the metro. Private-pay and facility trips start when the STS certificate and the insurance land.
An operator in rural Minnesota told me on a call in September that his company has been established for a year and a half and still hasn’t carried a rider. He’s chasing a health plan contract, because insurance contracts are, in his words, “pretty much the core of the business here in Minnesota,” and he’s “stuck in limbo” through what he called “all the stuff that kind of happened here.” Eighteen months, no trips.
The stuff that happened is why this guide exists. In 2024 Minnesota Medicaid paid $151 million for 6.9 million rides through 551 fee-for-service and 1,165 managed-care providers, some of them the same companies, per DHS’s March testimony to the House Fraud Prevention Committee [1].
Then came the crackdown. In January 2026 CMS rejected the state’s corrective action plan, and on February 25 it deferred $259.5 million in federal Medicaid money over fourteen high-risk services, NEMT among them [2][3]. DHS froze new enrollment in 13 Medicaid categories, NEMT among them, on January 27, 2026 at CMS’s direction, and made NEMT a high-risk provider type the same month [4][5]. Its July 23 provider notice, as it reads in search results, extends the freeze for providers in the seven metro counties to January 27, 2027 and reopens enrollment everywhere else [6].
The riders are still there, 1.13 million of them on Medicaid or CHIP as of May 2026 [7], and the operators who built on their own trip sources are doing fine. A two-van operator in the Twin Cities suburbs told me in June that he runs mostly private pay and plans to drop his Medicaid work, which by his count pays about a third of his private rate. A three-van Minneapolis operator I know runs almost nothing but private-pay stretcher and long-distance facility trips, and charges more than almost anyone I’ve seen in the country.
I run Duet, which builds dispatch software for non-emergency medical transportation (NEMT) businesses, and this is the Minnesota edition of our national guide. DHS’s website blocks most automated readers, so where I quote a DHS manual page from search results I say so. Confirm against the linked sources before you spend money.
The one-page checklist: steps to start a NEMT business in Minnesota
Sequenced so the expensive mistakes come last.
Phase 0: know your demand and your county
- Find out which side of the freeze you’re on. A company located in Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, or Washington County can’t enroll with DHS as a new NEMT provider right now, per DHS’s notice as it reads in search results [6]. Everywhere else, enrollment is open.
- Decide your modes. Wheelchair, stretcher, and protected trips bill the state directly. Ambulatory trips go through your county or its coordinator, and you never bill DHS for them [8].
- Visit facilities before you buy anything; the three-van stretcher operator above built his whole book on them. Get the website and Google Business Profile live first too.
Phase 1: business foundation, with the name checked first
- Check the name against MnDOT’s naming rule before you file; the licenses section has it [9].
- File Articles of Organization with the Secretary of State: $155 online, $135 by mail, free annual renewal [10].
- Get the free EIN. The DHS enrollment doesn’t need an NPI: DHS assigns Medical Transportation providers and their drivers a state identifier, the UMPI [11][12].
- Check every owner, manager, and driver against the OIG exclusion list and SAM.gov, and recheck monthly. DHS’s provider requirements page screens against both, and a hit bars the enrollment [13].
Phase 2: the MnDOT track
- Apply for a free intrastate USDOT number, which the STS rule requires, then file the “Get MnDOT Number” packet [14][15][16].
- Start NETStudy 2.0 background studies on every owner at 5 percent or more, every driver and attendant, and anyone who dispatches or bills: $44 a study plus $13.50 for fingerprints and photo [17][18].
- Have your insurer file the Form E at $500,000 combined single limit, and buy to the $1 million bar anyway [19][20].
- Schedule the MnDOT vehicle inspection, pay $45 per decal, and submit the certificate packet. MnDOT answers within 30 days of a complete application [21][22].
- Calendar the 90-day initial provider education deadline the day the certificate arrives, counting from the effective date printed on it [23].
Phase 3: the DHS track, in parallel
- Outside the metro: pay the $750 application fee, then file the organization enrollment through the MPSE portal as provider type 82, Medical Transportation, specialty 89, with the STS certificate, the vehicle list, the provider agreement, and the ownership disclosure [11][24].
- Expect fingerprint studies on every owner and an unannounced site visit before approval; NEMT has been a high-risk type since January 2026 [5].
- Once the welcome letter lands, enroll every driver individually as type DR from inside your portfolio, each with a background study ID on the form [12].
- Inside the metro: skip to Phase 4 and 5. Email transportation.DHS@state.mn.us, the address DHS’s notice gives, about the exception process, which is for areas short of capacity, runs through the county, and needs CMS’s written approval [4][25]. From January 1, 2027, every active owner and every manager must finish DHS’s compliance training before you apply [25].
Phase 4: drivers, vehicles, and the file
- Build each driver’s file to MnDOT’s rule: Class D license, a three-year clean record, a federal medical examiner’s certificate, the pre-service training, and the certified-trainer courses within 45 days [26][27].
- Put the business name and USDOT number on both sides of every van and the complaint contact information inside [28][29].
Phase 5: the trip sources you control
- Hospitals, dialysis clinics, and senior communities pay their own transfers without a level-of-service certificate.
- Contract with the payers that don’t wait on the freeze: private-pay families, facilities, and, outside the metro, your county’s coordinator and each health plan’s ride line.

Who pays for NEMT rides in Minnesota?
Four payers: Medicaid through two doors, the eight health plans, facilities, and private-pay families.
Medicaid is the volume, and 80 percent of it sits inside the health plans
Minnesota Medicaid paid for 6.9 million NEMT trips in 2024: 1.4 million fee-for-service trips worth $32.2 million and 5.5 million managed-care trips worth $119.2 million, per DHS’s March 2 figures to the House [1].
The fee-for-service side splits by mode, and the split decides who pays you. Minn. Stat. 256B.0625, subdivision 17 lists seven: client mileage, volunteer drivers, unassisted (a taxi or a bus), assisted (a walking rider who needs help door to door), lift-equipped or ramp (the rider stays in the wheelchair), protected transport, and stretcher [30]. Modes 1 through 4 are the county lane; modes 5, 6, and 7 are state-administered and paid directly to the enrolled provider [8].
The state’s rates, from the statute and the MHCP fee schedule as of August 11, 2026 [30][31]:
| Mode | Base rate | Per loaded mile, as paid in 2026 |
|---|---|---|
| Unassisted (NEMT provider, not transit) | $12.10 | $1.51 |
| Assisted | $14.30 | $1.51 |
| Lift-equipped or ramp | $19.80 | $1.80 |
| Protected transport | $75.00 | $2.40 statutory, before the fuel adjustment |
| Stretcher | $60.00 | $2.54 |
| Extra attendant on a stretcher trip, if medically necessary | $9.00 per trip |
The statute’s mileage figures are $1.43, $1.70, and $2.40; the paid figures carry the quarterly fuel adjustment the statute orders whenever Minnesota gasoline tops $3 a gallon [30][31]. A ten-mile wheelchair trip in the metro pays $37.80. Rural trips pay more: if the rider’s home zip is rural under the RUCA system, mileage pays 125 percent on trips of 17 miles or less and 112.5 percent from 18 to 50 miles, and a super-rural zip adds 11.3 percent to the base [30].
Nothing pays for the drive to the pickup. “NEMT providers cannot bill for ‘no load’ miles,” DHS told the committee, and wait time and no-shows are excluded too [1]. Margin lives in loaded miles and trip density.
The health plans set their own rates
The statute’s rate paragraphs don’t apply to managed care [30]. Blue Plus, HealthPartners, Medica, and the county-based plans negotiate, and none publishes a transportation rate card that I could find. Ask for the rate sheet before you sign.
Facilities are the stability
Minnesota has 113 Medicare-certified dialysis facilities across 50 of its 87 counties, and 338 nursing facilities with 24,060 certified beds, per CMS’s provider files in September 2026 [32][33].
Private pay is the margin, and the published cards are old
Published Minnesota rate cards are scarce and mostly stale. One current card in Winona County: ambulatory $25 pickup plus $2.49 a mile, wheelchair $30 plus $2.49, $11 per 30 minutes of waiting [34]. A 2021 Twin Cities booklet runs from $18.75 plus $1.55 a mile to $45 plus $3 for wheelchair riders [35]. Treat those as a floor to shop against. Minnesota private pay is real, and the operators chasing it are few.
The geography
The seven-county metro holds 55 percent of Minnesota’s people and half of its residents 65 and older [36]. The rest are spread across Rochester, Duluth, and St. Cloud and across counties where nearly a third or more of residents are past 65: Aitkin at 35.5 percent, Cook at 32.6, Lake and Koochiching at 29.5 [37][36]. The counties aging fastest are exurban: Carver’s 65-and-over population grew 28 percent in four years, Scott’s 24 percent, Wright’s 22.5 percent [36]. Rural counties have the need today; the exurbs have the curve. Two of those three, Carver and Scott, sit inside the seven-county freeze; Wright, Chisago, and Sherburne are the first ring outside it.
The smaller lanes, and one that’s bigger than it looks
- Waiver transportation. Minnesota’s home and community-based waivers pay separately for non-medical rides on a case manager’s authorization. The same STS certificate covers it, with no 245D license, plus a DHS enrollment as a waiver provider, which may or may not be your type 82 record, so ask, and a one-time provider training before that enrollment. DHS’s April 2026 rate limits put the Elderly Waiver and Alternative Care one-way trip at $20.21 and mileage at $1.54, with no published ceiling for the disability waivers [38][39][40]. It’s a different product by statute, not a way around the freeze [40].
- Two more doors. The Met Council’s Metro Move contract carries metro waiver riders at $26 a one-way trip and $35 for a wheelchair trip, per the March 2026 state study of Metro Mobility, and the Minneapolis VA’s $2.8 million wheelchair transportation order recompetes through SAM.gov [41][42].
Who is the NEMT broker in Minnesota?
Nobody is Minnesota’s statewide NEMT broker. State law forbids one: “Except for establishing level of service process, the commissioner shall not use a broker or coordinator for any purpose related to nonemergency medical transportation services,” says Minn. Stat. 256B.0625, subdivision 18b, on the books since 2009 [30]. Rides are arranged three ways at once: counties handle ambulatory trips, the state pays fee-for-service wheelchair, stretcher, and protected trips directly with no dispatcher in between, and each health plan runs its own ride line [1][8]. A 2025 law orders DHS to replace all of that with one contracted administrator, and the 2026 Legislature took the start date off the calendar.
