The New Jersey Legislature recently approved Senate Bill 3463, amending P.L.2002, c.126 (N.J.S.A. § 34:8-45.1), to revise the audit and financial reporting requirements applicable to health care service firms. The law continues to require any entity that employs, places, or refers individuals to provide companion, health care, or personal care services in the homes of individuals who are disabled or age 60 or older to register as a health care service firm and comply with the requirements of the Division of Consumer Affairs (Division) unless the entity is already licensed as a home health care agency or hospice.
The bill raises the Medicaid Personal Care Assistance reimbursement threshold that triggers an annual audit from $250,000 to $500,000. Required audits must now be submitted by September 30 of the calendar year in which they are due. The bill also expands the reporting requirements for firms with less than $10 million in gross revenue. Previously, reporting obligations differed depending on whether the entity’s revenue was $1 million or more, but less than $10 million.
For firms receiving less than $500,000 in Medicaid Personal Care Assistance reimbursements and generating less than $10 million in gross income, the bill replaces the requirement for an independent third-party practitioner review with a requirement for a detailed annual report containing specified information regarding insurance coverage, litigation, regulatory actions, independent contractors, and significant transactions.
The bill also authorizes the Division to permit a firm to submit and implement a corrective action plan before taking certain enforcement actions related to financial reporting deficiencies or concerns regarding the firm’s financial viability. In addition, required audits may now be performed by a certified public accountant (CPA) licensed in any US jurisdiction rather than only by a New Jersey-licensed CPA. The bill became effective immediately upon adoption on July 22, 2026.
McCarter’s Health care group monitors legislation in New Jersey affecting the health care industry. The team is available to assist clients in evaluating how newly adopted laws and regulations may affect their operations.