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The effect of an arbitrary change of frame on the structure of turbulence models is examined from a fundamental theoretical standpoint. It is proven, as a rigorous consequence of the Navier-Stokes equations, that turbulence models must be form invariant under arbitrary translational accelerations of the reference frame and should only be affected by rotations through the intrinsic mean vorticity. A direct application of the invariance property along with the Taylor-Proudman Theorem, material frame-indifference in the limit of two-dimensional turbulence and Rapid Distortion Theory is shown to yield powerful constraints on the allowable form of turbulence models. Most of the commonly used turbulence models are demonstrated to be in serious violation of these constraints and consequently are inconsistent with the Navier-Stokes equations in non-inertial frames. Alternative models with improved non-inertial properties are developed and some simple applications to rotating turbulent flows are considered.