Where MTM fits, and where it doesn’t
MTM Health is in Minnesota, but it works for counties, not the state. Its own Minnesota page: “MTM Health coordinates non-emergency medical transportation (NEMT) for fee for service Medical Assistance recipients in the Metro Twin City area through a contract with the Metro County Consortium” [43]. DHS’s manual, as it reads in search results, names Hennepin County as the host for that contract across 13 counties: Anoka, Benton, Chisago, Dakota, Hennepin, Isanti, Mille Lacs, Pine, Ramsey, Sherburne, Stearns, Washington, and Wright [44]. St. Louis County hosts four more, Aitkin, Carlton, Lake, and St. Louis, since January 1, 2019, and SmartLink, the Scott and Carver transit agency, coordinates there [44][45].
The brand “MNET” is that county contract. A wheelchair van in Hennepin County bills MTM for its assisted ambulatory work and bills DHS directly for its wheelchair work. The other 68 counties run the ambulatory lane through their own human services offices or a coordinator they’ve hired. DHS tells providers to “contact MTM-MNET, SmartLink or the local county or tribal agency for transportation service enrollment or contracting information,” as its manual reads in search results [46].
Which plan runs which ride line
Every plan arranges its own rides, and none names an outside broker. As of September 2026, from the plans’ pages: Blue Plus runs BlueRide, HealthPartners RideCare, Medica Provide-a-Ride, and UCare Health Ride, with notice windows of two to five days [47][48][49][50]. Those four pages I could read only in search results, and two of Blue Plus’s disagree on the window, so ask. Hennepin Health routes rides through Member Services, on a page last approved in 2020 [51]. The county-based plans run their own lines: PrimeWest’s Transportation Contact Center on two business days’ notice, South Country’s RideConnect on three, and IMCare through Itasca County Health and Human Services [52][53][54].
UCare is the caution. It left PMAP and MinnesotaCare in eleven counties on September 1, 2025, froze enrollment, and was placed into court-ordered rehabilitation [55][56]. Its MSHO and Integrated SNBC plans ended December 31, 2025, and Medica took certain UCare contracts and assets on January 1, 2026; UCare’s PMAP, MinnesotaCare, MSC+, and non-integrated SNBC products continue under its own name [57]. If a UCare contract is in your 2027 plan, ask both, and ask which product.
The administrator that’s coming, on a date nobody has set
In June 2025 the Legislature added subdivision 18i: “the commissioner must contract either statewide or regionally for the administration of the nonemergency medical transportation program” [30][58]. The same law sunset the county lane, the statutory rate table, the rural add-ons, and the broker ban on July 1, 2026 for fee-for-service and January 1, 2027 for managed care [58].
Then the dates went away. Laws 2026, chapter 121, signed May 27, 2026, struck them from every paragraph of the subdivision and substituted “upon implementation of the administrator under subdivision 18i” [25]. It added that DHS “must provide six months notice to counties, managed care organizations, and county-based purchasing organizations before implementing the administrator” [25]. The counties’ own association had already recorded the change in its May 4 legislative update, three weeks before the governor signed [59].
One wrinkle: the same chapter’s electronic visit verification article still recites the old dates, which the revisor reconciles when the 2026 statutes publish; DHS applied a July 1, 2026 fuel adjustment to the NEMT mileage codes as if nothing had expired [25][60]. DHS ran a procurement for “Administrative Services for NEMT” from January 15 to February 12, 2026, per bid listings visible only in search results, and no award has been announced [61]. Absence from a search isn’t proof of absence, so ask DHS’s Provider Resource Center (651-431-2700) before you build a 2027 plan.
What it means for you: the county and plan contracts you sign this year end when the administrator is implemented. DHS owes the counties and plans six months’ notice before that day and owes you none. Expect new credentialing and new rates. Minnesota will look like Georgia under Verida or Colorado under MediDrive on that day, and our broker tracker will carry the notice when DHS issues it.

Is there a moratorium on new NEMT providers in Minnesota?
Yes, for the Twin Cities metro, as of September 10, 2026. DHS froze new provider enrollment in 13 Medicaid service categories on January 27, 2026, “nonemergency medical transportation services” among them, and said in its release that “CMS directed Minnesota to implement this provider enrollment freeze” [4]. On July 15 it extended the pause on 12 high-risk services “at least another six months” [62]. John Connolly, by then the temporary commissioner, was quoted: “We still have a lot of work to do to verify the providers we have before we begin accepting new applications” [62].
DHS’s July 23 provider news, as it reads in search results, narrows the NEMT freeze to providers “located in the seven-county metro area which includes Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties” and extends it to January 27, 2027. The notice goes on: “NEMT providers located in any Minnesota county that is outside the seven-county metro area can enroll” [6].

Confirm the county line with DHS before you sign a lease on either side of it. Exceptions aren’t a workaround: “All exceptions require written approval from CMS” [4]. The 2026 Legislature also gave DHS a moratorium power of its own, Minn. Stat. 256B.0444, as enacted by Laws 2026, chapter 121, effective August 1, 2026: up to 24 months, with every provider in the category revalidated before it ends [25]. If that clock governs this freeze, the outer bound is January 2028. Nothing obliges DHS to lift it on January 27, 2027; the freeze was imposed at CMS’s direction, where moratoria renew six months at a time.
How Minnesota got here
At the House Fraud Prevention Committee’s March 2 hearing, DHS put 2025 at about 2,000 providers, roughly 250,000 riders, and about $127 million, down from $151 million in 2024 [63][1]. Billed rides were 64 percent lower in December than in January, per the coverage, which noted providers have a year to bill [63].
Then came Minnesota Revalidate. From February 2, every provider in the 13 high-risk types had to file a fresh application, pay the fee again, and pass an unannounced site visit by May 31, 2026 [64][65]. Of 5,583 providers, 2,061 passed and 3,411 got disenrollment notices: 2,491 for incomplete or inaccurate applications, 916 for failed site visits, four for failed background studies [66][67]. How many of the incomplete were disorganized, defunct, or fraudulent isn’t published. The lesson for a new entrant is the same either way: administrative discipline.
What a 2026 entrant inherits
- High-risk screening, fingerprints and an unannounced site visit, and the 2026 law puts revalidation with a site visit on a three-year cycle [5][25].
- Authority to withhold a new high-risk provider’s first 90 days of claims, under new Minn. Stat. 256B.0443, as enacted by Laws 2026, chapter 121, which says DHS “may withhold” and moves a power it already held [25]. Nothing published says whether DHS is using it on NEMT; plan your runway as if it will.
- Electronic visit verification for NEMT from January 1, 2027 or federal approval, whichever is later [25].
- A five-year bar. A terminated NEMT provider, “including all named individuals on the current enrollment disclosure form and known or discovered affiliates,” can’t re-enroll for five years, then serves a probation year of unannounced visits [30].
Clean files are the entry ticket.
Can I bill Minnesota Medicaid directly for NEMT rides?
Yes for wheelchair, stretcher, and protected transport, and never for ambulatory trips. State-administered NEMT, modes 5 through 7, is “reimbursed directly to the MHCP-enrolled providers,” while county-lane providers “do not bill MHCP directly for transport services,” per DHS’s bulletin to the counties [8]. No broker sits in the fee-for-service wheelchair lane. The rider gets a level-of-service certificate, calls an enrolled provider, and the provider bills DHS; a plan member’s wheelchair trip bills the plan. For comparison, Arizona’s direct lane is permanent, North Carolina’s runs through county social services, and Virginia has none.
How the wheelchair lane works
Acentra Health, the state’s medical review agent, certifies riders into modes 4, 5, and 7 through its portal, ten days standard and 72 hours expedited since January 1, 2026 [68]. Nursing facility residents are exempt from the level-of-need determination by statute for wheelchair-level trips; DHS’s manual still routes every stretcher trip through the review agent, nursing facility or not [30][69].
You bill on an 837P claim through MN-ITS, one base unit and the loaded miles, with the driver’s UMPI as the rendering provider; the statute puts the driver on every claim, and DHS’s bulletin says county claims without the enrolled driver’s identifier “will deny” [30][8]. DHS pays every other week: a Thursday cut-off, EFT the following Wednesday, remittance files “every other Friday” [70]. A trip billed the day after a cut-off waits about 19 days.
That calendar is the clean-claim case. DHS told the House that NEMT sits under enhanced pre-payment review, and the governor paused payments on the high-risk services for up to 90 days last October [1][3]. The 2026 law also lets DHS withhold a new high-risk provider’s first 90 days of claims; nothing published says whether it does that for NEMT, so plan as if it will [25].
The trip record that decides whether you keep the money
Subdivision 17b makes documentation “a condition for payment” and lists fourteen elements every trip record must carry [30]:
- The rider’s name and the date of service.
- The driver’s printed name or provider number and dated signature attesting to “the actual miles driven.” Misreporting “may result in civil or criminal action.”
- The rider’s dated signature or the medical provider’s certification of arrival, or a note that signatures were requested.
- The origin and destination addresses, the most-direct-route mileage, and how you determined the route.
- The mode and the license plate.
- The pickup and drop-off times and the odometer reading at each.
- The attendant’s name, if one rode.
Money paid on undocumented trips “may be subject to recovery,” and the standard applies to audit findings going back to January 1, 2020 [30]. The record didn’t change in 2026, but the claim did: since July 2026 DHS requires the referring provider on every NEMT claim, per its manual revisions page [60].
The ambulatory lane, and why it pays through the county
DHS’s manual says local-agency providers “do not bill MHCP for service reimbursements,” and, as its county-lane page reads in search results, that means no direct billing for unassisted (curb-to-curb) or assisted (door-to-door and door-through-door) transport and a contract with the county coordinator instead [71][46]. The county bills DHS and pays you on its own terms, which DHS reviews, with the coordinator’s per-trip administration fee needing DHS approval [8]. Ask the county what it pays and when before you build an ambulatory book.
What licenses and requirements does a NEMT business need in Minnesota?
Minnesota has no license called a NEMT license. The state operating authority is MnDOT’s Special Transportation Service (STS) certificate of compliance. Minn. Stat. 174.30 and Minnesota Rules chapter 8840 require it of any company carrying elderly or disabled riders on a regular basis with state or federal money in the fare [29][72].
