Medicaid NEMT Licensing Changes Effective January 1, 2027
The Nebraska Legislature recently passed LB1126, which changes how providers of Medicaid Non-Emergency Medical Transportation (NEMT) are authorized by the Nebraska Public Service Commission (PSC). Beginning January 1, 2027, Medicaid NEMT services will operate under a new licensing system.
This change affects both:
- Carriers that currently provide Medicaid NEMT services under a DHHS designation; and
- Individuals or companies interested in providing Medicaid NEMT services in the future.
The purpose of this transition is to create a separate licensing process specifically for Medicaid NEMT providers. The new process removes the public notice, protest, and hearing requirements that existed under the previous system and replaces them with a streamlined licensing process focused on safety, compliance, and fitness to operate.
This page explains, in plain language, what is changing, what current carriers need to do, and how new carriers can get licensed.
After a Medicaid NEMT license is issued, you must work with the Nebraska Department of Health and Human Services to enroll as a provider. Information on that process can be found here: Provider Screening and Enrollment
If you currently hold a Certificate or Permit with a DHHS designation, that designation will no longer be the authority used to provide Medicaid NEMT service after January 1, 2027. Instead, Medicaid NEMT services will be provided under a separate Medicaid NEMT License.
To simplify the transition and avoid interruptions in service, the PSC intends to automatically transition existing DHHS designations to the new license structure for carriers that confirm their desire to do so.
Current carriers must submit written confirmation to the PSC by December 9, 2026 to participate in this administrative transition process.
Beginning January 1, 2027, new applicants seeking to provide Medicaid NEMT services will apply directly for a Medicaid NEMT License. Unlike the previous process, applicants will not be required to demonstrate public need, undergo a protest process, or participate in a hearing before a license can be granted.
Instead, applicants must demonstrate that they are fit, willing, and able to provide the service and comply with applicable Commission requirements.
| Current System | Beginning January 1, 2027 |
|---|---|
| Medicaid NEMT authority issued as a DHHS designation attached to a Certificate or Permit | Medicaid NEMT authority issued through a separate Medicaid NEMT License |
| Public notice required and Applicant's face potential protests | No notice or protest process |
| Hearings often required | No hearing required for issuance, unless Commission determines Applicant poses a fitness concern |
| Authority remains active unless canceled or revoked | License MUST be renewed ANNUALLY |
| One authority may cover multiple services | Some carriers may need both a Medicaid NEMT License and a separate Certificate or Permit |
Generally:
- Current Medicaid NEMT providers should review the transition requirements and determine whether they need to submit written confirmation to the PSC.
- Prospective Medicaid NEMT providers should review the new licensing requirements that take effect January 1, 2027.
- Carriers providing both Medicaid NEMT and other passenger transportation services should pay particular attention to how the new license may interact with their existing authorities.
What is changing?
Under a new law (LB1126), anyone who wants to provide Medicaid NEMT services in Nebraska must have a Medicaid NEMT License issued by the Public Service Commission (PSC). This replaces the old system where carriers used a DHHS designation attached to a Certificate or Permit.
Why is this change happening?
The goal is to make regulation simpler and more efficient. Under the old system, carriers had to go through a lengthy approval process, including proving public need and waiting through protest periods. The new system removes those steps and focuses on whether a carrier is fit and able to provide Medicaid NEMT services.
What is the Medicaid NEMT License?
The Medicaid NEMT License is a stand‑alone authority that allows you to provide Medicaid NEMT transportation statewide.
Key points:
- Valid for one year and must be renewed annually
- $250 application fee
- Requires a background check
- Requires insurance documentation (a Form E)
- Requires a list of vehicles used (but no PSC vehicle plates will be issued)
- No public notice, protests, or hearings required for issuance
- The license remains a perquisite to contracting with the appropriate designated agent for DHHS
How is this different from the old DHHS designation?
Old System:
- DHHS designation attached to a Certificate or Permit
- Required proving public need
- Required 30‑day notice and potential hearings
- Authority remained valid indefinitely unless cancelled or revoked
New System:
- Separate Medicaid NEMT License
- No hearings or public‑need requirement
- Must be renewed every year
- Carriers offering additional (non‑Medicaid) services may need multiple authorities
What do current carriers need to do?
If you currently hold a DHHS designation, you must notify the PSC in writing by December 9, 2026 that you want your designation converted into a Medicaid NEMT License.
Written confirmation can be done by emailing psc.motorfilings@nebraska.gov your intention for a transition.
If you do not send this confirmation:
- Your designation will not be automatically transitioned
- You will need to apply for a new license beginning January 1, 2027
What if I am currently applying for a Certificate or Permit with a DHHS designation?
You must also confirm in writing by December 9, 2026 that you want your pending application transitioned into a Medicaid NEMT License application.
Written confirmation can be done by emailing psc.motorfilings@nebraska.gov your intention for a transition.
What happens on January 1, 2027?
If you submitted written confirmation by the deadline, the PSC will automatically transition your existing designation or pending application into the new licensing system.
If you did not submit confirmation:
- You may still apply for a Medicaid NEMT License beginning January 1, 2027
- Your transition will not be automatic
- You may experience a lapse in authorization until your new license is approved
Will I still need my Certificate or Permit?
It depends on the services you offer:
- If you only provide Medicaid NEMT services → You will likely only need the Medicaid NEMT License
- If you provide any other type of intrastate passenger service → You will need the Medicaid NEMT License and a separate Certificate or Permit
How will PSC enforce the new license requirements?
The PSC may suspend or revoke a Medicaid NEMT License if:
- You fall out of compliance with insurance or safety requirements
- You violate PSC rules or lawful orders
You will receive at least 15 days’ written notice before a suspension hearing.
Do rideshare companies (TNCs) need a Medicaid NEMT License?
Yes. Any TNC providing Medicaid NEMT services must hold a Medicaid NEMT License starting January 1, 2027.
What if I miss the December 9 deadline?
You can still apply for a Medicaid NEMT License beginning January 1, 2027. However:
- Your current authority will not automatically convert
- You may not be authorized to provide Medicaid NEMT services until the PSC issues your new license
Where do I get the application?
The application can be found here: Application - Medicaid Non-Emergency Medical Transportation License.docx
If you are seeking a transition of a current DHHS designation or application you do not need to file the application, just confirm your desire for a transition by emailing psc.motorfilings@nebraska.gov.
Need Assistance?
PSC staff can answer questions and help guide you through the transition process by emailing your question to psc.motorfilings@nebraska.gov or by calling the Commission at 402-471-0235.
Meetings can also be scheduled with Commission staff by contacting us and scheduling a time for an in-person meeting.
