Texas NEMT insurance, set by the HHSC contract chain

In Texas, non-emergency medical transportation for Medicaid riders runs through the Health and Human Services Commission's Medical Transportation Program. HHSC contracts with regional managed transportation organizations and two full-risk brokers for traditional Medicaid, and each Medicaid health plan arranges rides for its own members through a transportation vendor. The statute lets those organizations impose their own provider requirements, and the HHSC rule names no insurance amount. Your limit is in the contract you sign.

Tow truck insurance

The program, and the two doors into it

HHSC describes the Medical Transportation Program as "responsible for arranging and administering cost effective, non-emergency medical transportation NEMT services" for Medicaid clients, Children with Special Health Care Needs Services Program clients, and Transportation for Indigent Cancer Patients clients "who have no other means of transportation" (HHSC, Medical Transportation Program). Senate Bill 8 of the 83rd Legislature in 2013 required HHSC to implement a managed transportation organization model, delivered "in contiguous counties within a managed transportation service region", and HHSC "also contracts with two Full Risk Brokers to coordinate transportation using a network of providers in the Dallas Fort Worth and Houston/Beaumont" service delivery areas. Providers enroll with HHSC through the Texas Medicaid and Healthcare Partnership's enrollment system (TMHP, MTP).

The member-facing page shows the second door. A rider with a Medicaid health plan is told to "Call your health plan's medical transportation contact number"; a rider without one calls the MTP line (HHSC, Nonemergency Medical Transportation Program). HHSC publishes the vendor behind each plan: as of September 2026 the list names MTM, ModivCare, and SafeRide across the fourteen plans (HHSC, health plan transportation contacts). A Texas provider therefore subcontracts with an MTO or broker for traditional Medicaid trips, with a plan's vendor for managed care trips, or with both, and each agreement carries its own certificate requirement.

What Government Code Chapter 540A says, and does not say

The MTO statute was recodified into Texas Government Code Chapter 540A, Medicaid Managed Transportation Services, effective April 1, 2025, replacing the former Section 533.00257. It defines a managed transportation organization as a transit district, a public transportation provider, a regional contracted broker, a local private transportation provider approved by the commission, or any other entity the commission finds qualified (Section 540A.0001), and lets HHSC deliver the program regionally through MTOs that operate under a capitated rate, assume full financial risk, run a call center, use fixed routes where appropriate, and supply data to the commission, procured by competitive bid for each region (Section 540A.0051). The commission sets "minimum quality and efficiency measures" (Section 540A.0052), and an MTO must attempt to contract with providers that meet those measures "and other requirements that the managed transportation organization may impose" and that accept its prevailing rate (Section 540A.0053). That last clause is the hook. The statute does not name a coverage or a limit; it hands the MTO the authority to require one.

The managed care side is Subchapter C and D. Each Medicaid managed care organization must "arrange and provide nonemergency transportation services" to its enrollees (Section 540A.0101), may contract with a transportation vendor to do so (Section 540A.0151), and HHSC's rules must require that vendor, before a driver carries a rider, to confirm the driver is at least 18, holds a valid license, and "possesses proof of registration and automobile financial responsibility for each motor vehicle" used, to run a criminal background check, to confirm the vehicle passes state inspection and has four doors unless it is an accessible unit, and to review the driving record (Section 540A.0152). The phrase is "automobile financial responsibility". No amount follows it in the statute, and this page does not supply one. A separate carve-out lets an MTO or a plan subcontract with a rideshare-style transportation network company, and HHSC's transport rules do not apply to that company or its drivers (Sections 540A.0054 and 540A.0103); a driver who meets the Occupations Code's TNC driver requirements may not be given additional ones (Sections 540A.0058 and 540A.0155).

The HHSC rule: vehicle and driver standards without a limit

HHSC's program rules are 1 Texas Administrative Code Chapter 380, Medical Transportation Program. This page covers the definitions (Section 380.101), the individual transportation participant section (380.401), and both sections of Subchapter E, which govern regional contracted brokers and MTOs: Standards for Motor Vehicles (380.501) and Standards for Motor Vehicle Operators (380.502). The eligibility and services sections in Subchapter B, the client rights section, and the MTO, broker, and vendor contracts themselves sit outside it.

Section 380.501 requires a broker or MTO to ensure every vehicle meets state and federal safety and maintenance standards, carries the provider name and vehicle number in letters at least six inches high, and is equipped with seat belts at every passenger position, working speedometer and odometer, interior lights, two exterior and one interior mirror, a secured fire extinguisher, a first aid kit, working heat and air, and posted signage, and complies with the ADA vehicle guidelines, the Federal Motor Vehicle Safety Standards, and Transportation Code Chapter 547. Section 380.502 requires license verification, Department of Public Safety driving record and criminal history checks with a seven-year bar for DWI, and driver training. Neither section mentions insurance, a liability limit, or a dollar figure. The chapter's only insurance words appear in Section 380.401, which requires an individual transportation participant, the reimbursed relative, friend, or neighbor driver, to "have and maintain a current driver's license, current vehicle insurance, current vehicle inspection sticker and current vehicle license tags". That is the whole of what the rule says about coverage.

Put the pieces together and the picture is consistent with the federal one: the state assures the ride (42 CFR 431.53), CMS says federal law sets no vehicle or insurance standard beyond the 2020 driver floor, Texas's statute hands the MTO and the plan's vendor the power to set requirements, and the HHSC rule stops at the vehicle and the driver. What your van must carry is in the agreement in front of you. For the federal passenger-carrier minimum, which reaches a Texas provider only when trips cross a state line for hire, see our national NEMT insurance page. For the Texas class where the state does write the number into the permit, see Texas tow truck insurance, or start at the overview.

Frequently Asked Questions

Does Texas set a minimum insurance limit for NEMT vehicles in rule?
Not in the sections that govern brokers and managed transportation organizations. HHSC’s Medical Transportation Program rules in 1 TAC Chapter 380 set vehicle standards (seat belts at every position, mirrors, a fire extinguisher, a first aid kit, ADA and FMVSS compliance) and driver standards (license verification, DPS driving record and criminal history checks, training) without naming an insurance coverage or amount. The one insurance sentence in the chapter applies to individual transportation participants, the reimbursed relatives and neighbors, who must keep current vehicle insurance. The limit a commercial provider must carry comes from the managed transportation organization, broker, or health-plan vendor contract, and that contract is the document to ask for.
Who do I contract with to run NEMT in Texas?
It depends on which riders you carry. For traditional Medicaid riders, HHSC delivers the Medical Transportation Program through managed transportation organizations selected by competitive bid for each region, plus two full-risk brokers in the Dallas-Fort Worth and Houston-Beaumont service areas. For members of a Medicaid health plan, state law requires the plan itself to arrange nonemergency transportation, and HHSC lists the transportation vendor each plan uses. Providers subcontract with whichever of those entities holds the trips in their counties.
Does the Texas tow truck permit agency license NEMT vans?
No. Texas tow trucks are permitted by the Texas Department of Licensing and Regulation, which writes the insurance minimum into the permit. The Medical Transportation Program is administered by the Texas Health and Human Services Commission under Government Code Chapter 540A and 1 TAC Chapter 380, and the provider’s requirements flow from the HHSC contract chain rather than from a per-vehicle permit. The two programs do not overlap, and an agent quoting an NEMT van should not be looking at the towing rule.