For Medicaid work, Minn. Stat. 256B.0625, subdivision 17 removes the doubt: “All nonemergency medical transportation providers must comply with the operating standards for special transportation service,” and “all drivers must be individually enrolled with the commissioner” [30].
The claims you’ll read elsewhere, against the sources
| The claim you’ll read elsewhere | What Minnesota actually requires |
|---|---|
| ”Minnesota funds most non-emergency medical transportation through Medical Assistance … and routes those trips through contracted brokers rather than paying providers directly” | No statewide broker exists, and the state is barred from using one [30]. DHS pays fee-for-service wheelchair, stretcher, and protected trips directly to the enrolled provider, counties pay for ambulatory trips, and plan members’ rides bill the plan [8]. |
| ”Minnesota is the one state that bans broker dispatching outright” / “Minnesota does not have transportation brokers” | The ban binds DHS, not counties or plans. MTM coordinates the county lane in 17 counties under a county contract, and each health plan runs its own ride line [30][43]. |
| ”To serve Medicaid recipients, certification from the Minnesota Department of Human Services (DHS) is required” | DHS enrolls you; MnDOT certifies you. The certificate is the STS certificate of compliance under Minn. Stat. 174.30 [29][72]. |
| ”Minnesota Department of Public Safety: Register and inspect your vehicles” | MnDOT’s Office of Freight and Commercial Vehicle Operations inspects STS vehicles, at application and every year [21]. |
| ”Obtain a business license from your local city or county government” / “depending on your county, a local operating permit” | Minn. Stat. 174.30, subd. 6: a certificate holder “is not required to obtain any other state or local permit, license or certificate” for those vehicles [29]. |
| ”Drivers must … undergo background checks and drug testing” and hold “CPR and First Aid certification” | The state rule requires a DHS fingerprint background study, four hours of first aid, and no CPR or drug testing; brokers may add both by contract [29][27]. |
| ”Commercial auto insurance that meets state minimums for passenger transport” (no number given anywhere) | $500,000 combined single limit per vehicle, filed by your insurer on a Form E, under Minnesota Rules 8840.6000; $1 million on two policies to work for MTM [19][20]. |
| ”Estimated Annual NEMT Expense: $38 million” and “1,615,880” annual trips | Those figures come from the companion data file to a 2018 Transit Cooperative Research Program report, via a software vendor’s page. DHS reported $151.4 million and 6.9 million trips for 2024 [1]. |
| ”Ambulatory (per trip) ~$35 … Wheelchair (per trip) ~$70” / wheelchair “$65 - $110” base plus “$3.00 - $5.50” per mile | The state pays $12.10 for unassisted and $19.80 for wheelchair trips, plus $1.51 and $1.80 a mile as of August 2026 [31]. |
| ”Unassisted transport: Base rate of $17.00 per trip, plus $2.38 per mile … set to go into effect January 1, 2026” | A bill, H.F. 36, introduced February 2025 and never heard; its own summary labels the column “Proposed” [73][74]. |
| ”Minnesota Medical Assistance requires … Electronic Visit Verification (EVV) compliance” | Not yet. DHS’s EVV program covers personal care, waiver, and home health services; NEMT joins it January 1, 2027 or on federal approval [75][25]. |
| Silence on the moratorium | New NEMT enrollment frozen since January 27, 2026, now for metro-located providers through January 27, 2027 per DHS’s July 23 notice, as it reads in search results [4][6]. |
Who needs the STS certificate
The rule reaches anyone providing special transportation “on a regular basis,” more than 12 round trips or 30 passengers a month [76]. The statute limits it to providers that “receive grants or other financial assistance from either the state or the federal government,” and the rule extends that to money “distributed to third-party entities under contract” with either: a county coordinator or a health plan paying you with Medicaid dollars [29][76].
So a company paid only by riders themselves, with no Medicaid, Medicare, VA, or plan money anywhere in the fare, sits outside the STS standards on the statute’s face. A facility whose transfers a public program reimburses, a Medicare Advantage plan, or the VA is public money by the rule’s definition. Don’t build on that reading. Get the certificate. MnDOT’s own charge is $45 a vehicle a year, and it makes the rest of the state leave you alone.
What the certificate takes
MnDOT’s Office of Freight and Commercial Vehicle Operations runs the program in the order the checklist’s Phase 2 follows: USDOT number, MnDOT number, background studies, Form E, inspection, certificate packet [16]. Then the deadline that kills new certificates quietly. Within 90 days of the certificate’s effective date, someone with substantial interest or control in the company must finish MnDOT’s initial provider education course, or “the certificate of compliance is deemed canceled upon expiration of the 90 days.” No notice, no hearing [23][16].
MnDOT’s rule keeps STS records three years, except the daily vehicle inspection sheets, which keep for three months [77]. Medicaid runs a longer clock: DHS’s provider requirements say five years, and the trip-record standard reaches audit findings back to January 1, 2020, so keep every trip record at least five years and purge nothing from 2020 on [13][30].
Carrying a passenger who might reasonably need an ambulance draws a penalty of up to $10,000 under Minn. Stat. 174.315, and a third violation in three years means revocation [78].
The naming rule, and the one phrase it allows
A provider may not use “medical,” “emergency,” “life support,” “ambulance,” or anything that suggests ambulance service in its name or advertising unless it holds an ambulance license [9]. The statute carves out one phrase: a provider “may use the phrase ‘nonemergency medical transportation’ in its name” [29].
The local layer that isn’t there
Minn. Stat. 174.30, subdivision 6 is the preemption: a certificate holder “is not required to obtain any other state or local permit, license or certificate as a condition of operating the vehicles for that purpose,” notwithstanding “any other law, ordinance, or resolution to the contrary” [29]. It covers the vehicles used for the service, for that purpose, so a company that also runs ordinary taxi trips still faces the city taxi ordinance for that work.
Minneapolis is the one to call. Its taxi licensing page, updated September 3, 2026, links a “Medical transport vehicle license application,” and a search snippet of the city’s 2026 fee schedule, which I couldn’t open, lists a fee line for a medical transport carrier [79]. The state statute says that license doesn’t reach an STS-certified van; the city’s page doesn’t say. Ask Minneapolis Business Licenses at 612-673-2080 and keep the answer in writing.
Airport pickups are their own layer. MSP’s commercial vehicle ordinance, adopted in 2016 and in force since 2017, charges a $60 annual permit, $3.16 a trip, and a $50 tag fee, and names no medical exemption [80]. It prohibits its “small vehicle passenger service” category except as taxis and rideshare; which category a wheelchair van falls in is the question to ask [80]. Call MAC Landside at 612-726-5463 before you promise a hospital an airport run.
A sedan-only company can’t skip the certificate for Medicaid work anyway; the statute puts taxis inside the STS definition [81]. A private-pay-only sedan company that skips it has no preemption to stand on and likely falls to the city taxi rules, $469 a vehicle and $51 a driver in Saint Paul [82].
The thresholds a wheelchair van stays under
A wheelchair van sits under both CDL triggers, 16 passengers counting the driver and 26,000 pounds, and MnDOT’s June 2026 fact sheet says the same for STS drivers [83][84]. Minnesota has four license classes and no chauffeur or livery class between D and the CDL [83].
What are the NEMT insurance requirements in Minnesota?
Minnesota contracts expect $1 million of commercial auto liability and $1 million of general liability; the state floor under MnDOT’s rule is a $500,000 combined single limit per vehicle, filed by your insurer on a Form E [20][19].
The contract bar: $1 million, on two policies
MTM Health, which coordinates the metro counties’ fee-for-service ambulatory rides, writes it on its Minnesota provider page: “general and automobile liability policies of no less than $1,000,000 each,” with MTM Health “listed as a Certificate Holder and Additional Insured on both,” plus workers’ compensation [20].
The state floor: $500,000 a vehicle, filed by your insurer
Minnesota Rules 8840.6000 requires, “for each vehicle,” Minnesota no-fault benefits, “residual liability coverage in the amount of $500,000 combined single limit,” and uninsured and underinsured motorist coverage [19]. Your insurer files any cancellation on a Form K, effective 30 days after MnDOT receives it; MnDOT suspends the certificate five days after mailing you the notice, and you have 45 days to cure or the certificate is canceled [19][85].

What it costs
No licensed agency publishes a Minnesota premium band. The Amwins paratransit program, which writes NEMT and wheelchair vans on admitted paper in Minnesota at $1 million auto liability, lists “Minimum five units” as an eligibility rule [86]. A one-van startup is below that line, which is why first quotes come back ugly.
The only published bands I found come from a medical-billing vendor’s March 2026 guide, not an insurer, and they’re national: wheelchair vans $6,800 to $12,000 a year, plus $800 to $1,500 for general liability [87]. It says a new operator pays 20 to 40 percent more, which puts a first-year wheelchair van at roughly $9,000 to $19,000 for the two liability lines [87]. Treat that as a sanity check, not a quote. Get three quotes from agencies that already write STS providers, and ask each whether the carrier will sign the Form E.
Workers’ comp is part of the STS application
The STS application must include a statement of compliance with the workers’ compensation statute, which requires every employer to insure from the first employee, with penalties “up to $1,000 per employee per week” out of compliance [14][88]. An LLC manager who owns at least 25 percent of a company with ten or fewer members and under 22,880 payroll hours a year is excluded, which describes most one-van owners driving their own van [89]. The first hire means a policy.
Minnesota’s misclassification law, rewritten in 2024, decides a driver’s status by the workers’ comp and unemployment tests, whatever the contract says [90]. Penalties run up to $10,000 per misclassified worker plus up to $10,000 per violation, with owners and officers who knowingly or repeatedly misclassify individually liable [90]. Run W-2 drivers.
The 2026 labor rules a one-van company meets
- Paid Leave. 0.88 percent of wages, or 0.66 percent for employers of 30 or fewer people at ordinary wages; you may deduct no more than half the standard rate from paychecks [91][92][93].
- Minimum wage. $11.41 statewide for 2026, $16.37 for every employer in Minneapolis, and in Saint Paul $14.25 for a business with five or fewer employees from July 1, 2026, rising to $16.37 at the sixth [94][95][96].
- Workers’ comp rates. In the 2026 assigned-risk plan, drivers classed as bus-company employees rate $5.667 per $100 of payroll and drivers classed as chauffeurs $8.204, a 45 percent swing the rating bureau decides, not you [97].
What do NEMT drivers need in Minnesota?
