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Starting & scaling →How to Start a NEMT Business in Texas (2026)
Texas retired its Medicaid transportation brokers in 2021 and handed the rides to health plans. Here's how to build a transportation company in a market where the vendor behind your contract can change on New Year's Day.
By James O'Donnell, Cofounder and COO, Duet ·
To start a NEMT business in Texas: form an LLC ($300), get a free EIN and Type 2 NPI, insure each van to roughly a $1 million combined single limit, enroll in Texas Medicaid through TMHP’s PEMS portal ($750 application fee for 2026), then credential with the transportation vendors serving your region’s health plans, mainly SafeRide Health, MTM Health, and Modivcare. There’s no Texas NEMT license, no statewide broker, and a typical wheelchair van needs no motor carrier authority. Stretcher trips are off the table without an EMS provider license. Plan on $15,000 to $45,000 and two to four months to first trips, with private-pay revenue arriving earlier.
Between April 2025 and this summer, at least five Texas Medicaid health plans changed the company that arranges their members’ rides. Community First in San Antonio moved to SafeRide Health on April 1, 2025 [16]. Texas Children’s Health Plan followed [14]. UnitedHealthcare’s Texas plans switched to SafeRide on January 1, 2026 [1]. Molina has been moving its members over during 2026. And on May 14, 2026, the Access2Care name retired from Texas Medicaid entirely, folded into MTM Health after an acquisition [19]. None of it came with a press conference. Each change was a provider notice, and every operator whose schedule leaned on the old contract found out overnight how much of that volume was borrowed.
If you’re starting a non-emergency medical transportation (NEMT) business in Texas, that churn is the market you’re walking into, and it’s the direct result of a structural decision most guides still haven’t caught up with: on June 1, 2021, Texas retired its regional transportation broker model and made NEMT the job of each Medicaid health plan [2][3]. There is no state broker to sign up with. There are health plans, the three vendors they hire, and a small state-run lane for the fee-for-service members left over. So the questions that matter here are which plans cover your counties, and which vendor each of them uses this year.
I run Duet, a dispatch software company, and I talk to NEMT operators every week, Texas included. This is the Texas edition of our national guide on how to start a NEMT business. It cites the actual Texas statutes, rules, and agency documents, and where something couldn’t be verified against a primary source, I say so. Requirements change, and the Texas vendor map has changed five times since spring 2025. Confirm against the linked sources before you spend money.
The scale you’re building against: about 4 million Texans were on Medicaid or CHIP as of spring 2026, per CMS’s monthly enrollment data [20], and more than nine in ten Medicaid members are in managed care plans [21], every one of which must arrange rides to covered appointments under Texas Government Code chapter 540A [2]. CMS counts 745 Medicare-certified dialysis facilities in Texas, 137 of them in Harris County alone [22]. And the Texas Demographic Center projects the 65-and-over population to grow from 3.9 million in 2020 to 6.8 million by 2040 [23]. In Texas, demand is the easy part. The order of operations is what this guide is for.
The one-page checklist: steps to start a NEMT business in Texas
Six phases, in order: know your demand, form the business, get the federal identifiers, set up vehicles, drivers, and insurance, enroll and credential, then build the trip sources you control.
Phase 0: know your demand
- Decide where your trips will come from: your county’s Medicaid health plans and their vendors, facility contracts, private-pay families, or the state’s fee-for-service lane. Healthy Texas operators usually run two or three at once.
- Map which plans serve your service area and which vendor each uses. The three-vendor map below is your starting point; verify every row before you build on it.
- Price a wheelchair trip with two local competitors. Houston rates aren’t Lubbock rates.
- Write the one-page business plan before the paperwork: your counties, payer mix, trip math per van, and the runway number from the cost table below. Every lender in the funding section asks for exactly that and nothing fancier.
Phase 1: business foundation
- Form your LLC with the Texas Secretary of State: $300 to file the certificate of formation [4]. There’s no annual report fee; below $2.65 million in revenue you owe no franchise tax and file only a free Public Information Report each year [5].
- Get a free EIN from the IRS. Never pay a third party for this [6].
- If you’ll operate under a trade name, the assumed name certificate is $25 with the Secretary of State [4].
- Ask your city what applies to your vans. No Texas city has an NEMT permit category by name, but the big-city vehicle-for-hire ordinances are ambiguous enough that one phone call beats one citation. More on this in the licensing section.
Phase 2: federal identifiers
- Apply for a Type 2 (organizational) NPI at NPPES. Free, usually issued within days. One Texas wrinkle: the state’s MTP manual lists provider specialty TS with taxonomy 343800000X for demand response providers, not the 343900000X code most national guides quote [3]. PEMS confirms the right pairing at enrollment.
- Check owners and drivers against the OIG exclusion list and SAM.gov, and recheck monthly. Every plan and vendor checks these too.
Phase 3: vehicles, drivers, and insurance
- Spec the van for the work: lift or ramp and four-point securement to the federal accessibility standard, which requires the system to hold an occupied wheelchair to no more than 2 inches of movement in any direction [24]. Vendor vehicle inspections check securement first.
- Build each driver’s file: license, MVR, background check, drug screen, and the training topics in Texas’s MTP driver rule (the full list is in the drivers section below) [12].
- No CDL below 16 passengers including the driver [11]. No state chauffeur license exists either; a regular Class C license covers a typical wheelchair van.
- Insure to the vendor bar, roughly $1 million combined single limit, not the personal-auto minimum. Get quotes before you buy anything; the insurance section has the real numbers.
Phase 4: enrollment, then credentialing
- Enroll in Texas Medicaid through TMHP’s PEMS portal. This comes first: TMHP requires Texas Medicaid enrollment before you can be approved for any managed care network [7]. The 2026 application fee is $750, waived if you’ve already paid it to Medicare or another state’s Medicaid program [8].
- Then credential with each transportation vendor serving your target plans: SafeRide’s provider application, MTM’s network form, Modivcare’s provider inquiry. Each is a separate queue, and MTM says outright that it only advances applications where it has network need [17][18].
Phase 5: the trip sources you control
- Set up a NEMT website and Google Business Profile around the trips from Phase 0.
- Start facility outreach and private pay the same week your PEMS application goes in, not after it’s approved. Enrollment buys you the right to bill. It doesn’t send you a single rider.
- Offer friends and family free or discounted rides in exchange for honest Google reviews. The first ten do more than any ad budget.
- Stand up dispatch and billing before the first vendor trip, not after. Vendors send trip files from day one, and reconciling them by hand is how new operators fall behind in week two.
Who pays for NEMT rides in Texas?
Four sources pay for NEMT rides in Texas: Medicaid health plans through their contracted transportation vendors, the state’s fee-for-service Medical Transportation Program, contracts with facilities like hospitals, dialysis clinics, and senior living communities, and private-pay families booking directly.
