North Dakota Medicaid tightens enrollment and review rules for transportation and care providers
North Dakota Medicaid has paused some new provider enrollments and is imposing expanded identity, licensing, vehicle and insurance requirements on non-emergency transportation providers as a broader review plan begins.
North Dakota Medicaid has paused new enrollments for some transportation and care providers while requiring more detailed identity and vehicle documentation from non-emergency medical transportation providers.
The changes began with a temporary moratorium effective June 11, 2026. New NEMT driver enrollment requirements took effect July 1, while broader revalidation reviews are scheduled to continue through June 2028.
For Medicaid patients, the immediate distinction is important: the moratoria apply to new enrollments, not providers already enrolled in the program. North Dakota Medicaid says it will monitor provider capacity and access as the changes proceed.
What changed June 11
The statewide moratorium applies to new non-emergency medical transportation, or NEMT, agency enrollments.
Separate moratoria apply to new qualified service provider, or QSP, agency enrollments and new developmental-disability agency enrollments in Burleigh and Cass counties.
Existing enrolled providers are not affected by the moratoria. Applications that had reached final approval on June 11 could continue through approval. Applications that had not reached final approval by that date were to be denied.
The moratoria last six months from the June 11 effective date. North Dakota Medicaid may extend them in additional six-month periods if the department determines an extension is justified.
New requirements for NEMT drivers
Beginning July 1, NEMT drivers who work for an agency must obtain a National Provider Identifier, enroll individually in Medicaid and affiliate with their agency.
North Dakota’s revalidation strategy also calls for proof of vehicle registration and active insurance coverage, along with driver-license checks and other screening. The requirements are intended to give Medicaid a clearer record of each person delivering transportation services.
The changes affect drivers as well as agencies. An agency that remains enrolled may continue operating, but its drivers must meet the individual enrollment and documentation requirements as the new process is implemented.
Revalidation will continue through 2028
North Dakota’s strategy calls for NEMT provider revalidation to begin July 1, 2026, with all NEMT providers expected to complete the review by October 1, 2026.
Revalidation for 1915(i) providers is scheduled to begin October 1, 2026, with completion expected by May 1, 2027. QSP agency and individual revalidation is scheduled to begin January 1, 2027, and finish by June 1, 2028.
After the off-cycle reviews, NEMT, QSP and 1915(i) providers are expected to move from a five-year revalidation cycle to a three-year cycle. The strategy says dates will be assigned in a way that keeps providers within federal five-year requirements, and that full alignment with the three-year cycle will begin with the next revalidation period in 2029.
Some QSP and 1915(i) changes remain scheduled or conditional rather than fully in effect. The strategy calls for expanded individual enrollment, affiliation, site visits and competency-related requirements in later phases. Where administrative-code changes or other implementation steps are required, those steps must be completed before the requirements are fully integrated.
Who is included in the state’s review
The state strategy identifies QSP, NEMT and 1915(i) providers as service categories with operational vulnerabilities that warrant enhanced oversight. It does not classify them as federally designated high-risk provider types.
The strategy lists 254 QSP agencies and 1,221 QSP individuals among the targeted providers. It also lists 79 1915(i) groups and 412 1915(i) individuals. The strategy discusses provider capacity and risk statewide, including the possibility of service gaps in rural areas where fewer qualified home- and community-based providers may be available.
Why the state is increasing oversight
North Dakota Medicaid says the targeted services can be difficult to verify because they are often delivered in homes or community settings by independent contractors or small agencies. The state also cites inconsistent use of NPIs, limited outside credentialing and challenges confirming qualifications and service delivery.
The department’s strategy says North Dakota has not independently classified any provider type as federally “high risk.” Instead, the state identified QSP, NEMT and 1915(i) services as having operational vulnerabilities and program-integrity concerns that justify enhanced oversight.
KFYR-TV reported that North Dakota Health and Human Services received 38 referrals involving suspected fraud, waste or abuse in 2025, with four sent to the North Dakota Attorney General’s Medicaid Fraud Control Unit for further review or prosecution. Those figures describe referrals and reviews, not a finding that providers in the targeted categories generally engaged in wrongdoing.
What Medicaid patients and providers should do
Medicaid patients should generally be able to continue using providers that are currently enrolled. A moratorium is an enrollment pause, not an automatic termination of an existing provider.
If a transportation or care provider says it can no longer serve a patient, the patient or caregiver should ask whether the issue is an enrollment status, a revalidation request, a licensing or insurance problem, or a separate service-capacity issue. Patients should contact North Dakota Medicaid or their managed-care plan if they need help finding another enrolled provider or arranging necessary transportation.
Providers should watch for revalidation notices, keep enrollment information current and submit requested documentation by the stated deadline. NEMT agencies should confirm that each driver has the required NPI, individual Medicaid enrollment and agency affiliation, and that required license, vehicle-registration and insurance documentation is available.
North Dakota Medicaid says it will continue monitoring access, provider capacity and program-integrity needs as the six-month moratoria and the broader revalidation schedule move forward.
Sources
- North Dakota Medicaid Provider Enrollment Moratoria notice
- KFYR-TV: ND HHS tightens Medicaid provider oversight starting July 1
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