NEMT drivers in Minnesota don’t need a CDL for a wheelchair van; a regular Class D license covers vehicles designed for 15 or fewer passengers including the driver, up to 26,000 pounds [83][84].
Layer one: the DHS enrollment
The statute is the source: “all drivers must be individually enrolled with the commissioner and reported on the claim as the individual who provided the service,” with public transit, volunteers, and not-for-hire vehicles exempt [30]. Each driver files the individual enrollment application as type DR, Transportation Driver, with a background study number on the form [12]. DHS assigns the driver a UMPI that goes on every claim they drive [30].
The study is the fingerprint-based NETStudy 2.0 study through DHS, and a driver can’t work until DHS returns an eligible or set-aside notice [29]. A driver who has been off your roster more than 180 days needs a new study [98].
Layer two: MnDOT’s driver file
Minnesota Rules 8840.5900 sets the state’s driver qualifications [26]:
- At least 18, with a license valid for the class of vehicle driven.
- A three-year lookback on the driving record: no cancellation, revocation, or the listed suspensions, no conviction for driving without a valid license, and no DUI conviction or alcohol-related revocation.
- A federal medical examiner’s certificate under 49 CFR 391.43, carried on the driver while driving.
- The driving record pulled before hire and every year after, and the DHS background study clearance reviewed before the first shift.
Layer three: the training, in person, with tests
Minnesota Rules 8840.5910 builds the training in three tiers [27]:
- Before the first passenger, from you: orientation, a demonstration of the lift, ramp, and securement, emergency procedures, the daily inspection, and a behind-the-wheel evaluation.
- Within 45 days, from a MnDOT-certified trainer: four hours each of first aid, abuse prevention, and classroom defensive driving, plus passenger assistance: eight hours for wheelchair work, four for ambulatory-only, two more for stretcher work, three for child restraints.
- Every three years, a 15-hour refresher across the same subjects.
Every course includes proficiency testing and is taught in person unless MnDOT pre-approves otherwise, by instructors MnDOT certifies [27][99].
The background study reaches the office
Minn. Stat. 174.30, subdivision 10 lists who gets a study. Owners at 5 percent or more, controlling individuals and managerial officials, every driver, every attendant, and “all employees” who “may have face-to-face contact with or access to passengers,” “perform any scheduling or dispatching tasks,” or “perform any billing activities” [29]. Your dispatcher and your biller get fingerprinted.
What MTM and the plans add
PrimeWest lists MnDOT certification, DHS enrollment, and “additional driver and attendant training for protected transportation services” [100]. Drug testing, CPR, and camera requirements live in the plans’ provider agreements when they exist at all, so read the agreement before you build the driver file, and build every file to the strictest contract you hold.
What the van has to carry
A daily visual safety inspection, logged, covering eleven items including the lift and the securement devices [77]. Every wheelchair position needs a securement device approved under Minn. Stat. 299A.11 to 299A.17, inspected within a month of installation and every year after, with a misdemeanor for each failure; MnDOT’s decal can stand in for the separate securement certificate, so one inspection covers both [101][29].
Can a NEMT company run stretcher van trips in Minnesota?
Yes, on the strength of one clause. Minn. Stat. 144E.001, subdivision 3 defines ambulance service to include “all transportation involving the use of a stretcher, unless the person to be transported is not likely to require medical treatment during the course of transport” [102]. A stretcher trip for a stable rider falls outside that definition, and MnDOT’s STS definition picks it up from the other side: riders who “do not require ambulance service” [81].
What Medicaid calls it, and what it pays
Mode 7, “stretcher transport,” is “transport for a client in a prone or supine position” in a vehicle that can carry one [30]. The state pays $60 plus $2.54 a loaded mile this year, and $9 a trip for an additional attendant “if deemed medically necessary” [31][30]. That $60 base hasn’t moved since 2005; the 2023 law’s increase, effective January 1, 2024, skipped stretcher and protected transport entirely [103]. Every stretcher trip, nursing facility resident or not, needs the review agent’s certification first [69].
No statute or rule requires an attendant on a stretcher trip; the attendant is a $9 line item. The rules do require “a minimum of two hours” of stretcher-specific training on top of the passenger assistance course, and a stretcher securement that meets the federal ambulance specification [27][28].
The line is treatment, and offering counts
The transport becomes ambulance service when the rider is likely to require “medical treatment during the course of transport,” or when treatment is “rendered or offered to be rendered” [102]. Administering oxygen, running an IV, monitoring: ambulance.
Write the no-care line into your dispatch protocol, and get the Office of Emergency Medical Services’ reading in writing before the first hospice contract. Other states drew this line differently: Texas makes non-EMS stretcher work a crime, Colorado carves it out of its ambulance law, Virginia never decided.
Protected transport, the mode nobody else runs
Mode 6 is Minnesota’s behavioral-health lane. The rider is someone whose prescreening “has deemed other forms of transportation inappropriate” [30]. The provider has “a protected vehicle that is not an ambulance or police car and has safety locks, a video recorder, and a transparent thermoplastic partition between the passenger and the vehicle driver” [30].
A mental health crisis team certifies each rider, for a single trip on a single date, on DHS form 6715, and for a hospital-to-facility transfer a hospital’s licensed practitioner can sign the same form [104][105]. DHS’s manual adds a training layer MnDOT’s rules don’t carry: at least six hours from Crisis Intervention Team training, Mental Health First Aid, or another formal de-escalation course, for every protected-transport driver and attendant [105].
It pays $75 plus $2.40 a mile before the fuel adjustment, the highest base in the schedule [30]. No statute requires two staff, but DHS’s manual does: “Protected transport requires a driver and an attendant be in the vehicle during each transport. Additional payment for the attendant is not a separately reimbursable charge,” with one exception, a rider stabilized in an emergency department on a trip under 100 miles [105].
How do you become a Minnesota Medicaid NEMT provider?
Two tracks run in parallel, and each lists the other as a prerequisite. MnDOT’s “Become a provider” page puts “Register with Minnesota Health Care Programs” among its steps, and DHS’s enrollment page, as it reads in search results, asks for the STS certificate and MnDOT vehicle list [16][106]. Run them together.
Step one: the MnDOT number, then the background studies
The MnDOT number that comes back from the business packet is what NETStudy 2.0 needs before a single background study can start [98].
Step two: Form E, inspection, certificate
Insurer files the Form E, MnDOT inspects the vans and sells you the $45 decals, you file the certificate packet, and the rule gives MnDOT 30 days from a complete application [22]. Then the 90-day education clock starts [23].
Step three: DHS enrollment, outside the metro
Pay the non-refundable $750 federal application fee, per location, then file the organization enrollment in the MPSE portal as provider type 82, specialty 89, with the STS certificate and vehicle list, the provider agreement (DHS-4138), and the ownership disclosure (DHS-5259) [24][11]. DHS’s manual, as it reads in search results, says 30 days for a complete request, and by statute a request for more information gives you 60 days to answer [106][107]. Fingerprint studies on every 5 percent owner and the unannounced site visit come before approval [5].
Step four: every driver, individually
Each driver files the individual application as type DR, Transportation Driver, from inside your MPSE portfolio once the organization’s welcome letter has landed, listing your company under group affiliation and entering a background study number on the form [12]. The driver signs a provider agreement, DHS-4611A per DHS’s driver-enrollment page as it reads in search results, though the application form’s own checklist names DHS-4138, so ask which [108][12].
Step five: the county and the plans
Ambulatory work needs a contract with the county lane: MTM’s national provider application in its 17 counties, SmartLink in Scott and Carver, the county human services office, or its coordinator, elsewhere [109][45]. Plan work needs each plan’s own transportation agreement.
How long the two tracks take
Two to four months to first Medicaid trips outside the metro, by my math, assuming no request for more information, which restarts DHS’s 30-day clock and gives you 60 days to answer [106][107]. Inside the metro, the clock doesn’t start until the freeze lifts, and since PrimeWest and the county lane require DHS enrollment first, as the other plans’ agreements almost certainly do, the freeze closes those doors too [100][8].
Start with the payer the freeze can’t reach
The certificate arrives and the van is legal to carry riders that week. Private-pay families and facilities don’t check whether DHS is enrolling. For facilities that already have a provider: ask to be the backup for Sundays and after hours, take the two trips nobody else wants, and be early both times.
Don’t build the whole schedule on one payer
Minnesota spent 2026 proving the point: a metro enrollment freeze, a revalidation that sent 3,411 disenrollment notices, a health plan in court-ordered rehabilitation. And a coming statewide administrator will replace every county and plan contract in the state, on six months’ notice to them and none to you.
Minnesota just showed what one payer can do to a schedule
The rural Minnesota operator from the top of this guide has spent a year and a half waiting on one plan contract and hasn’t carried a rider.
That isn’t an argument against Medicaid work. It’s an argument against a schedule that stops when one payer does.
The hedges Minnesota hands you
- The wheelchair lane bills the state directly, with no broker to drop you, until the administrator arrives [8].
- Facilities. 338 nursing facilities and 113 dialysis clinics, most of the clinics under two chains [33][32].
- Private pay at three times the Medicaid rate, by the two-van suburban operator’s count, in a metro where he sees nobody else chasing it.
- Rochester and greater Minnesota. Mayo’s 139,000 patients a year from out of town need rides to and from a city of 124,000, and outside the metro, where enrollment is open, a county of 164,000 has one dialysis clinic [110][37][32].
The other half of the argument
On demos I push private pay and facility work first, because $37.80 for a ten-mile wheelchair trip doesn’t cover an insurance bill that doesn’t care how you’re reimbursed [31][1]. The counterweight is real too. Medicaid here is 6.9 million trips a year, the state pays fee-for-service wheelchair work directly, on a two-week cycle for clean claims, and 3,411 high-risk providers just got disenrollment notices, most over paperwork, which means the network has holes in it right now [1][66]. No single county or plan should own your schedule.
Whatever mix you land on, keep it in one system: Duet merges county and plan trip files with your facility and private-pay bookings, with the odometer readings and signatures the trip record demands.
How much does it cost to start a NEMT business in Minnesota?
One used wheelchair van, certified, insured, and legal to carry riders, runs $40,000 to $60,000 in Minnesota. A new conversion pushes it toward $100,000. Then the runway. One van with a hired driver at Minneapolis wages burns about $5,500 to $6,500 a month: insurance, wages and payroll costs, fuel, a van payment, software. Three to six months of that comes to $17,000 to $39,000, so a company that opens with the runway in the bank is at $55,000 to $100,000 all in.