Medicaid is the volume, and in Texas that means the plans. Since June 1, 2021, every Medicaid managed care organization must arrange and provide nonemergency transportation for its members, a duty that now sits in Texas Government Code chapter 540A [2]. More than nine in ten of Texas’s roughly 4 million Medicaid and CHIP members are in managed care [20][21], across the STAR, STAR+PLUS, STAR Kids, and STAR Health programs [13]. STAR+PLUS, the program for adults with disabilities or age 65 and older, held roughly half a million members in CMS’s 2024 plan-level data [21], and that’s the population that rides most: the last time CMS counted NEMT-covered lives in Texas separately, in 2020, more than 4 million people had the benefit [21].
Facilities are the stability. Dialysis clinics run standing three-times-a-week schedules, and Texas has 745 Medicare-certified dialysis facilities: 137 in Harris County, 68 in Dallas County, 57 in Bexar, 53 in Tarrant [22]. Add hospital discharge desks, skilled nursing, and rehab, and one facility that trusts you can fill a van’s whole day, whatever the health plans do with their vendor contracts this year.
Private pay is the margin. Families booking a parent’s appointments directly, at rates you set against your own market. Secret-shop two local competitors before you print a rate card; published Texas rates swing hard between metros and the internet’s numbers aren’t your market’s.
One payer other guides keep listing that doesn’t belong here: Medicare. Original Medicare pays for ambulance transport and doesn’t cover routine NEMT, so there’s no Medicare NEMT enrollment to file, whatever a template checklist tells you. What does exist is Medicare Advantage: some plans offer rides as a supplemental benefit, and in Texas those trips run through the same vendor layer; Community First’s move to SafeRide covered its Medicare members alongside Medicaid [16]. Credential once and both come through the same door.
One honest caution on market size. Texas removed about 2 million people from Medicaid during the 2023 to 2025 unwinding, and its enrollment now sits roughly a third below the March 2023 peak [20][25]. The demand math above still works, and dialysis patients didn’t stop needing rides. But any guide quoting 5-plus million Texas Medicaid members is quoting a market that no longer exists. Same for the $500 million Texas NEMT market growing 6.5 percent a year that template guides cite: no dataset I can find produces either number, and most of the pages quoting the projection published after its window had already expired. The figures that survive a source check are the ones in this guide: CMS enrollment data, CMS facility counts, and the state demographer’s projections.
Who is the NEMT broker in Texas?
Texas has no statewide NEMT broker, and that’s the most important fact about this market. Since June 1, 2021, each Texas Medicaid health plan arranges rides for its own members through its contracted transportation vendor, and in 2026 that vendor layer comes down to three names: SafeRide Health, MTM Health, and Modivcare; HHSC’s fee-for-service Medical Transportation Program covers only the members not in managed care [2][3]. Half the articles online still tell you to sign up with the state’s broker. In Texas, that door closed in 2021.
What makes 2026 unusual is how far the vendor layer has consolidated. Here’s the plan-to-vendor map as I can verify it from the plans’ and vendors’ own pages in August 2026. Treat it as a starting point and confirm before you build on any single row:
- SafeRide Health has been the fastest-growing network: Superior HealthPlan, including the statewide STAR Health foster care plan, since June 1, 2021 [13][26]; UnitedHealthcare Community Plan since January 1, 2026 [1]; Texas Children’s Health Plan [14]; Driscoll Health Plan in South Texas [15]; Community First Health Plans in San Antonio since April 1, 2025 [16]; and Molina’s STAR and STAR+PLUS members transitioning during 2026, per Molina’s member materials.
- MTM Health holds the widest list, much of it the former Access2Care book it acquired: Wellpoint (formerly Amerigroup) [27], Community Health Choice in Houston [28], Cook Children’s Health Plan [29], Aetna Better Health [18], El Paso Health [30], Parkland Community Health Plan in Dallas [31], and Dell Children’s, per MTM’s own Texas client list [18]. The Access2Care brand retired for Texas Medicaid plans on May 14, 2026, with phone numbers and provider networks carried over [19].
- Modivcare runs rides for Blue Cross and Blue Shield of Texas’s STAR plan [32], the one Texas Medicaid book a plan’s own page confirms for it as of August 2026. Context worth knowing before you bet a schedule on any single contract: Modivcare, the largest broker in the country, went through Chapter 11 in 2025 and emerged that December as a private company [33].
Two currency notes. Baylor Scott & White and FirstCare, both MTM accounts, are leaving Texas Medicaid managed care with plan codes end-dated August 31, 2026, per an HHSC provider notice, so their members will reshuffle to other plans this fall. And these pairings genuinely move: five changed in the fourteen months before this guide published. Our national NEMT broker changes tracker follows the changes state by state; Texas’s version of the story is that the churn happens plan by plan, vendor by vendor, and the only warning is a provider notice.
Can I bill Texas Medicaid directly for NEMT?
You can bill Texas Medicaid directly only in the fee-for-service lane, and it’s a narrow one. HHSC’s Medical Transportation Program (MTP) arranges rides for the fee-for-service Medicaid members, plus CSHCN Services Program and Transportation for Indigent Cancer Patients clients, and MTP prior-authorizes every one of those trips; the TMHP manual is explicit that the MTP handbook does not apply to managed care [3]. Fewer than one in ten Texas Medicaid members sit in fee-for-service [21], so treat this lane as a supplement, not a foundation.
The mechanics, from the current MTP handbook [3]: you enroll with TMHP through PEMS as a Demand Response Transportation Service (DRTS) provider, the category covering taxi and wheelchair van work. Members book through the statewide MTP line at least 2 business days before the appointment, 5 for out-of-county trips, with same-week exceptions for discharges, prescriptions, and urgent care. Claims go to TMHP on procedure code T2003 with a 95-day filing deadline. Texas also runs two smaller lanes worth knowing about: registered individual transportation participants, who are reimbursed mileage for driving themselves or family members, and transportation network companies, which state law welcomed into NEMT in 2019 with drivers qualified under the TNC statute rather than Medicaid enrollment [2].
One wrinkle to settle by phone: HHSC materials also reference contracted full-risk brokers coordinating fee-for-service trips in the Dallas-Fort Worth and Houston/Beaumont areas, while the current TMHP handbook describes no broker step at all, and older guides route West Texas fee-for-service trips through a named regional contractor too. Before you count on fee-for-service volume in any of those regions, ask MTP directly how trips in your county are assigned. It costs you one call.
How much does Texas Medicaid pay for a NEMT trip?
What Texas Medicaid pays for a NEMT trip depends on the lane, and only one lane publishes a number. Fee-for-service demand response trips bill procedure code T2003 at TMHP’s published fee schedule rate, set through public rate hearings and most recently updated effective November 1, 2024; look up the current amount by procedure code on TMHP’s Online Fee Lookup before you build a budget on it [59]. Managed care has no published rate at all: each transportation vendor negotiates per-trip and per-mile rates into your contract, and two operators in the same county can carry different numbers. Private pay is whatever your market bears, which is why you price against two local competitors before printing a rate card. And the base-plus-mileage cards you’ll find online, $40 to $55 plus $2.00 to $3.50 a mile for wheelchair trips, cite no fee schedule anywhere, while any Texas rate card quoting stretcher prices is pricing a criminal offense.
What licenses and requirements does a NEMT business need in Texas?
