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

Last reviewed: 2026-09-10

Maryland Medicaid delegates the administration and funding of Non-Emergency Medical Transportation (NEMT) directly to the 24 Local Health Departments (LHDs) rather than operating a centralized fee-for-service NEMT provider network. Providers seeking to offer medical transportation to covered appointments must secure a contract or vendor agreement with the specific LHD in the county where the beneficiary resides before they can receive Medicaid reimbursement.

For transportation funded under Home and Community-Based Services (HCBS) waivers, such as the Community Pathways Waiver, providers must obtain programmatic approval from the Developmental Disabilities Administration (DDA) or the Maryland Department of Health (MDH) before enrolling in the ePREP portal. Approval requires meeting vehicle inspection standards, driver credentialing, and county-specific procurement cycles, meaning independent operators cannot simply enroll and bill without a local government or waiver-program contract.

1. Service Definition and Scope

In Maryland, Non-Emergency Medical Transportation (NEMT) provides eligible Medicaid beneficiaries with rides to and from Medicaid-covered medical services when they have no other means of transportation. The service is administered locally by county health departments.

For HCBS waiver participants, transportation services cover rides to waiver-funded activities, such as supported employment or day habilitation, and are distinct from the LHD-managed medical appointment transportation.

• Covered Destinations: Medicaid-billable medical appointments, pharmacies, and approved waiver activities.
• Modality Types: Ambulatory (sedan/van) and wheelchair-accessible vehicle (WAV) transports.
• Excluded Services: Emergency ambulance transportation and rides to non-medical or non-waiver destinations.
• Beneficiary Eligibility: Beneficiaries must be screened by their LHD to verify lack of alternative transportation.
• Service Boundaries: Transportation is generally limited to the beneficiary's home county and adjacent counties unless specialized care is required.
• Waiver Integration: DDA waiver transportation is authorized through the participant's Person-Centered Plan (PCP).

2. Regulatory and Oversight Agencies

The Maryland Department of Health (MDH) holds ultimate authority over the Medicaid program, but delegates NEMT operations to local jurisdictions. Waiver transportation is overseen by specific MDH divisions like the Developmental Disabilities Administration (DDA).

Providers must interact with both state-level enrollment portals and county-level procurement offices to maintain compliance and active billing status.

• Maryland Department of Health (MDH): Oversees Medicaid policy and the ePREP enrollment system (https://health.maryland.gov).
• Local Health Departments (LHDs): Manage NEMT grants, screen beneficiaries, and contract with local transportation vendors (https://health.maryland.gov/pages/departments.aspx).
• Developmental Disabilities Administration (DDA): Approves providers for HCBS waiver transportation services (https://dda.health.maryland.gov).
• Maryland Public Service Commission (PSC): Regulates for-hire passenger transportation and issues operating authority (https://www.psc.state.md.us).
• ePREP / MPRIME Portal: The state's Medicaid provider enrollment system, transitioning to MPRIME in October 2026 (https://eprep.health.maryland.gov).

3. Gatekeeping Prerequisites: Who Can Even Apply

The absolute structural precondition for providing general Medicaid NEMT in Maryland is securing a contract or vendor agreement with a Local Health Department (LHD). The state does not allow independent NEMT companies to enroll in Medicaid and bill the state directly for general medical rides.

For waiver transportation, providers must first submit an application to the DDA and receive programmatic approval before their ePREP Medicaid enrollment application will be processed.

• Local Health Department Contracting: Providers must win a bid or sign a vendor agreement with the specific county LHD where they intend to operate.
• County Procurement Cycles: Access to LHD contracts is often limited to specific Request for Proposal (RFP) windows or open enrollment periods dictated by the county.
• DDA Provider Application: Waiver transportation providers must pass the DDA's initial application and readiness review.
• Public Service Commission Authority: Applicants must hold active for-hire operating authority from the Maryland PSC before applying to an LHD or DDA.
• Business Registration: Must be registered and in good standing with the Maryland State Department of Assessments and Taxation (SDAT).

4. Licensure and Certification Requirements

Maryland does not issue a specific "Medicaid NEMT License." Instead, providers must obtain for-hire passenger carrier authority from the Maryland Public Service Commission (PSC) and comply with local county business licensing.

Vehicles must pass rigorous safety inspections, and providers must maintain commercial insurance policies that meet both PSC and LHD minimums.

• PSC Carrier Authorization: Required for all entities transporting passengers for hire in Maryland.
• Vehicle Inspections: Vehicles must pass Maryland State Police or PSC-authorized safety inspections annually.
• Commercial Insurance: Minimum liability coverage as dictated by the PSC and the specific LHD contract (often $1 million or more).
• ADA Compliance: Wheelchair-accessible vehicles must meet Americans with Disabilities Act (ADA) lift and securement standards.
• Local Business Licenses: Providers must hold valid business licenses in the counties where they are headquartered and operate.

5. Medicaid Provider Enrollment

Once local contracts or DDA approvals are secured, providers must enroll in Maryland Medicaid via the electronic Provider Revalidation and Enrollment Portal (ePREP). MDH has announced a transition to a new system, MPRIME, scheduled for October 2026.

Enrollment requires submitting proof of LHD affiliation or DDA approval, along with standard federal disclosures and application fees.

• ePREP Portal: The mandatory online system for all Maryland Medicaid provider enrollments and updates.
• Application Fee: Institutional providers must pay the federal Medicaid application fee (or provide proof of Medicare payment) during enrollment.
• NPI Requirement: Providers must obtain a National Provider Identifier (NPI) specific to transportation services.
• Provider Type Classification: Must enroll under the specific provider type code designated for NEMT or waiver transportation.
• Revalidation: Providers must revalidate their Medicaid enrollment through ePREP every five years.