The line items
| Line item | What it costs |
|---|---|
| LLC formation | $155 online, $135 by mail; annual renewal free [10] |
| Registered agent | $0. Minnesota requires a registered office at a street address and only “may” have an agent [111] |
| Assumed name, if you use one | $50 online plus newspaper publication in two issues, which no fee schedule shows [10][112] |
| EIN | Free |
| NPI | Free, and not required for the DHS enrollment [11] |
| State NEMT license | $0. None exists |
| USDOT number, intrastate | $0 [15] |
| MnDOT STS certificate | No published application fee; $45 per vehicle per year for the inspection decal [29][113] |
| Background studies | $44 each plus $13.50 fingerprinting, for every owner, driver, attendant, dispatcher, and biller; about $345 for six people [17][18] |
| DOT medical examiner’s certificate, per driver | Clinic-priced; budget about $100 |
| MnDOT-certified driver training | Trainer-priced; ask MnDOT’s certified trainer list |
| DHS enrollment | $750 federal application fee for 2026, per location, non-refundable, charged again at revalidation [24][11] |
| City permits | $0 for an STS-certified van under state preemption, with the Minneapolis question flagged in the licenses section [29] |
| Commercial auto and general liability | Roughly $8,000 to $14,000 a year at the $1 million bar for a wheelchair van in one vendor’s national estimate, $9,000 to $19,000 with the 20 to 40 percent new-operator loading it describes [87] |
| Used wheelchair minivan | $28,000 to $38,000 for a 2010 to 2019 conversion with 90,000 to 140,000 miles at the two Twin Cities dealers, $61,000 to $88,000 for a 2024 or 2025 [114][115] |
| New full-size conversion | $83,662.75 for a 2026 Ford Transit wheelchair van at one dealer’s September pricing, less $2,250 in rebates [116] |
| Registration tax | $10 plus 1.575 percent of the original MSRP, scaled down by age; a used van previously registered in Minnesota pays no more than the smallest amount ever paid on it [117] |
| Motor vehicle sales tax | 6.875 percent, but the conversion’s value is excluded from the tax base [118] |
| Workers’ comp | From the first employee; $5.67 to $8.20 per $100 of payroll in the 2026 assigned-risk plan [88][97] |
| Working capital | Three to six months at about $5,500 to $6,500 a month with a hired driver; DHS pays every other week and may withhold a new high-risk provider’s first 90 days [70][25] |
Anyone quoting a $5,000 Minnesota launch hasn’t priced the Form E.
How do you fund a NEMT startup in Minnesota?
All checked September 2026, none of them fast:
- DEED’s Emerging Entrepreneur Loan Program lends $5,000 to $150,000 through partner nonprofits and CDFIs to businesses owned by minorities, women, veterans, people with disabilities, or low-income owners. The state covers up to half of each loan and private money matches at least the rest, except on microloans up to $40,000 ($55,000 in a low-income area), which need no match [119].
- The African Development Center makes microloans up to $50,000 and business loans up to $350,000, with vehicle financing named on its page, and WomenVenture lends up to $100,000 to anyone with a business, women or not [120][121].
No lender can reopen the metro or hurry a site visit. Borrow against the timeline you actually face: the screening, then a possible 90 days of withheld claims.
How long does it take to start a NEMT business in Minnesota?
Private-pay and facility trips start when the STS certificate and the Form E policy land, four to eight weeks from filing if the background studies and the inspection go smoothly. Medicaid trips take two to four months outside the metro, by my math. Inside the metro they wait on a freeze DHS has extended to January 27, 2027, per its notice as it reads in search results [6].
- Now. Check the name against the STS rule, file the LLC, get the EIN and the USDOT number, and quote insurance at the $1 million bar before you shop for a van [9][10][20].
- Weeks 1-2. File MnDOT’s business packet; the MnDOT number comes back by mail, and NETStudy 2.0 on every owner, driver, and office employee the statute lists can’t start until it does [98][29].
- Weeks 2-4. Buy the van after the quote. Insurer files the Form E. Schedule the MnDOT inspection [19][21].
- Weeks 4-8. Certificate of compliance, decals, lettering, and the first private-pay and facility trips. Finish the initial provider education inside 90 days [22][23].
- Weeks 4-8, in parallel, outside the metro. Pay the $750 and file the organization enrollment in MPSE with the certificate and vehicle list [11].
- Weeks 8-16. DHS review, the unannounced site visit, the welcome letter, then each driver’s DR enrollment from your portfolio. First state-billed wheelchair trips once the drivers’ UMPIs issue, with the first 90 days of claims possibly withheld [5][12][25].
- Months 3-4. County coordinator contract for ambulatory work and the plan agreements, each with its own credentialing [109][100].
- Throughout. Everything in Phase 5, a watch on DHS’s six-month administrator notice to the counties and plans, and, for anyone applying on or after January 1, 2027, the owner and manager compliance training before the application goes in [25].

Minnesota NEMT FAQ
Does Minnesota require a NEMT license?
Not by that name. The state operating authority is MnDOT’s Special Transportation Service certificate of compliance, required by Minn. Stat. 174.30 for any company carrying elderly or disabled riders on a regular basis with public money in the fare [29]. It takes background studies, a $500,000 Form E policy, a MnDOT inspection, and a $45 decal per van, with no published application fee [19][113]. A certificate holder needs no city or county permit for those vans; Minneapolis’s medical transport vehicle license is the one question [29].
Who is the NEMT broker in Minnesota?
Nobody, statewide; state law bars DHS from using a broker [30]. Counties arrange ambulatory rides, MTM doing that job for 17 counties under two county consortium contracts, the state pays fee-for-service wheelchair, stretcher, and protected trips directly, and each health plan runs its own ride line [43][44][8][52]. A 2025 law orders one contracted administrator; the 2026 Legislature replaced its July 1, 2026 start date with six months’ notice to the counties and plans that, as far as I can find, DHS hasn’t given [25].
Is there a moratorium on new NEMT providers in Minnesota?
Yes, in the seven-county metro, as of September 2026. DHS froze new enrollment in 13 Medicaid categories including NEMT on January 27, 2026 at CMS’s direction [4]. Its July 23 notice, as it reads in search results, extends the NEMT freeze to January 27, 2027 for providers located in Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties, and reopens enrollment everywhere else [6]. Exceptions need CMS’s written approval, and the 2026 law lets a moratorium run up to 24 months [4][25].
Can I bill Minnesota Medicaid directly for NEMT rides?
Yes for fee-for-service wheelchair, stretcher, and protected transport, reimbursed directly to the enrolled provider on a two-week cycle for clean claims under enhanced pre-payment review; a plan member’s trip bills the plan [8][70][1]. Never for ambulatory trips, which the county or its coordinator pays, MTM in 17 counties and SmartLink in Scott and Carver [8][45]. Every claim names the enrolled driver, every trip needs the 14-element record behind it, and DHS may withhold a new high-risk provider’s first 90 days of claims [30][25].
How much does Minnesota Medicaid pay for a NEMT trip?
By the rider’s assessed mode, not your vehicle. As of August 2026: $12.10 plus $1.51 a loaded mile for unassisted, $14.30 plus $1.51 for assisted, $19.80 plus $1.80 for wheelchair, $60 plus $2.54 for stretcher, and $75 plus $2.40 before the fuel adjustment for protected transport [30][31]. A ten-mile metro wheelchair trip pays $37.80. Rural riders’ trips earn 125 percent of the mileage rate up to 17 miles, and super-rural addresses add 11.3 percent to the base [30]. Nothing pays for the drive to the pickup [1].
What insurance does a NEMT business need in Minnesota?
$1 million of commercial auto liability and $1 million of general liability, with MTM named as certificate holder and additional insured, plus workers’ comp, is what MTM requires [20]. The legal floor is lower: Minnesota Rules 8840.6000 requires $500,000 combined single limit residual liability per vehicle, plus no-fault and uninsured and underinsured coverage, filed with MnDOT on a Form E signed by the insurer [19][85]. Workers’ comp compliance is a condition of the STS application and applies from the first employee [14][88].
Do NEMT drivers need a CDL in Minnesota?
No, below 16 passengers including the driver and 26,000 pounds; a regular Class D license covers a wheelchair van [83][84]. Every driver enrolls with DHS individually after a fingerprint background study, carries a federal medical examiner’s certificate, and is at least 18 with a three-year clean record [30][26]. Within 45 days, each completes four hours each of first aid, abuse prevention, and defensive driving plus eight hours of passenger assistance for wheelchair work; the state rules require no CPR and no drug testing, though contracts may [27].
Can a NEMT company run stretcher van trips in Minnesota?
Yes. Minnesota’s ambulance definition includes stretcher transport “unless the person to be transported is not likely to require medical treatment during the course of transport,” so a stretcher trip for a stable rider falls outside ambulance licensing and inside the STS certificate [102][81]. Medicaid pays $60 plus $2.54 a mile and $9 for a medically necessary attendant; no rule requires a second person [31][30]. Drivers need two hours of stretcher-specific training [27]. Treatment en route, or offering it, makes the trip an ambulance run, a misdemeanor without a license [102][122].
How much does it cost to start a NEMT business in Minnesota?
One used wheelchair van, certified and insured, runs $40,000 to $60,000, and a new conversion toward $100,000. State fees are about $1,000: $155 for the LLC, $750 for the Medicaid application, $45 per decal, and $57.50 per background study [10][24][113][17]. Insurance is roughly $9,000 to $19,000 in year one at the $1 million bar in one vendor’s national estimate [87]. Add three to six months of runway at about $5,500 to $6,500 a month with a hired driver, for $55,000 to $100,000 all in.
Is Minnesota a good state to start a NEMT business in?
Outside the seven-county metro, yes; inside it only for a company that can live on facilities and private pay until the freeze lifts. Demand is 6.9 million Medicaid trips a year, and the network just sent disenrollment notices to 61 percent of its high-risk providers, most over paperwork [1][66]. The margin is in private pay, which one of the two operators here prices at about three times Medicaid; the risk is an administrator on six months’ notice to the counties and plans and none to you [25].
How long does it take to start a NEMT business in Minnesota?
Private-pay and facility trips can start four to eight weeks in, once the background studies clear, the Form E is filed, MnDOT inspects the van, and the certificate issues [22]. Medicaid trips take two to four months outside the metro: DHS’s manual says 30 days for a complete enrollment, then an unannounced site visit, then a welcome letter, and DHS may withhold the first 90 days of claims [5][25]. Inside the seven-county metro, new enrollment waits on the freeze [6].