Texas issues no NEMT license, and a typical wheelchair van needs no TxDMV motor carrier authority either: under Transportation Code chapter 643, registration is required only for vehicles meeting the commercial motor vehicle definition in section 548.001, which starts at more than 26,000 pounds or a vehicle designed or used to carry more than 15 passengers including the driver (plus household goods movers of any size, which is not this business) [9][10]. The real Texas NEMT requirements are Medicaid enrollment, vendor credentialing, and the local layer. That’s less state licensing than almost anywhere, and it means the internet gets Texas spectacularly wrong. The short version, against the sources:
| The claim you’ll read elsewhere | What Texas actually requires |
|---|---|
| “You must obtain a NEMT business license from the state of Texas” | No such license exists. TDLR’s program list has no NEMT category [34], and TMHP enrollment is an enrollment, not a license [7]. (Several websites will sell you help getting it anyway.) |
| “Texas requires NEMT providers to be licensed by the TxDOT” / “Your vehicles must comply with Texas Department of State Health Services regulations” | Wrong agency, both times. Motor carrier registration lives at TxDMV under Transportation Code chapter 643, and it only reaches vehicles over 26,000 pounds or designed for more than 15 passengers [9][10]. TxDOT licenses nothing here, and DSHS regulates EMS providers and their vehicles, not wheelchair vans [48]. |
| “There is a $599 fee with this application” / “The state NEMT provider registration fee is $599” | That’s the 2021 federal enrollment fee, fossilized in old guides; the federal screening fee resets every year, which is why every stale guide quotes a different number. The 2026 Texas Medicaid application fee is $750, and it’s waived if you already paid it to Medicare or another state [8]. |
| “Get your NEMT license by registering with the state’s Medical Transportation Program” | Two errors in one sentence. MTP enrollment is a Medicaid enrollment through TMHP’s PEMS portal, not a license [7], and MTP covers only the fee-for-service lane, fewer than one in ten members [21]. A guide routing you through MTP as the front door points you at the smallest lane in the market and skips the health plan vendors holding the volume. |
| “Your vehicles need TxDMV livery plates” | Texas has no livery plate class. That’s another state’s rule pasted into Texas content. Standard registration by weight applies [10]. |
| “Sign up with LogistiCare (or Modivcare), the state’s NEMT broker” | LogistiCare became Modivcare in 2021, and Modivcare isn’t Texas’s broker either: the one Texas Medicaid book a plan’s own page confirms in 2026 is Blue Cross and Blue Shield of Texas [32]. Texas hasn’t had a statewide broker since June 1, 2021; each health plan contracts its own vendor [2][3]. |
| “Dallas NEMT permits run $100 to $200 per vehicle, Houston $50 to $150, Austin $75 to $125” | Invented. No Texas city has an NEMT permit category, so no Texas city publishes an NEMT fee schedule. Houston’s Chapter 46 lists eight vehicle-for-hire categories and medical transport isn’t one [39]; Austin’s real published numbers are a $159 operating authority license and a roughly $36 chauffeur permit [40]. Call the for-hire office and get its answer in writing. |
| “Add stretcher vans as a premium service tier” / “Qualifying NEMT vehicles in Texas include stretcher vans” | Not in Texas. Transporting a patient by stretcher without an EMS provider license is a Class A misdemeanor under Health and Safety Code 773.041 and 773.064 [35]. The stretcher section below has the whole story. |
The motor carrier line, precisely
Texas draws its commercial motor vehicle line at more than 26,000 pounds gross weight or a vehicle designed or used to carry more than 15 passengers including the driver [9]. Below both thresholds, intrastate, there’s no TxDMV number, no USDOT number requirement, and no state operating authority [10]. Cross either line and the whole apparatus arrives at once: TxDMV registration built on an intrastate USDOT number, an insurance filing from your carrier, and the adopted federal safety rules [10][36]. A 16-plus passenger shuttle is a different regulatory animal from a six-passenger wheelchair van, so decide what you’re buying before you buy it.
Two federal edges even small vans can hit. Interstate is its own regime: cross a state line for compensation in a vehicle designed or used for 9 or more passengers, or over 10,001 pounds, and you’re a federal commercial motor vehicle with FMCSA registration and, for-hire, a $1.5 million liability floor [36][37]. That matters in El Paso and Texarkana and almost nowhere else in Texas NEMT. And on bigger platforms, read the door-jamb GVWR sticker rather than the model name: many heavier cutaway builds cross 10,001 pounds, which changes nothing intrastate in Texas but makes any interstate trip federally regulated [36].
On inspections: since January 1, 2025, Texas dropped the annual safety inspection for non-commercial vehicles, replacing it with a $7.50 registration fee, and the commercial inspection program keys to the same over-26,000-pound definition [38]. For-hire status alone doesn’t move that line; the surviving inspection follows the vehicle definition, not how the van earns. A typical NEMT van’s only test is emissions, in the seventeen metro counties that require it, with Bexar County added in 2026 [38]. Confirm your county with your inspection station.
What are the NEMT vehicle requirements in Texas?
Texas publishes no vehicle certification list for NEMT, but it does have a codified equipment standard: 1 TAC 380.501, the Medical Transportation Program’s motor vehicle rule, and vendor inspections track it plus their own lists [58]. The rule’s requirements, since the official rule viewer is hostile to automated readers:
- Company name and vehicle number on the vehicle in letters at least six inches high
- Functioning, clean, accessible seat belts at every passenger position
- Two exterior rear view mirrors plus an interior mirror
- Working interior lights, heating, cooling, and ventilation
- Adequate sidewall padding and ceiling covering, clean inside and out
- Working speedometer and odometer
- A functional fire extinguisher, secured within the driver’s reach and visible to passengers
- A first aid kit including latex gloves, hazardous waste bags, scrub brush, disinfectant, and deodorizer
- Three posted signs: no smoking, eating or drinking; all passengers must wear seat belts; concealed weapons prohibited
Add the federal securement standard from the checklist, a lift or ramp with four-point securement that holds an occupied wheelchair to no more than 2 inches of movement in any direction [24], and your van is specced for any vendor inspection in the state.
The local layer: no NEMT category, so make the calls
Here’s what surprised me researching this: not one of Texas’s six biggest cities has an NEMT or wheelchair-van permit category by name. Houston’s Chapter 46 vehicle-for-hire ordinance enumerates eight categories, none of them medical transport [39]. Dallas’s Chapter 47A, San Antonio’s Chapter 33, Fort Worth’s Chapter 34, and El Paso’s transportation-for-hire code all regulate for-hire vehicles in general terms that never mention NEMT, and whether a wheelchair van falls inside them is genuinely unsettled city by city. Austin is the closest call: it licenses vehicle-for-hire operating authority at $159 [40], and separately runs a medical transfer franchise regime that in practice covers private ambulance companies, staffed by EMTs, not wheelchair vans [41].
