Non-Emergency Medical Transport

Most NEMT programs in Texas are carrying at least three hidden gaps.

ModivCare requires $2M liability. Your wheelchair lift isn't on the policy. Your backup driver isn't listed. One missed detail costs you the contract—or worse, a denied $500K claim.

In most programs we review, at least one of these exposures is either excluded or improperly structured.

Why NEMT Operators Come to Us

You're running Medicaid trips for ModivCare, MTM, or Southeastrans.

Your vans have wheelchair lifts and stretcher mounts. You're transporting bariatric patients, dialysis patients, and hospital discharges. Your drivers work odd hours. You call in backups when someone's sick.

Most NEMT programs we audit have at least one broker-contract gap and at least one equipment-disclosure gap. These don't surface until a contract audit or a claim hits. By then, you're either scrambling to fix it mid-contract or watching an insurer deny a six-figure claim because your policy doesn't match your actual operation.

We've spent 46 years reviewing NEMT programs across Texas. Same gaps. Same broker contracts. Same wheelchair-lift modifications nobody disclosed to the insurer. Here's what your program should actually include.


Coverage Details

What Your NEMT Program Should Include

Most NEMT operators don't realize they're carrying these gaps until a broker audit or claim exposes them. Here's what each coverage type prevents:

The Scenario Coverage That Steps In What It Protects The Cost If You're Exposed
Passenger Loading Liability. A solo driver attempts a two-person bariatric transfer. The patient falls and fractures a hip. Family sues for negligence. Passenger Accident Insurance Medical costs and liability for passenger injuries during loading, unloading, and transport. $300K–$500K
Unlisted Equipment Exposure. A driver rear-ends a vehicle. The insurer discovers an undisclosed wheelchair lift modification and denies the claim because the vehicle doesn’t match the policy. Commercial Auto with Equipment Schedule Modified vehicles (lifts, ramps, stretcher mounts) explicitly listed and covered on the declarations page. $400K–$600K
Contract Non-Compliance. ModivCare updates requirements to $2M auto liability. Your policy renews at $1M. A broker audit catches the discrepancy and terminates your contract. Auto Liability at Contract Limits Auto liability coverage matching broker requirements ($2M–$5M for Texas NEMT). Loss of contract
Unlisted Driver Exposure. A retired backup driver covers a morning route and gets T-boned. The insurer denies the claim because he wasn’t a named insured on the policy. Any Auto + Hired Auto Endorsements Coverage for unnamed occasional drivers and emergency backup staff. $100K–$200K
Workers’ Comp Misclassification. An auditor reviews trip logs and discovers drivers were coded as “delivery” to save premium. Reclassifies all staff retroactively to “passenger transport.” Back-premium bill arrives. Workers’ Compensation (Class Code 7380) Drivers coded correctly for medical transport (class code 7380) from day one. $30K–$50K
Transit A&M Exposure. Passenger alleges inappropriate conduct by a driver during a 40-minute transport. General Liability caps abuse claims at $100K. Jury awards massive damages. Abuse & Molestation (A&M) with Dedicated Limits Dedicated $1M limit for abuse allegations, separate from general liability. $500K–$1M+

If you're not sure how your policy handles these scenarios, we can walk through it with you.

Review My Coverage

Critical NEMT Coverage Details

  • Note on Claim Costs: The financial exposures above aren’t just settlements. They factor in legal defense costs. Even if you win the case, defending a passenger injury or abuse claim routinely costs $100K–$200K in attorney fees alone. Defense Outside Limits (DOL) is critical.
  • ModivCare and MTM contract requirements: Most Texas brokers require minimum $2M auto liability, $1M general liability, and $1M A&M coverage with dedicated limits. Verify your certificates match current contract requirements—these change annually.
  • Equipment schedules matter: Every wheelchair lift, stretcher mount, and ramp modification must be explicitly listed on your auto policy. "We told the agent verbally" doesn't count. Get it in writing on the declarations page.
  • Workers' Comp class code 7380: NEMT drivers transporting patients must be coded as "Drivers - Passenger Transport, NOC" (class code 7380), not as delivery drivers (8742). Wrong code = December surprise bill.
  • Hired & Non-Owned Auto is not the same as Any Auto: If you use backup drivers who aren't on your policy, you need both endorsements. One covers the driver, the other covers the vehicle they're driving.