Key official sources
[1] Minnesota Department of Human Services, “Non-Emergency Medical Transportation (NEMT),” presentation to the House Fraud Prevention Committee (March 2, 2026; slides dated February 27, 2026): 2023 and 2024 trips, paid claims, provider and recipient counts, the 80 percent managed-care share, the no-load-miles rule, high-risk classification, the metro moratorium, investigation and suspension counts. https://www.house.mn.gov/comm/docs/V1YTkkW450ePEPE_hySgBg.pdf
[2] Centers for Medicare and Medicaid Services, deferral letter to Minnesota Medicaid Director John Connolly (February 25, 2026): $259,505,491 deferred, $243.79 million tied to the fourteen high-risk service areas. https://ccf.georgetown.edu/wp-content/uploads/2026/03/Q4-2025-MN-Deferral-Letter-final-daf.pdf
[3] Georgetown University Center for Children and Families, “Minnesota Medicaid fraud timeline” (April 13, 2026, updated): the dated sequence of corrective action plans, deferrals, the lawsuit, and rulings. https://ccf.georgetown.edu/2026/04/13/minnesota-medicaid-fraud-timeline/
[4] Minnesota DHS news release, “Minnesota Department of Human Services freezes provider enrollment for 13 Medicaid services” (January 30, 2026): the January 27, 2026 freeze, the category list including nonemergency medical transportation services, CMS’s direction, the exception rule. https://content.govdelivery.com/accounts/MNDHS/bulletins/406e446
[5] Minnesota DHS, MHCP Provider News, January 27 to February 9, 2026 issue: NEMT designated a high-risk provider type, fingerprint studies for 5 percent owners, the unannounced site visit, the off-cycle revalidation, Provider Resource Center numbers. https://mn.gov/dhs/assets/2026-01-27-mhcp-provider-news_tcm1053-724398.pdf
[6] Minnesota DHS, MHCP provider news and updates, article published July 23, 2026: the NEMT enrollment moratorium extended to January 27, 2027 for providers located in the seven-county metro, with enrollment open elsewhere. Quoted as it appears in search results; the page blocks automated readers. https://mn.gov/dhs/partners-and-providers/news-initiatives-reports-workgroups/minnesota-health-care-programs/provider-news/
[7] Centers for Medicare and Medicaid Services, Medicaid and CHIP monthly applications, eligibility determinations, and enrollment data (August 2026 release): Minnesota enrollment by month, including May 2026 preliminary and the June 2023 peak. https://download.medicaid.gov/data/pi-dataset-august-2026-release.csv
[8] Minnesota DHS Bulletin #25-21-10, “DHS Requests Biennial Health Care Access Plans for Calendar Years 2026 through 2027” (November 20, 2025): the seven modes defined, county-administered modes 1 to 4, state-administered modes 5 to 7 reimbursed directly to enrolled providers, county-lane providers paid by the county, the driver UMPI claim rule, coordinator fees, the MCO coverage rules. Its July 1, 2026 timing is superseded by Laws 2026, chapter 121. https://www.dhs.state.mn.us/main/groups/publications/documents/pub/mndhs-073659.pdf
[9] Minnesota Rules 8840.5450: restrictions on the name and description of the service. https://www.revisor.mn.gov/rules/8840.5450/
[10] Minnesota Secretary of State, Business Filing and Certification Fee Schedule: LLC articles $155 online and $135 by mail, free annual renewal, assumed name fees. https://www.sos.mn.gov/media/1687/businessentityfees.pdf
[11] Minnesota DHS form DHS-4016A, MHCP Organization Provider Enrollment Application (rev. 1-25): provider type 82 Medical Transportation and specialty 89 Special Transportation, no NPI requirement for the type, the application-fee rules, the attachment list. https://edocs.dhs.state.mn.us/lfserver/Public/DHS-4016A-ENG
[12] Minnesota DHS form DHS-4016, MHCP Individual Provider Enrollment Application (rev. 8-25): type DR Transportation Driver, the background study number field for NEMT drivers, group affiliation. https://edocs.dhs.state.mn.us/lfserver/Public/DHS-4016-ENG
[13] Minnesota DHS, MHCP Provider Manual, “Provider Requirements” (revised July 16, 2024): exclusion-list screening, the five-year record-retention minimum, the 30-day change-of-ownership notice. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=ID_008921
[14] Minnesota Rules 8840.5500: the certificate application, the USDOT number, the Form E, the workers’ compensation statement, and ten-day change notices. https://www.revisor.mn.gov/rules/8840.5500/
[15] MnDOT, Intrastate USDOT Number for STS Providers fact sheet (July 2025): no fee for an intrastate number. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=36493317
[16] MnDOT, Special Transportation Services, “Become a provider”: the steps, the naming restriction, the 90-day education requirement, and the Form E cost statement. https://www.dot.state.mn.us/cvo/sts/becomeaprovider.html
[17] Minnesota Statutes 245C.10, subdivision 13: background study fees for special transportation providers capped at $44 per study. https://www.revisor.mn.gov/statutes/cite/245C.10
[18] Minnesota DHS, Background Studies: the IDEMIA fingerprint and photo fee increase to $13.50 on March 30, 2026, paid separately from the NETStudy fee. https://mn.gov/dhs/background-studies/
[19] Minnesota Rules 8840.6000: STS insurance, the $500,000 combined single limit per vehicle, no-fault and uninsured coverage, Form E and Form K, suspension and the 45-day cure. https://www.revisor.mn.gov/rules/8840.6000/
[20] MTM Health, Minnesota Transportation Providers: the $1,000,000 general and automobile liability requirement, certificate holder and additional insured, workers’ comp. https://www.mtm-inc.net/minnesota/transportation-providers/
[21] MnDOT, STS Vehicle Inspection General Information (June 2025): inspections by MnDOT staff at application and annually, outcomes, the Richfield site. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=38359755
[22] Minnesota Rules 8840.5525: certificates issued or denied within 30 days of a complete application, one-year term, denial grounds. https://www.revisor.mn.gov/rules/8840.5525/
[23] Minnesota Rules 8840.5640: the 90-day initial provider education deadline and automatic cancellation. https://www.revisor.mn.gov/rules/8840.5640/
[24] Centers for Medicare and Medicaid Services, MLN Connects newsletter (December 11, 2025): the $750 provider enrollment application fee for applications submitted January 1 to December 31, 2026. https://www.cms.gov/training-education/medicare-learning-network/newsletter/mln-connects-newsletter-december-11-2025
[25] Laws of Minnesota 2026, chapter 121 (S.F. 4476, approved May 27, 2026): article 3, sections 27, 28, and 62 (the sunsets re-tied to implementation of the administrator, six months’ notice), sections 18 to 24 (new sections 256B.044 through 256B.0446: high-risk screening, the 90-day payment withhold, the enrollment moratorium, compliance training), and article 10 (electronic visit verification for NEMT from January 1, 2027 or federal approval). https://www.revisor.mn.gov/laws/2026/0/Session+Law/Chapter/121/
[26] Minnesota Rules 8840.5900: driver qualifications, age, license, driving record, the medical examiner’s certificate, annual record checks. https://www.revisor.mn.gov/rules/8840.5900/
[27] Minnesota Rules 8840.5910: driver and attendant training, the 45-day courses, passenger assistance hours, stretcher and child-restraint add-ons, the three-year refresher, proficiency testing and in-person instruction. https://www.revisor.mn.gov/rules/8840.5910/
[28] Minnesota Rules 8840.5925: vehicle equipment, stretcher securement, and vehicle identification on both sides. https://www.revisor.mn.gov/rules/8840.5925/
[29] Minnesota Statutes 174.30: STS operating standards, applicability and exemptions, the $45 decal, the naming carve-out, the preemption of other state and local permits, penalties, and the background-study list including dispatchers and billers. https://www.revisor.mn.gov/statutes/cite/174.30
[30] Minnesota Statutes 256B.0625 (2025 edition), subdivision 17 (NEMT definition, STS compliance and driver enrollment, the seven modes, the level-of-service rule, the 30- and 60-mile limits, rates, rural add-ons, fuel adjustment), 17b (documentation), 17c (nursing facility residents), 17e (five-year bar), 18b (broker prohibition), 18h (managed care), and 18i (the administrator). The page shows the 2025 text with July 1, 2026 expiration language that Laws 2026, chapter 121 replaced. https://www.revisor.mn.gov/statutes/cite/256B.0625
[31] Minnesota DHS, MHCP Fee Schedule, “current fee schedule as of 08/11/2026”: the NEMT base and mileage codes and amounts, effective dates, and prior-authorization indicators. https://mn.gov/dhs/assets/mhcp-fee-schedule_tcm1053-294225.pdf
[32] Centers for Medicare and Medicaid Services, Provider Data Catalog, dialysis facilities dataset (modified June 16, 2026), queried for Minnesota on September 10, 2026: facility counts by county, chains, stations, and shifts. https://data.cms.gov/provider-data/dataset/23ew-n7w9
[33] Centers for Medicare and Medicaid Services, Provider Data Catalog, nursing homes dataset (modified August 1, 2026), queried for Minnesota on September 10, 2026: facilities, certified beds, and counties. https://data.cms.gov/provider-data/dataset/4pq5-n9py
[34] Sunset Mobility Inc., Winona County nonemergency medical transportation rate card, as seen September 10, 2026. https://sunsetmobilityinc.com/services/non-emergency-medical-transportation-winona-county-mn/
[35] Community Thread, “Transportation Resources for Washington County Residents 2022” (compiled August 2021): Twin Cities operators’ published prices and Metro Mobility fares at the time. https://gowashingtonmn.com/wp-content/uploads/2021/11/Transportation-Resources-Booklet-2022.pdf
[36] U.S. Census Bureau, Vintage 2024 county population estimates by age and sex for Minnesota: statewide and county 65-and-over counts and shares as of July 1, 2024, and the 2020 to 2024 change. https://www2.census.gov/programs-surveys/popest/datasets/2020-2024/counties/asrh/cc-est2024-agesex-27.csv
[37] U.S. Census Bureau, Vintage 2024 subcounty population estimates: Rochester, Duluth, and St. Cloud populations as of July 1, 2024. https://www2.census.gov/programs-surveys/popest/datasets/2020-2024/cities/totals/sub-est2024.csv