So skip the fee tables you’ll find online for Texas cities; the precise ones are invented, and so is the $1,000-to-$3,000 “licensing and permits” line in template budgets, a budget for fees no Texas agency charges a wheelchair van operator. Some guides state flatly that Dallas providers must register with the city’s transportation regulation office; Chapter 47A never names medical transport, which is exactly why you get the city’s answer about your vans in writing instead of trusting a template guide, or this one. And if you see “COPCN barriers” attributed to Dallas or Fort Worth, that’s ambulance-franchise territory, the same licensed-EMS line the stretcher section draws; a wheelchair van asks the for-hire office, not the EMS office. The honest advice: before your first trip, call the vehicle-for-hire office in each city you’ll serve, describe your vehicles and service exactly, and get the answer in writing. Houston’s Administration and Regulatory Affairs department, Dallas’s Transportation Regulation Division, San Antonio’s police Ground Transportation Unit, Austin’s Transportation and Public Works at 512-974-7857. Budget a week of phone calls. It’s the cheapest insurance in this guide.
What are the NEMT insurance requirements in Texas?
For a Texas NEMT company, plan on roughly $1 million combined single limit commercial auto plus $1 million per occurrence and $2 million aggregate general liability: the bar the transportation vendors and facility contracts actually set, not anything in Texas law. SafeRide Health, now the vendor behind the biggest block of Texas Medicaid plans, publishes its floor: $1 million general liability per occurrence, $2 million aggregate, minimum $500,000 auto liability, with SafeRide as additional insured on the certificate [17]. MTM publishes a $1 million combined single limit for general and auto liability on its state provider pages, with MTM as certificate holder and additional insured [42]. Modivcare publishes no figure; roughly $1 million combined single limit is commonly reported, so get the real number from provider relations before you bind a policy. A policy at $1 million combined single limit clears every published Texas bar with room. One line item you can strike: professional liability, which some guides list as required for NEMT. Neither vendor requirement sheet cited here asks for it [17][42], and a non-medical transport service has no professional act to insure. Ask your agent, and don’t let a template sell you a policy no contract demands.
Now the part that makes Texas strange: for a typical NEMT van, there is no state insurance floor above ordinary personal-auto minimums. The passenger rows of the TxDMV filing table in 43 TAC 218.16 start at vehicles designed or used for more than 15 passengers ($500,000) and run to $5 million at 27 or more [43], and the table only applies to carriers required to register at all. Below those thresholds, the only law on the books is the 30/60/25 minimum every Texas driver carries, which the Department of Insurance itself warns may be too low for a multi-car accident [44]. So when a guide tells you “Texas law requires $500,000 for NEMT,” it’s quoting a table that doesn’t apply to your van, and when it tells you 30/60/25 is fine, it’s quoting a law no broker, facility, or plaintiff’s lawyer will accept. The vendor bar is the real number. Buy to it.
What that costs: one Texas-quoting agency’s December 2025 guide puts standard vehicles around $6,000 to $10,000 a year and wheelchair vans around $8,000 to $15,000, with first-year operators toward the top of the band [45]. Those are published agency ranges, not filed rates, so treat them as the shape of the market and get your own quotes from an agent who places medical transport risks every week, before you commit to a vehicle.
And one genuinely Texan wrinkle: workers’ compensation is elective here. Texas doesn’t require most private employers to carry it [46], famously the only state that leaves it broadly optional. Before you celebrate the savings, read the fine print: a non-subscriber must file annual notices with the state, post and give written notice to employees, and, if sued by an injured worker, loses the classic defenses; you can’t argue the employee’s own negligence, a coworker’s negligence, or that they knew the risk [46]. Many vendor contracts require workers’ comp or occupational accident coverage anyway. Price both paths with your agent instead of assuming bare is cheaper.
What do NEMT drivers need in Texas?
NEMT drivers in Texas don’t need a CDL, not for a typical wheelchair van. Texas adopts the federal thresholds through Transportation Code section 522.003: a commercial license starts at vehicles designed for 16 or more passengers including the driver, or over 26,001 pounds [11]. Mind the label trap: a “15-passenger van” seats 15 plus the driver, which is 16, which is CDL territory. Below the line, an ordinary Class C license drives the van, and there’s no state chauffeur license on top; where a for-hire driver permit exists at all it’s municipal, like Austin’s roughly $36 chauffeur permit [40].
What your drivers actually need is the file your vendors and the state’s MTP rule expect. Texas’s own driver standard for Medicaid transportation, 1 TAC 380.502, requires a valid driver’s license, a DPS driving record check, and a criminal history clean of the listed disqualifiers, including any DWI within seven years and more than one moving violation in twelve months [12].
What driver training does Texas actually require?
Start with the certification question, because it has a short answer: Texas has no state NEMT certification, for companies or for drivers. What it has is the training-topics list in 1 TAC 380.502, the MTP driver rule, and since the official rule viewer is hostile to automated readers, here’s the full list [12]:
- Passenger safety (annually)
- Passenger assistance (annually)
- Assistive devices, including wheelchair lifts, tie-downs, and child safety seats (annually)
- Non-discrimination, sensitivity, and diversity
- Customer service
- Defensive driving (every 2 years)
- Prohibited behaviors, including offensive language, tobacco, alcohol, drugs, and sexual harassment
- Whatever additional training HHSC decides is necessary (the rule keeps a catch-all)
Notice what’s not on it: CPR, first aid, and PASS (CTAA’s Passenger Assistance Safety and Sensitivity course). Those come from the vendors, contractually; MTM, for instance, describes CPR certification, ADA education, HIPAA training, drug testing, and multi-level background checks across its network [42]. Also not in any Texas rule: the “21 years old with a 3-year clean license” requirement you’ll see presented as state law. It’s a common vendor contract term, and the only age minimum actually written into Texas transportation statute is 18, on the rideshare pathway [2]. The “finish your state-mandated training within 30 days of hire” deadline circulating online is the same species: the rule sets topics and refresh cadences, not an onboarding clock, and where a 30-day window exists it’s your vendor contract talking [12]. Build your driver files to the strictest vendor you want to join, and you’ll clear the rest. Two more items for the file while you’re at it: a signed HIPAA training acknowledgment, because vendor contracts make you a business associate handling member health information [42], and printouts from the Texas Employee Misconduct Registry and the national sex offender site, screens vendor audits ask about and the rideshare statute already writes into its own lane [2].
Do Texas NEMT drivers need PASS or NEMTAC certification?
Not by law. No Texas statute or rule requires PASS or NEMTAC certification for NEMT drivers: the state’s list is the 1 TAC 380.502 topics above, and PASS isn’t on it [12]. What makes PASS, and sometimes NEMTAC’s transport specialist credential, feel mandatory is vendor contracts: securement, first aid, CPR, and passenger assistance training run through the big networks’ credentialing [17][42], and a PASS card is the standard way drivers evidence the passenger assistance piece. Build to the strictest vendor you want to join and the certification question answers itself.
One more thing you don’t need: federal drug-and-alcohol testing programs only attach to CDL drivers [47]. Vendors require testing by contract, so you’ll do it anyway, but it’s their rule, not FMCSA’s, for a standard van.
Can a NEMT company run stretcher van trips in Texas?