6. Staffing, Training and Background Checks

Drivers are the primary point of care in NEMT and must meet strict background and training standards set by the LHDs, DDA, and the PSC.

Agencies must maintain comprehensive driver files demonstrating continuous compliance with driving record checks and safety certifications.

• Criminal Background Checks: State and federal fingerprint-based background checks are required for all drivers.
• Driving Record (MVA): Continuous monitoring of Maryland Motor Vehicle Administration records for moving violations or suspensions.
• CPR and First Aid: All drivers must hold current, in-person CPR and First Aid certifications.
• Defensive Driving: Completion of an approved defensive driving course prior to transporting beneficiaries.
• Passenger Assistance Training: Drivers operating WAVs must complete specialized training in wheelchair securement and passenger handling.
• Drug Testing: Pre-employment and random drug and alcohol testing as required by PSC and LHD contracts.

7. Documentation, Policies and Records

Providers must maintain meticulous records of every trip to support claims billed to LHDs or the state. Missing signatures or incomplete logs are the leading cause of recouped funds.

Agencies must also keep up-to-date vehicle maintenance logs and driver credential files available for immediate inspection.

• Trip Manifests: Must include pickup/drop-off times, locations, odometer readings, and driver signatures.
• Beneficiary Signatures: A physical or electronic signature from the beneficiary or facility staff is required for every completed leg of a trip.
• Vehicle Maintenance Logs: Documented proof of routine maintenance, daily pre-trip inspections, and repairs for each vehicle.
• Driver Credential Files: Centralized records of licenses, background checks, and training certificates for all active staff.
• Incident Reporting: Documented policies for reporting accidents, injuries, or behavioral incidents to the LHD or DDA within 24 hours.
• Record Retention: All trip and billing records must be retained for a minimum of six years per Maryland Medicaid rules.

8. Billing, Rates and Claims

Billing procedures depend entirely on the funding source. General NEMT is billed directly to the authorizing Local Health Department according to the rates and invoicing procedures established in the county contract.

Waiver transportation is billed through the state's LTSSMaryland system or ePREP, using specific HCPCS procedure codes authorized in the participant's care plan.

• LHD Invoicing: General NEMT claims are submitted to the county health department, not through the state MMIS.
• Waiver Claims (LTSSMaryland): DDA transportation claims are processed through the state's Long Term Services and Supports system.
• Procedure Codes: Common codes include A0120 (Non-emergency transportation: mini-bus, mountain area transports, or other transportation systems) and A0130 (Wheelchair van).
• Rate Setting: General NEMT rates are negotiated or set by the individual LHD; waiver rates are published in the MDH fee schedule.
• Prior Authorization: All trips must be pre-authorized by the LHD or included in the approved DDA Person-Centered Plan.
• Clean Claim Timelines: Claims must typically be submitted within 12 months of the date of service, though LHD contracts may stipulate shorter windows.

9. Approval Sequence and Timeline

Becoming a provider is a multi-step process that must be completed in a strict sequence. Attempting to enroll in Medicaid before securing local authority will result in immediate denial.

The entire process can take 6 to 12 months, heavily dependent on county procurement schedules and PSC hearing dates.

• Step 1: Entity Formation: Register the business with Maryland SDAT and obtain an EIN and NPI.
• Step 2: PSC Authority: Apply for and receive for-hire operating authority from the Maryland Public Service Commission.
• Step 3: Local Contracting: Respond to an LHD RFP or submit a DDA provider application and await programmatic approval.
• Step 4: ePREP Enrollment: Submit the Medicaid enrollment application via ePREP, attaching the LHD contract or DDA approval.
• Step 5: LTSSMaryland Registration: For waiver providers, complete registration and training in the LTSSMaryland billing system.
• Step 6: Credentialing: Finalize driver training, vehicle inspections, and begin accepting authorized trips.

10. Common Denials and Survey Findings

Applications are frequently rejected when providers misunderstand Maryland's decentralized NEMT structure and attempt to enroll without a county contract.

During audits, LHDs and state surveyors focus heavily on trip documentation and driver qualifications, recouping funds for any gaps.

• Missing LHD Contract: ePREP applications denied because the provider lacks a vendor agreement with a Local Health Department.
• Incomplete Trip Logs: Recoupment of funds due to missing beneficiary signatures or odometer readings on manifests.
• Lapsed Insurance: Suspension of LHD contracts due to failure to maintain or provide proof of continuous commercial auto liability insurance.
• Driver File Gaps: Citations for allowing drivers with expired CPR certifications or unchecked MVA records to transport beneficiaries.
• Unapproved Vehicles: Billing for trips performed in vehicles that have not passed PSC or LHD safety inspections.
• Address Discrepancies: ePREP denials caused by mismatches between the SDAT business address and the application address.

11. Key Contacts and Resources

Providers must navigate multiple state and local websites to maintain compliance. The MDH Provider Enrollment page and the specific county health department websites are the most critical resources.

For waiver services, the DDA website provides the necessary programmatic applications and policy manuals.

• MDH Provider Enrollment: Official guidance and fee schedules (https://health.maryland.gov/mmcp/provider/Pages/enrollment.aspx).
• ePREP Portal: The Medicaid enrollment system (https://eprep.health.maryland.gov).
• Maryland Public Service Commission: For-hire vehicle regulations and applications (https://www.psc.state.md.us).
• Developmental Disabilities Administration: Waiver provider applications and policies (https://dda.health.maryland.gov).
• Local Health Departments Directory: Contact information for county NEMT contracting (https://health.maryland.gov/pages/departments.aspx).
• LTSSMaryland: The billing and case management system for waiver services (https://ltssmaryland.health.maryland.gov).

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