Modivcare Compliance Checklist: Avoiding Broker Audit Red Flags

Modivcare, the largest non-emergency medical transportation broker in the country, coordinating roughly 70 million trips a year across 48 states and DC, emerged from Chapter 11 bankruptcy on December 29, 2025, after cutting more than $1.1 billion in debt and bringing in $100 million in new capital. The company is now privately owned by a group of restructuring lenders.

That matters for every provider in Modivcare's network, not just its shareholders. A company coming out of a debt restructuring with new ownership has one job: protect margins. For a broker, that means tighter compliance enforcement, faster terminations for non-compliant providers, and (per Modivcare's own public statements) a move toward automated transportation provider credentialing. Automated systems don't make exceptions for a missing document or an expired certification the way a human reviewer sometimes will. The providers most at risk right now are the ones who've been getting by on manual, loosely tracked compliance.

Here's what Modivcare actually requires, and how to make sure you're not the provider who fails the next audit.

Driver requirements

• PASS (Passenger Assistance Safety and Sensitivity) certification for wheelchair/mobility-device transport
• First Aid/CPR certification, current and not expired
• Defensive driving certification
• Clean Motor Vehicle Report (MVR), pulled at contracting and re-checked periodically
• Background check on file for every active driver
• Drug testing records, including for any new driver added mid-contract
• North Carolina specifically requires additional training on serving passengers who have experienced trauma

Vehicle requirements

• Current vehicle registration and, where applicable, state inspection certificates for every vehicle in your active fleet
• Insurance coverage meeting Modivcare's minimums: General Liability, Sexual Abuse/Molestation coverage, Auto (typically $1M combined single limit), and Workers' Compensation where required
• Vehicles must be ready for field visits. Modivcare conducts in-person checks to confirm vehicles match what's on file, not just what was submitted at onboarding

Documentation and business compliance

• Active state transportation licenses and permits
• Business registration, EIN, and current tax standing, plus a signed W-9
• HIPAA compliance training documentation for all staff who touch trip or patient data
• Completed Code of Conduct and Transportation Provider Compliance Training, done at contracting and again annually
• Annual Transportation Provider Compliance Attestation, signed and submitted on Modivcare's schedule, not yours

Where providers actually get flagged

Talk to any operator who's been dropped from a broker network and the reason is rarely one big violation. It's usually a document that expired and nobody caught it, a driver added to the schedule before their background check cleared, or a compliance attestation that got missed because it lived in someone's inbox instead of a system that tracks renewal dates. As Modivcare moves to automated credentialing, that kind of gap gets caught faster, not slower.

The checklist, in one place

• Every active driver has current PASS, First Aid/CPR, and defensive driving certifications on file
• MVRs pulled within the required window for every driver
• Background checks and drug testing records complete for all drivers, including recent hires
• Every vehicle's registration and inspection is current
• Insurance policies meet or exceed Modivcare's minimums and haven't lapsed
• HIPAA training documentation is current for all relevant staff
• Code of Conduct and Compliance Training completed and dated within the last 12 months
• Annual Compliance Attestation submitted on schedule
• A system in place that flags any of the above before it expires, not after an audit catches it

Why this is a software problem, not a paperwork problem

Most providers who fail a broker audit aren't cutting corners. They're tracking dozens of expiration dates across drivers, vehicles, and documents in spreadsheets or filing cabinets, and something slips. That's exactly the gap NEMT dispatch and fleet software is supposed to close: automated renewal reminders before a certification lapses, a single system of record for every driver and vehicle document, and an audit trail that's ready to hand over the moment a broker asks for it, instead of a scramble.