No. This is the answer Texas gets wrong most often online, so here it is with the statute attached: under Health and Safety Code section 773.041(a-1), “a person may not transport a patient by stretcher in a vehicle unless the person holds a license as an emergency medical services provider” [35]. DSHS rules close the loop: licensed providers must assure that all stretcher patients ride in a department-authorized EMS vehicle [48], and the authorized levels run from basic life support ambulance up; there is no stretcher-van category. Texas has no invalid-car or ambulette lane. If the rider can’t sit, it’s ambulance work, full stop.
The consequences are not theoretical. Unlicensed stretcher transport is a Class A misdemeanor [35], and DSHS can stack administrative penalties up to $7,500 per violation, per day [35]. On the billing side, Texas Medicaid’s NEMT benefit simply has no stretcher mode: the MTP handbook covers wheelchair vans and taxis and never mentions stretchers, while bed-confined members are covered as nonemergency ambulance transport, billed by DSHS-licensed, Medicare-enrolled ambulance providers with prior authorization the requesting physician or facility submits [3][49]. So when a national guide tells you to “add stretcher vans as a premium tier” and quotes per-mile stretcher rates for Texas, it’s pricing a service that would be a criminal offense for you to run. In Texas the stretcher question isn’t a pricing decision. It’s a licensing decision: either build a licensed EMS operation, a different business with a $500 provider application, $180 per vehicle, and medical staffing rules [48], or build your service line for wheelchair and ambulatory riders and refer stretcher requests to a licensed partner.
The contrast with other states is sharp enough to plan around. Georgia lets a non-ambulance invalid car carry stable stretcher patients; California runs a litter van category with a driver-and-attendant crew. Texas allows neither. An operator moving here from either state should assume their stretcher playbook is illegal until a lawyer says otherwise, and put the wheelchair-only line in their dispatch protocols in writing.
How do you become a Texas Medicaid NEMT provider?
Becoming a Medicaid transportation provider in Texas is a two-step: enroll with the state through TMHP’s PEMS portal first, then credential separately with each transportation vendor whose plans you want to serve. The order matters, because TMHP requires Texas Medicaid enrollment before you can be approved for any managed care network, and a missed revalidation later (the cycle runs three to five years, most providers at five) disenrolls you from every plan at once [7].
Step one: Texas Medicaid enrollment through PEMS
Everything runs through PEMS at tmhp.com: the application, the disclosure-of-ownership forms, the provider agreement, and the fee [3][7]. The 2026 application fee is $750, set federally and adjusted most years, and it’s waived if you’ve already paid it to Medicare or another state’s Medicaid or CHIP program, with proof of that payment attached to the application [8]. Claim the waiver without the proof and you’ve created exactly the kind of deficiency that adds 100 days. You’ll also read that enrollment takes a $50,000 surety bond per location; TMHP’s enrollment manual and the MTP handbook list no such bond for transportation providers, and PEMS tells you at application exactly what it wants, so let the portal set your checklist, not a blog [3][7]. TMHP’s published expectation is that processing typically takes up to 60 days once it has everything it needs, and that last clause is the trap: the clock starts when your application is complete, and TMHP reports that applications with deficiencies take about 100 days longer [7][50]. The backlog is real. A 2025 legislative review found nearly 9,000 Texas Medicaid provider applications processing for more than 60 days as of December 2024 [50], and TMHP has been running rolling revalidation extensions since late 2025 to work it down. You can’t speed up the queue. You can refuse to join the slow lane: complete application, every document, first submission.
Step two: credentialing with the vendors
Once enrollment is in motion, work the vendor layer for your counties: SafeRide’s provider application collects your NPI, EIN, Medicaid ID, fleet details, and insurance certificates to its published limits, and its network standards include full background checks, MVR, drug screening, first aid, CPR, defensive driving, and wheelchair securement training for drivers [17]. MTM takes applications through its network portal and tells you plainly that it moves forward where it has need in your area and keeps your file otherwise [18]. Modivcare runs an inquiry form and assigns a partner relationship manager [51]. None publishes a credentialing timeline, and the week-by-week onboarding windows quoted elsewhere trace to no vendor page I could find; operators report weeks to months, and need-gating means a fully qualified company can still be told its county is full.
Which brings up the catch-22 every new Texas operator hits: vendors like operating history, and you can’t build operating history on trips they haven’t given you. The answer is the payer that doesn’t need permission: private pay and facility work first, Medicaid volume layered on as credentials land. Our guides on winning facility contracts, getting your first trip from a facility meeting, and private pay are the playbook for those first months.
Don’t build the whole Texas schedule on one payer
Everything above gets you into Texas Medicaid work. Here’s what the last fourteen months should pin to every Texas business plan: in this state, broker volume is borrowed volume, plan by plan, and five plans have traded vendors since spring 2025. If your whole schedule rode on an Access2Care contract in Dallas or an MTM contract in San Antonio, there was a morning in the last two years when your business changed hands without your signature on anything. The operators who shrugged through it were the ones with facility contracts and private-pay customers no vendor swap could touch.
Texas actually makes diversification easier than most states. The three-vendor consolidation means one SafeRide credential now reaches a half-dozen plans, MTM’s network reaches another half-dozen, and a Modivcare contract adds Blue Cross. Add two dialysis clinics and a private-pay pipeline from your website and Google Business Profile, and no single provider notice can sink the schedule. Georgia operators learned this the hard way when the whole state flipped to one broker in April 2026; California operators live the plan-by-plan version like Texas, just with dozens of vendors instead of three.
However you mix payers, don’t run the vendors’ trips in one system and your own in a legal pad. Dispatch software like Duet that pulls broker trip files in alongside facility and private-pay work keeps one schedule, one driver app, and one billing trail across all of it.
How much does it cost to start a NEMT business in Texas?
Plan on $15,000 to $45,000 to put the first wheelchair van on the road legally in Texas, dominated by the vehicle and the insurance. The line items, from the sections above:
| Line item | What it costs |
|---|---|
| LLC formation | $300; assumed name certificate $25 if you want one [4] |
| Franchise tax and annual report | $0 below $2.65 million revenue; the annual Public Information Report is free [5] |
| EIN and NPI | Free; never pay a third party [6] |
| State NEMT license | $0. It doesn’t exist [34] |
| TxDMV motor carrier authority | $0 for a typical van; only vehicles over 26,000 lbs or 16-plus passengers register [9][10] |
| State safety inspection | $0 for a typical van since 2025; emissions testing only, in the metro counties that require it [38] |
| Medicaid (PEMS) application fee | $750 for 2026; waived if already paid to Medicare or another state [8] |
| Commercial auto insurance | Roughly $8,000 to $15,000 a year per wheelchair van from Texas-quoting agencies; standard vehicles $6,000 to $10,000 [45] |
| Used wheelchair van | Commonly $20,000 to $35,000 on the mobility marketplaces, plus 6.25% motor vehicle sales tax [52] |
| City permits | Likely $0 to a few hundred dollars, but unsettled: no Texas city has an NEMT category, so call your city’s for-hire office and get its answer in writing |
| Working capital | 3 to 6 months of expenses; vendor payments and facility checks both take weeks to arrive |
Anyone quoting a $5,000 Texas launch hasn’t priced Texas commercial auto, and anyone quoting $50,000 to $150,000 is reciting a template: that range circulates through AI-generated state guides with no source behind it, alongside the same guides’ 15 to 20 percent profit margins, 12 to 18 month break-evens, and $50,000-to-$60,000-per-van owner incomes, numbers nobody can trace to a rate sheet, a payer mix, or a single real operator. Your economics are your payer mix. One more Texas-specific note for the model: fares for transporting people aren’t on the Comptroller’s list of taxable services, so you won’t collect sales tax on trips [53], and the “Texas seller’s permit” step on some checklists dies with that fact: no taxable service, no permit. Texas has no state income tax on your profits either.
