New Jersey News: Heath Care Service Firm Registration Update

According to the New Jersey Division of Consumer Affairs, all Health Care Service Firm (HCSF) registrations will now expire on September 30, 2026, instead of June 30. Additionally, renewal applications must be submitted before October 1 each year, along with any required financial reports, statements, or audits that are required to be submitted as a condition of renewal. HCSFs that have already renewed their registration for 2026-27 will be automatically extended to September 30, 2027, and will be issued a registration with the new expiration date. The division intends to amend N.J.A.C. 13:45B-13.5 to effectuate this change. ​

This extension provides additional time to work with your CPA to compile the documentation required under the HCSF financial reporting law that applies to this renewal. 
 
Audit requirements 
As a reminder, under current law an HCSF is required to submit an audit, in addition to a financial statement, if it: 
 
Received more than $250,000 for the provision of NJ Medicaid Personal Care Assistance in 2025 

• An audit must be submitted every three (3) years. 

• For HCSFs registered prior to July 1, 2022, an audit is due 2026, 2029, 2032, etc. 

• For HCSFs registered after July 1, 2022, an audit is due three years after initial registration and every three years thereafter.
  
  

Generated $10 million or more in gross income in a year. 
An HCSF is required to submit an audit after any year from when gross income was $10 million or more (i.e., a HCSF that generates $10 million or more in gross income each year will be required to submit an audit with each registration renewal. 
 
For more information, read the division’s FAQ about HCSF Financial Reporting Requirements. 
 
Toward a Legislative Solution: S3463 / A4790
The good news: Legislation has been introduced to help mitigate the negative effects of some of these onerous reporting requirements. 
S3463 / A4790 would modernize New Jersey’s financial reporting framework while maintaining accountability. 

Key reforms include: 

• Raising the Medicaid audit threshold from $250,000 to $500,000 

• Extending audit deadlines to September 30 

• Modernizing compensation reporting thresholds 

• Streamlining and clarifying reporting requirements 

• Allowing corrective action opportunities 

• Permitting qualified out-of-state accountants to conduct audits 

This legislation represents a balanced, common-sense approach, reducing red tape without sacrificing oversight. 
 
Take Action 
HCAOA is actively advocating for passage of these reforms, but provider voices are critically needed. 
 
Please ask your New Jersey senator and assemblyperson to support these bills in their respective chambers. 
We encourage all New Jersey providers to stay informed, share their experiences, and act to support these much-needed reforms. If you have any questions, please contact HCAOA Director of Government Relations Allison Cramer or join our monthly Government Relations Office Hours. These informal drop-in sessions offer members an opportunity to ask questions, share challenges, and discuss policy and advocacy issues. 

UPDATE
The revised HCSF audit bill is now scheduled for a hearing before the Senate Health, Human Services and Senior Citizens Committee Monday, May 11 at 1 p.m. in Trenton.

The hearing is an opportunity to deliver relief from the financial reporting requirements that have generated widespread frustration. Provider presence at the committee hearing will carry real weight. Even a modest turnout from agency owners can send a powerful signal to legislators about the urgency of this issue. If you are able to attend, your voice matters.