Arizona - Adult Health Transportation — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-09

The Arizona Health Care Cost Containment System (AHCCCS) registers Non-Emergency Medical Transportation (NEMT) under Provider Type 28 (PT-28) to fund rides to covered medical appointments and Arizona Long Term Care System (ALTCS) waiver services. Arizona does not issue a distinct state facility license for standard ground NEMT businesses; instead, the state regulates these providers directly through the Medicaid enrollment process and managed care network standards.

Approval requires passing AHCCCS's high-risk provider screening, which mandates a site visit, an application fee, and fingerprint-based criminal background checks before an application is approved. Once enrolled in the AHCCCS Provider Enrollment Portal (APEP), providers must secure contracts with individual AHCCCS Complete Care (ACC) managed care plans, ALTCS plans, or their designated NEMT brokers to receive trip assignments and reimbursement.

1. Service Definition and Scope

In Arizona, NEMT (PT-28) covers ground transportation for AHCCCS members to medically necessary services and ALTCS waiver programs. The service is designed for members who do not require ambulance-level medical care or life support during transit.

The service model accommodates standard fleet operators as well as Transportation Network Companies (TNCs). Coverage includes base trip rates and mileage, with specific rules governing the transport of unaccompanied minors.

• Service Name: Non-Emergency Medical Transportation (Provider Type 28).
• Scope Limit: Members who do not require personal medical assistance or life support during transport.
• Mileage Threshold: Roundtrip ground transportation over 100 miles requires Prior Authorization.
• Unaccompanied Minors: Transporting members aged 16-17 without a guardian requires a signed Authorization and Release Form and a driver with a Level I Fingerprint Clearance Card.
• TNC Scope: Transportation Network Companies are eligible to serve Medicaid members who do not require personal assistance.

2. Regulatory and Oversight Agencies

Because Arizona does not issue a specific state facility license for standard NEMT businesses, oversight is handled directly through Medicaid provider enrollment and managed care contracting.

AHCCCS dictates provider standards, conducts high-risk screenings, and audits claims, while the Arizona Department of Public Safety processes the required fingerprint clearances for drivers.

• Medicaid Agency: Arizona Health Care Cost Containment System (AHCCCS) (https://www.azahcccs.gov/).
• Enrollment System: AHCCCS Provider Enrollment Portal (APEP) (https://www.azahcccs.gov/APEP).
• Background Check Authority: Arizona Department of Public Safety (AZ DPS) (https://www.azdps.gov/).
• Claims Portal: AHCCCS Online (https://ao.azahcccs.gov/).

3. Gatekeeping Prerequisites: Who Can Even Apply

Arizona allows NEMT PT-28 providers to apply directly for registration in APEP without a prior Certificate of Need or state facility license. However, enrollment alone does not guarantee trip volume.

To receive scheduled rides and payment, providers must navigate managed care network requirements and contract with the specific health plans or brokers operating in their region.

• Risk Level Designation: All new NEMT PT-28 applicants are categorized as High-Risk, requiring site visits and fingerprinting before enrollment.
• Managed Care Contracting: Providers must contract with AHCCCS Complete Care (ACC) plans, ALTCS plans, or their designated NEMT brokers to receive scheduled rides.
• TNC Eligibility: Transportation Network Companies (rideshare) are explicitly eligible to register as NEMT providers as of May 1, 2019.
• EFT Requirement: Electronic Funds Transfer enrollment is a mandatory prerequisite; failure to complete the EFT form results in application denial.

4. Licensure and Certification Requirements

Standard NEMT is not a licensed health care facility category in Arizona, meaning there is no Department of Health Services (ADHS) license required for PT-28. Providers must instead meet AHCCCS's vehicle and insurance standards.

Vehicles must comply with state traffic laws and AHCCCS subcontract provisions to ensure member safety during transit.

• State Licensure: No distinct Department of Health Services license exists for standard ground NEMT.
• Vehicle Standards: Vehicles must be in good working order and not exceed manufacturer seating occupancy.
• Insurance: Providers must meet AHCCCS Minimum Subcontract Provisions Insurance Requirements.
• Driver Licensing: Drivers must hold a valid standard driver's license following applicable state laws.

5. Medicaid Provider Enrollment

Enrollment is conducted entirely online through APEP. The process includes submitting tax documents, paying the federal application fee, and undergoing high-risk screening protocols.