How do you fund a NEMT startup in Texas?
If the savings account doesn’t cover it: SBA 7(a) loans and microloans finance vehicles and working capital [54], and Texas has an unusually deep bench of community lenders. LiftFund, the San Antonio-born nonprofit CDFI, lends to borrowers banks decline and lists vehicles among its loan uses [55]; PeopleFund does the same from Austin [56]; the Texas Small Business Credit Initiative backs loan guarantees through participating banks [57]; and the Texas SBDC network advises for free. On the “grants and subsidies for healthcare businesses” the template guides list as a funding option: I looked, and I couldn’t find a Texas grant program a NEMT startup can apply to for vans or working capital. Budget as if grant money is zero; the community lenders above are the real version of that promise. And none of it speeds up PEMS or a vendor’s need review, so borrow against the timeline you actually face.
How long does it take to start a NEMT business in Texas?
Plan on two to four months in Texas from first paperwork to first Medicaid trips, with PEMS enrollment and vendor credentialing as the two slowest steps, and private-pay revenue available months earlier. A realistic sequence:
- Weeks 1-2. LLC ($300), EIN, NPI. Map your counties’ plans and vendors, and make the city vehicle-for-hire calls. Price trips with two local competitors.
- Weeks 2-4. Insurance quotes at the vendor bar from an NEMT-savvy agent. Pick the van after you know the premium.
- Weeks 3-6. Buy the van, used and mechanically sound, equip it to the securement standard, and build driver files to your strictest target vendor. Submit the PEMS application complete, with the fee, the first time.
- Months 2-4. While TMHP processes: vendor applications to SafeRide, MTM, and Modivcare for your counties, plus website, Google Business Profile, facility visits, and a private-pay rate card. This is revenue that doesn’t wait on a queue in Austin.
- First trips. However they arrive, run them flawlessly and ask for the review. The second trip comes from the first one.
Budget per the cost table above, and keep 3 to 6 months of expenses in reserve: the PEMS backlog is real, vendor credentialing is need-gated, and facility checks take weeks. The operators who fail in Texas mostly fail for one reason: the runway ran out before the queues cleared.
Texas NEMT FAQ
Does Texas require a NEMT license?
No. Texas issues no NEMT license or certification [34], and a typical wheelchair van needs no TxDMV motor carrier authority either, because that only starts at vehicles over 26,000 pounds or designed or used for more than 15 passengers [9][10]. What you actually need is Texas Medicaid enrollment through TMHP’s PEMS portal [7], credentialing with each health plan’s transportation vendor, and whatever your city’s vehicle-for-hire office says applies to your vans.
Who is the NEMT broker in Texas?
Nobody is, statewide. Since June 1, 2021, each Texas Medicaid health plan arranges rides for its own members through its contracted vendor [2][3]. In 2026 that vendor layer has consolidated to three names: SafeRide Health (Superior, UnitedHealthcare, Texas Children’s, Driscoll, Community First, with Molina moving over) [1][13][14][15][16], MTM Health (Wellpoint, Community Health Choice, Cook Children’s, Aetna, El Paso Health, Parkland, and the former Access2Care accounts) [18][19], and Modivcare (Blue Cross and Blue Shield of Texas) [32]. Verify your region’s pairings before you build on any of them.
Is LogistiCare or Access2Care still a NEMT broker in Texas?
No. LogistiCare became Modivcare in 2021, and in Texas Medicaid its confirmed 2026 book is Blue Cross and Blue Shield of Texas [32]. Access2Care was acquired by MTM Health, and the Access2Care name retired for Texas Medicaid plans on May 14, 2026 [19]. Guides that route you to either name are running on a pre-2021 map.
How much does it cost to start a NEMT business in Texas?
Plan on $15,000 to $45,000 to put the first wheelchair van on the road legally, dominated by the van and the insurance: the LLC is $300 [4], the Medicaid application fee is $750 for 2026 [8], commercial auto runs roughly $8,000 to $15,000 a year per wheelchair van [45], and there’s no state NEMT license fee because no such license exists [34]. The $50,000 to $150,000 range circulating online is template content with no source behind it.
What insurance does a NEMT business need in Texas?
For a Texas NEMT company, plan on roughly $1 million combined single limit commercial auto plus $1 million per occurrence and $2 million aggregate general liability: the bar the transportation vendors set, not anything in Texas law. SafeRide publishes a $500,000 auto minimum with $1 million/$2 million general liability [17], and MTM a $1 million combined single limit [42]. For a typical van there’s no state floor above the 30/60/25 every Texas driver carries [43][44], so the vendor bar is the real number. Buy to it.
Can I bill Texas Medicaid directly for NEMT rides?
Only in the fee-for-service lane, which covers fewer than one in ten members [21]. HHSC’s Medical Transportation Program arranges and prior-authorizes those trips, and you serve them by enrolling with TMHP through PEMS as a demand response transportation service provider [3]. The rest are in managed care, where you get paid by each health plan’s transportation vendor, not the state.
How long does Texas Medicaid NEMT enrollment take?
TMHP says the process typically takes up to 60 days once your application is complete [7], but HHSC told the Texas Legislature it had nearly 9,000 Medicaid provider applications stuck past 60 days as of December 2024 [50], and TMHP reports applications with deficiencies take about 100 days longer. Then each transportation vendor’s credentialing runs its own queue on top. Plan on two to four months end to end and submit a clean application the first time.
Do NEMT drivers need a CDL in Texas?
Not for a typical wheelchair van. Texas adopts the federal CDL thresholds: a commercial license starts at vehicles designed for 16 or more passengers including the driver, or over 26,001 pounds [11]. Careful with the ‘15-passenger van’ label, because 15 passengers plus a driver is 16 and does require a CDL. Plan instead for the driver file your vendors require: background checks, MVR, drug screens, and the training topics in Texas’s MTP rule [12].
What vehicles qualify for NEMT in Texas?
Texas publishes no NEMT vehicle certification list. A wheelchair van qualifies when it meets the MTP vehicle rule’s equipment standard (seat belts at every position, mirrors, fire extinguisher, first aid kit, working climate control, company name and vehicle number in six-inch letters, posted signs) [58] plus the federal securement standard: a lift or ramp with four-point securement that holds an occupied wheelchair to no more than 2 inches of movement [24]. Standard four-door vehicles work for ambulatory riders. Stretcher vans don’t qualify at all: transporting a patient by stretcher without an EMS provider license is a Class A misdemeanor [35], whatever a national template says.
