Quick answer: NEMT insurance requirements vary by state, but the practical floor almost everywhere is a $1,000,000 combined single limit (CSL) commercial auto policy, with many transportation brokers requiring $1.5M. Nearly every state also requires general liability, workers' compensation, and sexual abuse & molestation (SAM) coverage, plus proof-of-coverage filings (often Form E) with the state PUC or DOT.
If you run non-emergency medical transportation, "what insurance do I need?" has two answers stacked on top of each other: what your state requires to operate a for-hire vehicle, and what the Medicaid broker requires to credential you. This guide walks through both so you can build a policy that clears every gate before your first trip.
NEMT is a for-hire livery operation. The moment you transport a Medicaid member for compensation, standard personal auto and even ordinary "business use" fleet policies exclude the exposure. Insurers treat carrying passengers for a fee as a fundamentally different risk, and a claim on the wrong policy can be denied outright. That is why every NEMT operator needs a commercial auto policy written specifically for livery/for-hire passenger transportation, not a repurposed contractor or delivery policy.
While the exact numbers move from state to state, the structure of an NEMT insurance program is remarkably consistent nationwide:
| Coverage | Typical requirement | What it protects |
|---|---|---|
| Commercial auto (livery) | $1M CSL floor; $1.5M common | Bodily injury & property damage from accidents |
| General liability | $1M / $2M aggregate | Slips, falls, and non-auto premises/operations claims |
| Sexual abuse & molestation (SAM) | $1M common | Abuse/molestation allegations involving passengers |
| Workers' compensation | State statutory | Employee driver injuries |
On top of those limits, brokers and many state programs require you to name them as an additional insured and to provide a certificate of insurance (COI) before you carry a single member.
Across the country, $1,000,000 combined single limit is the practical minimum for NEMT commercial auto. Some states set a lower statutory number for small vehicles, but that number is almost irrelevant in practice because the Medicaid transportation brokers who actually assign your trips typically require $1M or $1.5M regardless of what the state minimum says. A handful of higher-risk states, larger vehicles (10+ passengers), and certain broker contracts push toward $1.5M. When in doubt, build to $1.5M so you are not re-shopping the moment a broker tightens its rules.
Many states regulate for-hire passenger carriers through a Public Utilities Commission (PUC), Department of Transportation (DOT), or transportation authority. In those states your insurer must file proof of coverage on your behalf, commonly a Form E (uniform motor carrier bodily injury and property damage certificate) and, on cancellation, a Form K. This is not paperwork you file yourself; it is a filing your insurance company makes electronically to the regulator. If your policy lapses, the insurer files the cancellation notice, and your operating authority can be suspended automatically. Always confirm your carrier can make the required filing in your state before you bind.
Rather than a fragile 50-line table that goes stale, here is the framework that holds up in every state:
Because assignment structures change, always verify current requirements with your specific broker and state Medicaid transportation office. Start with your state's Medicaid NEMT page and the federal overview below.
This is the part operators underestimate. A coverage lapse does not just leave you exposed to a claim; it can suspend your Medicaid enrollment and broker credentialing. When your insurer files a cancellation notice or your COI expires, brokers stop assigning trips and your enrollment can go inactive until you re-credential, a process that can take weeks. Continuous, unbroken coverage is the single most important compliance habit in this business.
• Medicaid.gov — Non-Emergency Medical Transportation (NEMT) overview
• FMCSA — Insurance filing and Form E requirements for passenger carriers
• Georgia Medicaid — Non-Emergency Medical Transportation
NEMT Insurance Pros places commercial auto, general liability, abuse & molestation, and workers' comp for NEMT operators nationwide, with the filings and additional-insured language your broker demands.
Request a quote or call (818) 356-8150
This article is general information, not legal or insurance advice. Requirements change; verify current rules with your state Medicaid transportation office and assigned broker. NEMT Insurance Pros is the national non-emergency medical transportation insurance practice of Thrive Risk Management.