A new Colorado law removes a long-standing tool brokers have used to limit how many Medicaid trips small transportation providers can accept.
Most Colorado transportation and trucking owners have never heard of HB1328. But if your company operates Medicaid nonemergency medical transportation (NEMT) services—or competes with providers who do—this bill contains a provision that directly affects your revenue and operational freedom starting July 1, 2026.
The provision is buried in Section 2, §25.5-1-802(10)(b), on page 5 of the bill. Here's what it does in plain terms: Colorado's Department of Health Care Policy and Financing must adopt rules that prohibit trip caps and market-share restrictions on small NEMT providers. In other words, brokers and the state can no longer limit how many Medicaid transportation trips a small provider can accept—with one narrow exception.
Historically, brokers managing Medicaid NEMT contracts have used trip caps as a primary mechanism to control which providers get work and how much revenue they can earn. A broker might tell a small transportation company: "You can accept up to 50 trips per month, no more." This suppresses competition, locks in lower rates, and keeps small operators dependent on broker goodwill.
HB1328 removes that power. Starting July 1, 2026, the state rules must prohibit these caps entirely—meaning a small provider cannot be artificially limited in the number of trips they can accept based on arbitrary broker decisions or market-share allocation schemes.
There is one exception: the state may impose trip caps as corrective action. But this can only happen if a provider has documented performance failures, and the state must provide prior written notice. The cap must be time-limited and tied to fixing a specific problem—not used as a general control mechanism.
For small transportation companies, this is significant. It removes a structural barrier to growth and revenue. If your operation meets service standards, you can now accept more work without hitting an artificial ceiling imposed by a broker or the state.
This applies to small NEMT providers contracting with Colorado's Medicaid program. If your company is larger or operates outside the Medicaid NEMT space, the rule doesn't directly apply. But if you're in this market, or considering entering it, the landscape changes on July 1, 2026.
Brokers and larger providers should also pay attention. The rule shifts leverage toward smaller operators and may require changes to how contracts are structured and trips are allocated.
If you operate NEMT services in Colorado, review your current broker agreements and state contracts. Understand what trip caps or restrictions currently apply to your operation. When the Department of Health Care Policy and Financing publishes its rules implementing this provision—which must happen before July 1, 2026—those rules will define exactly how the prohibition works and what "small provider" means in this context.
Mark your calendar for July 1, 2026. That's when the new rules take effect.
Source: Colorado HB1328, Section 2, §25.5-1-802(10)(b), effective July 1, 2026.