Are stretcher van trips allowed in Texas?
No, not without an EMS provider license. Texas Health and Safety Code 773.041 says a person may not transport a patient by stretcher in a vehicle unless licensed as an emergency medical services provider [35], and DSHS rules require stretcher patients to ride in an authorized EMS vehicle [48]. Unlicensed stretcher transport is a Class A misdemeanor [35]. Wheelchair and ambulatory trips are fine; the moment a rider needs to lie down, it’s ambulance work.
Is the Texas NEMT market worth entering in 2026?
The demand math is strong: about 4 million Texans on Medicaid or CHIP in CMS’s spring 2026 enrollment data [20], 745 Medicare-certified dialysis facilities in CMS’s count with 137 in Harris County alone [22], and a 65-and-over population the Texas Demographic Center projects to grow from 3.9 million in 2020 to 6.8 million by 2040 [23]. The cautions are real too: enrollment shrank by about a third during the 2023 to 2025 unwinding [20][25], and broker volume moves plan by plan. Enter with trip sources you control.
Key official sources
[1] UnitedHealthcare provider news: SafeRide Health manages UnitedHealthcare Community Plan of Texas NEMT effective January 1, 2026. https://www.uhcprovider.com/en/resource-library/news/2025/tx-medicaid-nemt-transportation-vendor.html
[2] H.B. 1576 (86th Legislature, 2019), enrolled text (the managed care NEMT carve-in and TNC provisions); Texas Government Code § 540A.0101 (current MCO duty to arrange and provide nonemergency transportation). https://capitol.texas.gov/tlodocs/86R/billtext/html/HB01576F.HTM and https://codes.findlaw.com/tx/government-code/gov-t-sect-540a-0101/
[3] TMHP, Texas Medicaid Provider Procedures Manual: Medical Transportation Program Handbook (July 2026): the FFS/managed-care split, DRTS and TNC provider types, booking rules, T2003 billing, taxonomy table. https://www.tmhp.com/sites/default/files/file-library/resources/provider-manuals/tmppm/pdf-chapters/2026/2026-07-july/2_14_med_transport_program.pdf
[4] Texas Secretary of State, certificate of formation instructions ($300) and assumed name certificate ($25). https://www.sos.state.tx.us/corp/instructions/205.shtml and https://www.sos.state.tx.us/corp/instructions/503.shtml
[5] Texas Comptroller, franchise tax: 2026 no-tax-due threshold $2,650,000; Public Information Report filing. https://comptroller.texas.gov/taxes/franchise/
[6] IRS, employer identification number (free; the IRS warns against paid EIN sites). https://www.irs.gov/businesses/small-businesses-self-employed/get-an-employer-identification-number
[7] TMHP, Texas Medicaid Provider Procedures Manual Vol. 1, Section 1: Provider Enrollment (March 2026): enrollment before managed care participation, 60-day processing expectation, revalidation and disenrollment rules. https://www.tmhp.com/sites/default/files/file-library/resources/provider-manuals/tmppm/pdf-chapters/2026/2026-03-march/1_01_provider_enrollment.pdf
[8] TMHP news, December 19, 2025: 2026 provider enrollment application fee set at $750; exemption for fees already paid to Medicare or another state. https://www.tmhp.com/news/2025-12-19-2026-provider-enrollment-application-fee-set-750
[9] Texas Transportation Code § 548.001 (commercial motor vehicle definition) and chapter 643 (motor carrier registration). https://statutes.capitol.texas.gov/Docs/TN/htm/TN.548.htm and https://statutes.capitol.texas.gov/Docs/TN/htm/TN.643.htm
[10] TxDMV, TxDMV Number and motor carrier registration criteria; Motor Carrier Handbook (May 2025). https://www.txdmv.gov/motor-carriers/txdmv-number and https://www.txdmv.gov/sites/default/files/body-files/Motor_Carrier_Handbook.pdf
[11] Texas Transportation Code § 522.003 (adopting the federal CDL definition at 49 CFR 383.5); Texas DPS, commercial driver license classifications. https://statutes.capitol.texas.gov/Docs/TN/htm/TN.522.htm and https://www.dps.texas.gov/section/driver-license/how-do-i-apply-commercial-driver-license
[12] 1 Texas Administrative Code § 380.502, Medical Transportation Program standards for motor vehicle operators (driver file and training topics; unofficial mirror, since the official SOS TAC viewer blocks automated readers). https://txrules.elaws.us/rule/title1_chapter380_sec.380.502
[13] Superior HealthPlan, Medical Ride Program (SafeRide; STAR, STAR Health, STAR Kids, STAR+PLUS). https://www.superiorhealthplan.com/members/medicaid/resources/transportation.html
[14] Texas Children’s Health Plan, transportation assistance (SafeRide Health). https://www.texaschildrenshealthplan.org/benefits/transportation-assistance
[15] Driscoll Health Plan, transportation (SafeRide Health partnership). https://driscollhealthplan.com/services/transportation/
[16] Community First Health Plans, SafeRide Health transition effective April 1, 2025. https://medicaid.communityfirsthealthplans.com/2025/03/12/new-saferide-health-to-provide-transportation-services-for-community-first-medicaid-and-medicare-members-beginning-april-1-2/
[17] SafeRide Health, what to expect as a NEMT provider (application, insurance minimums, driver credentialing, performance standards). https://www.saferidehealth.com/what-to-expect-nemt-provider
[18] MTM Health, Texas client list and join-our-network pages (need-gated onboarding). https://www.mtm-inc.net/texas/ and https://www.mtm-inc.net/service-providers/
[19] MTM Health, completion of the Access2Care acquisition from Global Medical Response, and the Access2Care brand transition for Texas Medicaid plans (May 14, 2026). https://www.mtm-inc.net/mtm-finalizes-acquisition-of-access2care-expanding-market-leadership-in-nemt-sector/ and https://www.mtm-inc.net/mtm-link-a2c-intro/
[20] CMS, State Medicaid and CHIP Applications, Eligibility Determinations, and Enrollment Data (Texas rows; April 2026 preliminary and March 2023 peak). https://data.medicaid.gov/dataset/6165f45b-ca93-5bb5-9d06-db29c692a360
[21] CMS, Managed Care Enrollment by Program and Population, and by Program and Plan (Texas, 2024 report year; 2020 transportation-covered lives). https://data.medicaid.gov/dataset/e2ce0d2f-07c5-5213-947a-31e19bc649f6
[22] CMS Provider Data Catalog, Dialysis Facility listing (Texas counts as of the June 2026 data refresh). https://data.cms.gov/provider-data/dataset/23ew-n7w9
[23] Texas Demographic Center, Vintage 2024 population projections (65+ growth, October 2025 projections briefing). https://demographics.texas.gov/Resources/TDC/Presentations/29f2de6b-4625-4620-aa9e-2e14ab1fd139/20251022_TDCProjectionWebinar.pdf
[24] 49 CFR § 38.23, mobility aid accessibility: lifts, ramps, and securement (2-inch movement limit, 30-by-48-inch clear floor area). https://www.law.cornell.edu/cfr/text/49/38.23