You're running one of the tightest-margin operations in Texas healthcare.

Medicaid reimbursement rates haven't moved in years. Gas prices fluctuate. Drivers call in sick. Broker contracts get more demanding every renewal cycle. You're squeezing pennies everywhere—and insurance feels like one more line item you're being told to accept at face value.

The problem isn't the premium—it's knowing whether the policy you're paying for will actually respond when a wheelchair transfer goes wrong or a broker audits your certificates.

We don't quote you first. We read your current policy first. We look for the gaps between how you operate (bariatric patients, backup drivers, modified vans) and what your policy actually covers. Then you decide what to fix.

What We’ve Seen

Across Texas NEMT Programs

Hundreds
Healthcare and transport programs reviewed across Texas over 46 years.
Majority
Contain at least one hidden gap tied to unlisted equipment, backup drivers, or broker requirements.
$300K+
Typical starting point for passenger loading and transit injury claims.

Equipment schedule omissions and unlisted drivers are the most frequent triggers for claim denials in NEMT. Most operators don’t learn their policy has these structural gaps until after an accident. That’s the window we’re trying to close.


Common Questions

Why is NEMT so hard to insure compared to standard commercial auto?

NEMT sits at the intersection of medical liability and commercial transportation — two risk categories most standard carriers underwrite separately. You're moving vulnerable passengers with documented medical needs in vehicles that may be modified, staffed by drivers with varying training levels, under contracts that specify response times and vehicle standards. That combination requires specialty market access that most generalist agents don't have.

We have personal auto policies on our vehicles. Isn't that sufficient?

No. The moment a vehicle is used for commercial passenger transport — even part-time — most personal auto policies exclude coverage entirely. NEMT operations require commercial auto at minimum, and depending on your contracts, may require specific limits, passenger liability endorsements, and medical payments coverage that personal policies don't provide.

Our Medicaid contract specifies minimum insurance requirements. If we meet those, are we covered?

Meeting the contract minimum gets you compliant — it doesn't mean you're adequately protected. Medicaid contract minimums are set to protect the state, not your business. A single serious accident involving a vulnerable passenger can generate liability well above standard contract minimums. We review what your contracts require and what your actual exposure profile demands — those are often different numbers.

Some of our drivers use their personal vehicles for runs. How does that affect our coverage?

Hired and Non-Owned Auto (HNOA) coverage is essential if any driver operates a personal vehicle for company business. Without it, a loss in a driver's personal vehicle during a company run has no commercial coverage response — and the driver's personal policy will likely deny the claim on commercial use grounds. This is a frequent and expensive gap in NEMT programs.

We operate both NEMT and home health services. Do we need separate policies?

Not necessarily — but the program design matters significantly. Some carriers will write a combined program; others require separation. The bigger issue is making sure neither operation's exposures bleed into the other's policy limits. We see programs where an HHA claim erodes auto limits and vice versa. Proper program architecture prevents that.

What markets do you use for NEMT?

We work with specialty markets that actually understand the NEMT risk profile — carriers like Lancer, Prime Insurance, and specialty E&S markets through Amwins, Burns & Wilcox, and RT Specialty. These are not standard commercial auto carriers. Access to the right market at submission is what determines whether you get a real quote or a declination.

Get Started

Let's audit your NEMT program.

30-minute call. Walk us through your operation—your vans, your brokers, your modifications. We’ll tell you exactly where your current policy breaks—and what a claim would actually cost.

Office 6750 West Loop South, Suite 767
Bellaire, TX 77401