[38] Centers for Medicare and Medicaid Services, Minnesota’s approved CADI 1915(c) waiver application (MN.0166.R08, effective October 1, 2025) and Elderly Waiver application (MN.0025.R09.04, effective January 1, 2026): the transportation service definition, provider qualifications including MnDOT STS certification, and market-rate pricing. https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/82181
[39] Minnesota DHS, DHS-3945, “Long-Term Services and Supports Service Rate Limits Effective April 1, 2026”: the waiver transportation trip and mileage rate limits by program. https://edocs.dhs.state.mn.us/lfserver/Public/DHS-3945-ENG
[40] Minnesota Statutes 256B.4912: home and community-based services provider requirements, applicant training, and subdivision 13 on waiver transportation documentation and its separation from medical transportation. https://www.revisor.mn.gov/statutes/cite/256B.4912
[41] MnDOT and Texas A&M Transportation Institute, “Metro Mobility Enhancements Study” (March 2026): the zone contractors, the Premium On-Demand carriers and payment tables, the Metro Move contract and DHS billing rates, and the finding that Medicaid NEMT is infeasible on the Met Council platform. https://www.lrl.mn.gov/docs/2026/mandated/260796.pdf
[42] USAspending.gov, Minneapolis VA Health Care System wheelchair transportation order 36C26326N0524 (August 2, 2026 to August 1, 2027, $2,802,122.50) and related Minnesota VA transportation awards. https://www.usaspending.gov/award/CONT_AWD_36C26326N0524_3600_36C26325D0064_3600
[43] MTM Health, Minnesota Non-Emergency Medical Transportation: the Metro County Consortium contract statement and member line. https://www.mtm-inc.net/minnesota/
[44] Minnesota DHS, MHCP Provider Manual, “Minnesota Nonemergency Transportation (MTM-MNET)” and the local county or Tribal agency NEMT pages: the host-county consortia and county lists, SmartLink. Quoted as they appear in search results; the pages block automated readers. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=DHS-287333
[45] Scott County, Non-Emergency Medical Assistance: SmartLink as the Scott and Carver County ride coordinator. https://www.scottcountymn.gov/553/Non-Emergency-Medical-Assistance
[46] Minnesota DHS, MHCP Provider Manual, “Local County or Tribal Agency Nonemergency Medical Transportation (NEMT) Transportation Services”: providers can’t bill MHCP for modes 3 and 4 and must contract with MTM-MNET, SmartLink, or the county. Quoted as it appears in search results. https://www.dhs.state.mn.us/dhs16_141019/
[47] Blue Cross and Blue Shield of Minnesota, BlueRide transportation pages: the scheduling line and notice rule. Quoted as they appear in search results. https://www.bluecrossmn.com/our-plans/medical-assistance-medicaid/medical-assistance-resources/blueride-transportation
[48] HealthPartners, RideCare medical transportation in Minnesota: the numbers and the 30- and 60-mile scope. Quoted as it appears in search results. https://www.healthpartners.com/insurance/members/benefits-discounts/ridecare-medical-transportation/
[49] Medica, Provide-a-Ride for Minnesota Health Care Programs members: the five-day notice and the tracking portal. Quoted as it appears in search results; medica.com blocks automated readers. https://www.medica.com/find-care/select-your-medicaid-plan/resources/provide-a-ride
[50] UCare, Health Ride: the member line and hours. Quoted as it appears in search results. https://www.ucare.org/health-wellness/special-programs/ucare-health-ride
[51] Hennepin Health, “Get a ride”: Member Services numbers and the authorization rules for taxi and specialized transport. https://www.hennepinhealth.org/members/Get-a-ride
[52] PrimeWest Health, Administered NEMT Services (updated December 8, 2025): modes 2 through 7, the Transportation Contact Center, the two-business-day rule. https://www.primewest.org/pwh-administered-nemt
[53] South Country Health Alliance, RideConnect (updated January 16, 2026): the member line, three-business-day rule, pre-authorization for assisted trips. https://www.mnscha.org/members/member-services/rideconnect/
[54] IMCare Provider Manual, Transportation Services (revised September 12, 2024): rides arranged through Itasca County Health and Human Services. https://www.itascacountymn.gov/DocumentCenter/View/735/Transportation-Services-PDFUpdated-091224
[55] Minnesota DHS bulletin (July 15, 2025): UCare’s exit from PMAP and MinnesotaCare in eleven counties effective September 1, 2025. https://content.govdelivery.com/accounts/MNDHS/bulletins/3e990e8
[56] UCare, provider FAQ on 2025 and 2026 product changes: the enrollment freeze, the senior plan suspension, court-ordered rehabilitation, and the November 17, 2025 agreement with Medica. https://www.ucare.org/providers/provider-news/provider-faq-ucare-product-changes
[57] Minnesota DHS bulletin, “Medica acquiring UCare clarifications” (late 2025): the January 1, 2026 effective date and the end of UCare’s MSHO and Integrated SNBC products on December 31, 2025. https://content.govdelivery.com/accounts/MNDHS/bulletins/400969b
[58] Laws of Minnesota 2025, First Special Session, chapter 3, article 8, sections 13, 14, and 43 (approved June 14, 2025): the subdivision 17 sunsets, new subdivision 18i, the repeal of 18b, 18e, and 18h, and the sunset of the competitive-bidding bar on special transportation. https://www.revisor.mn.gov/laws/2025/1/Session+Law/Chapter/3/
[59] Minnesota Inter-County Association, Legislative Update (May 4, 2026): the July 1, 2026 NEMT date replaced with “upon implementation of the administrator.” https://mica.org/lu20260504
[60] Minnesota DHS, MHCP Provider Manual, “Latest Manual Revisions” (updated September 3, 2026): the July 31, 2026 entry adding the referring provider to NEMT claims and the July 1, 2026 fuel adjustment to the mileage codes. Read in full. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_137531
[61] State of Minnesota DHS solicitation 2000017848, “Administrative Services for NEMT,” as listed on bid aggregators: open January 15, 2026, closed February 12, 2026, projected award March 1, 2026. Read only in search results; the listings block automated readers. https://www.bidnetdirect.com/minnesota/solicitations/open-bids/statewide/DHS-Administrative-Services-for-NEMT/443832083700
[62] Minnesota DHS news release (July 15, 2026): the new-provider pause on 12 high-risk services extended at least another six months, with temporary commissioner John Connolly’s statement. https://content.govdelivery.com/accounts/MNDHS/bulletins/42084d2
[63] CBS News Minnesota, “Minnesota House panel: transportation Medicaid program at risk of fraud” (March 2, 2026): about 2,000 providers, 250,000 riders, $127 million in 2025, and the 64 percent drop in billed rides, as testified. https://www.cbsnews.com/minnesota/news/minnesota-house-panel-transportation-medicaid-program-risk-fraud/
[64] Minnesota DHS bulletin, “Off-cycle revalidation updates” (April 2, 2026): the 13 high-risk types, the May 31, 2026 deadline, termination for non-response. https://content.govdelivery.com/accounts/MNDHS/bulletins/4114945
[65] Minnesota DHS Provider Roundtable deck, “Minnesota Revalidate 2026: Site Visits and Background Studies” (February 17, 2026): what an unannounced site visit checks. https://content.govdelivery.com/attachments/MNDHS/2026/02/17/file_attachments/3556111/021226_ProviderRoundtable.pdf
[66] Minnesota DHS news release (June 4, 2026): Minnesota Revalidate results, 2,061 providers revalidated and 3,411 disenrollment notices. https://content.govdelivery.com/accounts/MNDHS/bulletins/41a6cae
[67] Georgetown University Center for Children and Families, “Revalidation of High-Risk Medicaid Providers: Early Lessons from Minnesota” (July 8, 2026): the breakdown of the 3,411 disenrollment notices. https://ccf.georgetown.edu/2026/07/08/revalidation-of-high-risk-medicaid-providers-early-lessons-from-minnesota/
[68] Acentra Health, Minnesota MHCP transportation page: level-of-service assessments, the DHS-6715 form, the January 1, 2026 turnaround times, contact numbers. https://mhcp.acentra.com/transportation/
[69] Minnesota DHS, MHCP Provider Manual, “State-Administered NEMT” (updated July 7, 2025): nursing facility residents’ automatic qualification for non-stretcher trips, the stretcher certification rule, vehicle marking, attendant billing. Read in full. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_141021
[70] Minnesota DHS, MHCP Payment and Claim Cut-off Calendars, DHS-3947J (February 2025): the two-week claim cycle, Thursday cut-offs, Wednesday EFT, remittances every other Friday. https://edocs.dhs.state.mn.us/lfserver/Public/DHS-3947J-ENG
[71] Minnesota DHS, MHCP Provider Manual, “Nonemergency Medical Transportation (NEMT) Services” overview (updated April 7, 2025): direct billing for state-administered modes, no MHCP billing for local-agency modes, the 837P format, mileage rounding, no-load and wait-time exclusions, the 30- and 60-mile limits. Read in full. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=id_008991
[72] Minnesota Rules 8840.5400: no special transportation service without a current certificate of compliance. https://www.revisor.mn.gov/rules/8840.5400/
[73] Minnesota House Research Department, bill summary of H.F. 36 as introduced (February 20, 2025): the “Proposed MA Payment Rate” table of $17, $22, and $31 bases against current rates of $12.10, $14.30, and $19.80. https://www.house.mn.gov/comm/docs/MKZaRLhiIEyWdHWaZZiz4Q.pdf
[74] Minnesota Revisor, H.F. 36 (2025) status in the House: introduced February 10, 2025, referred to Health Finance and Policy, no further action. https://www.revisor.mn.gov/bills/94/2025/0/HF/36/
[75] Minnesota DHS EVV Team, “Electronic Visit Verification (EVV)” provider training deck: EVV applies to certain personal care, waiver, and home health services under the 21st Century Cures Act. https://mn.gov/dhs/assets/electronic-visit-verification_tcm1053-546188.pdf
[76] Minnesota Rules 8840.5100: STS definitions, including “regular basis” and “grants or other financial assistance.” https://www.revisor.mn.gov/rules/8840.5100/
[77] Minnesota Rules 8840.6100: records, trip records, attendant files, and retention periods. https://www.revisor.mn.gov/rules/8840.6100/
[78] Minnesota Statutes 174.315: penalties of up to $10,000 for transporting a passenger who might reasonably require an ambulance, and revocation on a third violation in three years. https://www.revisor.mn.gov/statutes/cite/174.315