[25] Texans Care for Children, review of the Texas Medicaid unwinding (citing HHSC’s end-of-continuous-enrollment dashboard). https://txchildren.org/looking-back-on-medicaid-unwinding-in-texas-and-forward-to-strategies-for-a-more-effective-enrollment-system-for-families/
[26] SafeRide Health, Texas (supporting Texas Medicaid NEMT beginning June 1, 2021). https://www.saferidehealth.com/texas
[27] Wellpoint Texas, Medicaid transportation benefits (MTM Health). https://www.wellpoint.com/tx/medicaid/extras/transportation
[28] Community Health Choice, MTM transportation for STAR members. https://www.communityhealthchoice.org/texas-star-medicaid-plan/member-resources/mtm-transportation/
[29] Cook Children’s Health Plan, STAR benefits (MTM Health). https://www.cookchp.org/members/star/benefits/
[30] El Paso Health, member transportation (Access2Care, now MTM Health). https://www.elpasohealth.com/members/transportation.html
[31] Parkland Community Health Plan, nonemergency medical transportation (MTM Health). https://parklandhealthplan.com/nemt1
[32] Blue Cross and Blue Shield of Texas, STAR transportation services (Modivcare). https://www.bcbstx.com/star/plan-details/transportation-services
[33] Modivcare Form 8-K, December 2025 (Chapter 11 emergence, December 29, 2025). https://www.sec.gov/Archives/edgar/data/1220754/000143774925038831/modv20251226_8k.htm
[34] Texas Department of Licensing and Regulation, programs licensed and regulated by TDLR (no NEMT or medical transport program). https://www.tdlr.texas.gov/licenses.htm
[35] Texas Health and Safety Code §§ 773.041, 773.064, and 773.065 (EMS licensure for stretcher transport; Class A misdemeanor; administrative penalties). https://statutes.capitol.texas.gov/Docs/HS/htm/HS.773.htm
[36] Texas DPS, A Texas Motor Carrier’s Guide to Highway Safety (MCS-9): intrastate versus interstate commercial motor vehicle definitions, marking, insurance tables. https://www.dps.texas.gov/internetforms/forms/mcs-9.pdf
[37] 49 CFR § 387.33T, schedule of insurance limits for for-hire motor carriers of passengers in interstate commerce. https://www.law.cornell.edu/cfr/text/49/387.33T
[38] Texas DPS, vehicle safety inspection changes effective January 2025 (HB 3297; commercial inspections continue; emissions counties). https://www.dps.texas.gov/news/vehicle-safety-inspection-changes-take-effect-january-2025
[39] City of Houston, Chapter 46 vehicle-for-hire categories and Administration and Regulatory Affairs vehicle-for-hire division. https://www.houstontx.gov/ara/vfh/
[40] City of Austin, operating authority license ($159) and chauffeur permit. https://www.austintexas.gov/services/apply-operating-authority-license and https://www.austintexas.gov/services/apply-chauffeur-permit
[41] Austin-Travis County EMS, medical transfer franchise findings (private ambulance companies; City Code chapter 10-2). https://services.austintexas.gov/edims/document.cfm?id=416017
[42] MTM, transportation provider insurance requirements ($1 million combined single limit, certificate holder and additional insured, per MTM’s state provider pages) and network driver standards. https://www.mtm-inc.net/wisconsin/providers/ and https://www.mtm-inc.net/healthcare/nemt/
[43] TxDMV, 43 TAC § 218.16 as adopted December 2024 (motor carrier insurance filing table by vehicle type). https://www.txdmv.gov/sites/default/files/body-files/Chapter-218-Adopt-2024.pdf
[44] Texas Department of Insurance, automobile insurance guide (30/60/25 minimums and their limits). https://www.tdi.texas.gov/pubs/consumer/cb020.html
[45] Aquatree Insurance, NEMT insurance in Texas (December 2025 agency-published premium ranges; market color, not filed rates). https://aquatreeinsurance.com/2025/12/15/nemt-insurance-texas/
[46] Texas Department of Insurance, workers’ compensation guide and non-subscriber requirements. https://tdi.texas.gov/pubs/consumer/cb030.html and https://www.tdi.texas.gov/wc/nonsubscriber.html
[47] Texas DPS, controlled substance and alcohol use and testing (49 CFR Part 382 scope: CDL drivers). https://www.dps.texas.gov/section/highway-patrol/controlled-substance-and-alcohol-use-and-testing
[48] 25 Texas Administrative Code § 157.11, EMS provider licensing (stretcher patients in department-authorized EMS vehicles; license and vehicle fees). https://www.law.cornell.edu/regulations/texas/25-Tex-Admin-Code-SS-157-11
[49] TMHP, Texas Medicaid Provider Procedures Manual: Ambulance Services Handbook (February 2026): nonemergency ambulance criteria, prior authorization by the requesting provider. https://www.tmhp.com/sites/default/files/file-library/resources/provider-manuals/tmppm/pdf-chapters/2026/2026-02-february/2_01_ambulance_services.pdf
[50] Texas Legislature, S.B. 1266 (89th Legislature, 2025) bill analysis: nearly 9,000 applications processing beyond 60 days as of December 2024. https://capitol.texas.gov/tlodocs/89R/analysis/html/SB01266F.htm
[51] Modivcare, transportation providers (network inquiry process). https://www.modivcare.com/who-we-serve/transportation-provider-driver/
[52] Texas Comptroller, motor vehicle sales and use tax (6.25 percent). https://comptroller.texas.gov/taxes/motor-vehicle/sales-use.php
[53] Texas Comptroller, Publication 96-259, taxable services (transportation of persons not among the enumerated taxable services). https://comptroller.texas.gov/taxes/publications/96-259.php
[54] SBA, 7(a) loans and microloans. https://www.sba.gov/funding-programs/loans/7a-loans and https://www.sba.gov/funding-programs/loans/microloans
[55] LiftFund, small business loans (San Antonio-based CDFI; vehicle loans). https://www.liftfund.com/about
[56] PeopleFund, Texas CDFI small business lending. https://peoplefund.org/
[57] Office of the Texas Governor, Texas Small Business Credit Initiative. https://gov.texas.gov/news/post/governor-abbott-announces-texas-small-business-credit-initiative
[58] 1 Texas Administrative Code § 380.501, Medical Transportation Program standards for motor vehicles (equipment, signage, and identification requirements; unofficial mirror, since the official SOS TAC viewer blocks automated readers). https://txrules.elaws.us/rule/title1_chapter380_sec.380.501
[59] TMHP news, reimbursement rate changes for MTP procedure code T2003 effective November 1, 2024; current rates via TMHP’s Online Fee Lookup. https://www.tmhp.com/news/2025-01-28-reimbursement-rate-changes-and-updates-mtp-procedure-code-t2003-effective-november and https://public.tmhp.com/FeeSchedules/Default.aspx
Last verified against the sources above in August 2026. Texas requirements, health plan contracts, and vendor assignments change; check the primary sources 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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