Effective May 1, 2023, all new and revalidating PT-28 applicants are subject to these high-risk screening requirements.

• Application Portal: AHCCCS Provider Enrollment Portal (APEP).
• Application Fee: $750 for calendar year 2026 (effective January 1, 2026 through December 31, 2026).
• Tax Documentation: Completed IRS W-9 Form is required.
• Screening Form: Provider Enrollment Screening Glossary (PEP-903) dictates required attachments.

6. Staffing, Training and Background Checks

Staffing requirements focus heavily on background clearances due to the high-risk designation of the NEMT provider type. Drivers must be cleared before transporting vulnerable Medicaid members.

Specific fingerprint clearance levels are mandated depending on the age of the members being transported.

• Owner/Applicant Background: Fingerprint-Based Criminal Background Check (FCBC) (PEP-902) required for high-risk screening.
• Driver Clearance: Level I Fingerprint Clearance Card from AZ DPS required for drivers transporting unaccompanied minors.
• Exclusion Checks: Providers must conduct Federal health care program exclusion checks on all drivers.
• TNC Drivers: TNCs must maintain records of driver criminal background checks.

7. Documentation, Policies and Records

AHCCCS requires strict record-keeping to support retrospective audits. Providers must document the medical necessity, specific locations, and exact mileage of every trip.

TNCs must utilize specific digital network capabilities to track ride data securely.

• Record Retention: Maintain all records (driver info, vehicle inspections, trips) for a minimum of six complete calendar years.
• Trip Documentation: Must verify mileage, medical condition, and specific pick-up/drop-off locations.
• Minor Transport Form: Must retain the signed Authorization and Release Form (Attachment A) for unaccompanied minors.
• TNC Software: TNCs must use a digital network capturing member name, phone, addresses, date, and time.

8. Billing, Rates and Claims

NEMT claims are submitted either to the managed care plan or to AHCCCS directly for fee-for-service populations (like IHS/638). Billing separates the base trip from the mileage.

Prior authorization is strictly enforced for long-distance transports.

• Claim Form: CMS 1500 (or 837P for electronic claims).
• Base Rate Billing: Billed on Line 1 of the claim form (two units if multiple transports authorized same day).
• Mileage Billing: Total mileage billed on Line 2.
• Prior Authorization: Required via AHCCCS Online for roundtrips over 100 miles.

9. Approval Sequence and Timeline

The enrollment process begins with APEP submission and fee payment, followed by AHCCCS screening activities. Expedited processing is only available for specific emergent member needs.

Providers must complete the EFT setup process concurrently to avoid application denial.

• Standard Processing: AHCCCS generally processes Provider Enrollment applications within 60 days of submission.
• Screening Sequence: Application submission, fee payment, database checks, site visit, and FCBC.
• EFT Setup: Submit EFT Auth Form via AHCCCS Solutions Center after generating an APEP application ID.
• Expedited Requests: Submitted via AHCCCS Solutions Center; requires NPI, TIN, and APEP application number.

10. Common Denials and Survey Findings

Applications are frequently delayed or denied due to incomplete documentation or failure to complete the mandatory EFT setup. Post-enrollment, providers face recoupment if retrospective audits find mileage discrepancies.

Strict adherence to prior authorization rules is required to prevent claim denials.

• EFT Failure: Application denied if the provider fails to complete the EFT requirement and respond to AHCCCS requests.
• Audit Recoupment: Retrospective audits target unjustifiable mileage or incorrect specific locations.
• Missing PA: Claims denied for roundtrips over 100 miles lacking Prior Authorization from AHCCCS DFSM or ALTCS case manager.
• Incomplete Inquiries: Solutions Center tickets closed if missing required data (Provider name, NPI, Application ID).

11. Key Contacts and Resources

Providers utilize AHCCCS portals for enrollment, claims, and support. The Solutions Center acts as the primary help desk for application issues.

Background checks are coordinated through the state's public safety department.

• AHCCCS Provider Enrollment Portal (APEP): https://www.azahcccs.gov/APEP
• AHCCCS Solutions Center: https://servicenow.azahcccs.gov/gsp
• AHCCCS Online (Prior Auth/Claims): https://ao.azahcccs.gov/
• Arizona Department of Public Safety (Fingerprinting): https://www.azdps.gov/

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