[79] City of Minneapolis, taxicab license application page (updated September 3, 2026): links to the medical transport vehicle license application. The 2026 fee schedule itself couldn’t be opened. https://www.minneapolismn.gov/business-services/licenses-permits-inspections/business-licenses/vehicles/taxis/taxicabs/application/
[80] Metropolitan Airports Commission, Ordinance 122, Commercial Vehicles (adopted October 17, 2016, effective January 1, 2017): permit and per-trip fees, the definition of commercial vehicle, and the small passenger vehicle restriction. https://metroairports.org/documents/ordinances/ordinance-122
[81] Minnesota Statutes 174.29: the definition of special transportation service, including taxis, and its incorporation of Medicaid NEMT. https://www.revisor.mn.gov/statutes/cite/174.29
[82] City of Saint Paul, Department of Safety and Inspections, business licenses and permits fee list (page dated August 31, 2026): taxicab driver $51, taxicab vehicle $469, and no medical transportation category. https://www.stpaul.gov/departments/safety-inspections/open-operate-expand-business/business-licenses-and-permits-1
[83] Minnesota Statutes 171.02, subdivision 2: the license classes, and the Class D limits of 26,000 pounds and 15 passengers including the driver. https://www.revisor.mn.gov/statutes/cite/171.02
[84] MnDOT, STS Driver’s License and Driving Records general information (June 2026): a CDL with passenger endorsement at 16 or more passengers including the driver. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=38907409
[85] MnDOT, STS Insurance fact sheet (June 2025): the $500,000 minimum, the Form E signed by the insurer, suspension and cancellation timing. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=36491510
[86] Amwins, Paratransit Program (page current May 26, 2026): NEMT and wheelchair vans, $1 million auto liability, admitted in Minnesota, minimum five units. https://www.amwins.com/products/paratransit-program-amwins
[87] Elite Med Financials, a medical-billing and marketing vendor, not an insurer, “NEMT insurance cost” guide (March 16, 2026): national premium bands by vehicle type and a 20 to 40 percent new-operator loading. Vendor-published, not Minnesota-specific. https://elitemedfinancials.com/nemt-insurance-cost/
[88] Minnesota Statutes 176.181: compulsory workers’ compensation insurance, the penalty of up to $1,000 per employee per week, and the gross misdemeanor. https://www.revisor.mn.gov/statutes/cite/176.181
[89] Minnesota Statutes 176.041, subdivision 1: the sole proprietor and LLC manager exclusions. https://www.revisor.mn.gov/statutes/cite/176.041
[90] Minnesota Statutes 181.722: misclassification of employees, the penalties, and the test. https://www.revisor.mn.gov/statutes/cite/181.722
[91] Minnesota Department of Employment and Economic Development, Paid Leave employer overview: the 0.88 percent premium, benefits from January 1, 2026, first premiums due April 30, 2026. https://mn.gov/deed/assets/paid-leave-in-person-employers_tcm1045-706805.pdf
[92] Unemployment Insurance Minnesota, Paid Leave small employer premium rate: 0.66 percent for employers with 30 or fewer employees. https://ui.mn.gov/employers/paid-leave/small-employer-premiums.jsp
[93] Minnesota Statutes 268B.14: Paid Leave premiums, the employer minimum share, the small-employer rate. https://www.revisor.mn.gov/statutes/cite/268B.14
[94] Minnesota Department of Labor and Industry, “New minimum-wage rates, changes to meal and rest break laws take effect Jan. 1, 2026” (December 17, 2025): $11.41, the training wage, the rest and meal break rules. https://www.dli.mn.gov/news/new-minimum-wage-rates-changes-meal-and-rest-break-laws-take-effect-jan-1-2026
[95] City of Minneapolis, minimum wage news (December 19, 2025): $16.37 for all employees from January 1, 2026. https://www.minneapolismn.gov/news/2025/december/minimum-wage/
[96] City of Saint Paul, Minimum Wage (page edited August 31, 2026): the size tiers, $14.25 for micro businesses from July 1, 2026. https://www.stpaul.gov/departments/human-rights-equal-economic-opportunity/labor-standards-enforcement-and-education/minimum-wage
[97] Minnesota Workers’ Compensation Assigned Risk Plan, rates effective January 1, 2026: class codes 7370, 7380, and 7382. https://www.mwcarp.org/_DOWNLOAD/2025-1234.pdf
[98] MnDOT, NETStudy 2.0 Background Studies general information for STS providers (October 2018, with the July 2025 fact sheet): who needs a study, the MnDOT number prerequisite, timing, the 180-day rule, and its outdated fee figures. https://www.dot.state.mn.us/cvo/sts/pdf/netstudy.pdf
[99] Minnesota Rules 8840.6200: MnDOT certification of training courses and instructors. https://www.revisor.mn.gov/rules/8840.6200/
[100] PrimeWest Health, Transportation Providers, Join PrimeWest Network: MnDOT certification, DHS enrollment, protected-transport training. https://www.primewest.org/join-our-network/eligible-providers/transportation
[101] Minnesota Statutes 299A.12, 299A.14, and 299A.17: wheelchair securement devices, inspection within a month of installation and annually, and the misdemeanor. https://www.revisor.mn.gov/statutes/cite/299A.14
[102] Minnesota Statutes 144E.001, subdivision 3: the definition of ambulance service, including the stretcher clause. https://www.revisor.mn.gov/statutes/cite/144E.001
[103] Minnesota Statutes 256B.0625 (2022 edition), subdivision 17: the pre-2024 rate table, showing which modes the 2023 increase raised. https://www.revisor.mn.gov/statutes/2022/cite/256B.0625
[104] Minnesota DHS form DHS-6715, MHCP Protected Transport Level-of-Service Assessment (rev. 6-25): crisis-team certification, single trip and single date. https://edocs.dhs.state.mn.us/lfserver/Public/DHS-6715-ENG
[105] Minnesota DHS, MHCP Provider Manual, “Protected Transportation Services” (updated April 18, 2025): the driver-plus-attendant rule and its emergency-department exception, the six-hour training options, hospital certification on DHS-6715, T2003 UA and S0215 UA billing. Read in full. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs-288176
[106] Minnesota DHS, MHCP Provider Manual, “Medical Transportation Enrollment Criteria and Forms”: the STS certificate and vehicle list as enrollment documents, the screening fee and site visit, the enrollment documents. The 30-day processing statement sits on the manual’s “Enrollment with Minnesota Health Care Programs” page (dDocName id_000090). Both quoted as they appear in search results; both pages block automated readers. https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=ENROLL-82
[107] Minnesota Statutes 256B.04, subdivisions 21 and 22: provider enrollment, the 60-day response window, revalidation, and the application fee. https://www.revisor.mn.gov/statutes/cite/256B.04
[108] Minnesota DHS form DHS-4611A, MHCP Individual Non-Pay-To Provider Agreement (rev. 1-22), the agreement a driver signs. https://edocs.dhs.state.mn.us/lfserver/Public/DHS-4611A-ENG
[109] MTM Health, Service Providers: how a transportation company applies to join MTM’s network. https://www.mtm-inc.net/service-providers/
[110] Mayo Clinic in Rochester, Community Health Needs Assessment 2025: 2024 hospital admissions and patient origin within and beyond 120 miles. https://static1.squarespace.com/static/644aa122716271579b019f2c/t/6942c8951cdbae5a164f1e1c/1765984405969/Rochester+CHNA+2025+Final+mc4776-05.pdf
[111] Minnesota Statutes 322C.0113 and 5.36: an LLC must have a registered office and may have a registered agent. https://www.revisor.mn.gov/statutes/cite/322C.0113
[112] Minnesota Statutes 333.01: assumed name certificates and newspaper publication in two successive issues. https://www.revisor.mn.gov/statutes/cite/333.01
[113] MnDOT, STS Vehicle Decal fact sheet (June 2025): $45 per decal, monthly invoicing, one-year validity. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=38907520
[114] Rollx Vans, Savage, Minnesota, used wheelchair vans for sale: listings and prices as seen September 10, 2026. https://www.rollxvans.com/used-handicap-vans-for-sale/
[115] MobilityWorks, Roseville, Minnesota, wheelchair vans for sale: listings and prices as seen September 10, 2026. https://www.mobilityworks.com/wheelchair-vans-for-sale/minnesota/
[116] MobilityWorks Commercial, 2026 Ford Transit wheelchair van: chassis and conversion pricing and rebates, promotion valid August 1 to September 30, 2026. https://commercial.mobilityworks.com/ford-transit-commercial-van/
[117] Minnesota Statutes 168.013, subdivision 1a: the registration tax formula and the cap for a used vehicle previously registered in Minnesota. https://www.revisor.mn.gov/statutes/cite/168.013
[118] Minnesota Statutes 297B.01, subdivision 14, and 297B.02: the 6.875 percent motor vehicle sales tax and the exclusion for accessibility modifications. https://www.revisor.mn.gov/statutes/cite/297B.01
[119] Minnesota Statutes 116M.18: the Minnesota Emerging Entrepreneur Program loan sizes, eligibility, matching, rate cap, and forgiveness. https://www.revisor.mn.gov/statutes/cite/116M.18
[120] African Development Center, Start a Business: microloans up to $50,000, business loans up to $350,000, vehicle and equipment financing, service area. https://www.adcminnesota.org/services-programs/start-business
[121] WomenVenture, Lending: loans up to $100,000, no application fee, the credit-score floor, eligibility. https://www.womenventure.org/services/lending/
[122] Minnesota Statutes 144E.33 and 609.03: a misdemeanor for violating the ambulance chapter, and the misdemeanor maximum. https://www.revisor.mn.gov/statutes/cite/144E.33
Last verified against the sources above in September 2026. Minnesota’s NEMT program is mid-transition: the metro enrollment freeze, the administrator procurement, and the rate table all carry dates that can move, and DHS’s website blocks most automated readers, so several of its statements are quoted from search results and marked as such. Confirm the primary sources directly before acting, and treat this guide as education, not legal advice.
About the author
James O'Donnell cofounded Duet and leads its sales, partnerships, and growth services. He talks with NEMT operators every week, hosts the NEMT Growth podcast, and answers Duet's sales line himself. More about Duet's founders →
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