New Jersey Health Care Service Firm Registration Requirements

Highlights

• New Jersey's Health Care Service Firm (HCSF) registration framework imposes compliance obligations that affected organizations should review in light of recent guidance from the Division of Consumer Affairs, including requirements for annual financial statements, accreditation and bonding.
• Recent legislation has changed the annual registration deadline from June 30 to September 30, with current registrations now expiring September 30, 2026.
• The Division has suspended enhanced financial reporting requirements while it updates its regulations, though HCSFs must still submit the standard annual financial statement.

New Jersey's Health Care Service Firm (HCSF) registration framework creates certain compliance obligations for businesses that provide healthcare, personal care or companion services. Recent legislative and regulatory changes – including updates to financial reporting requirements and renewal deadlines – may prompt affected HCSFs to take a fresh look at their compliance, registration and renewal processes.

This Holland & Knight alert provides an overview of the HCSF registration framework, summarizes recent developments, and highlights key considerations for organizations seeking to obtain or maintain HCSF registration in New Jersey.

Scope of HCSF Registration

Under New Jersey law,¹ the HCSF registration requirement applies broadly to entities that:

• employ or engage individuals to provide healthcare, personal care or companion services (collectively, Covered Services)
• place or arrange for the placement of individuals to provide Covered Services
• otherwise refer individuals to Covered Services

Covered Services may be provided either directly in the homes of individuals with disabilities or adults aged 60 or older, or at caregiving facilities.²

An entity generally qualifies as an HCSF if it directly or indirectly employs workers for the purpose of assigning them to provide Covered Services, maintains employment-related insurance and tax obligations, and remains responsible for those workers' conduct. Notably, the registration requirement applies to HCSFs located within and outside New Jersey if they provide Covered Services in the state.³

Registration Process

To register, HCSFs must submit an application through New Jersey's Regulated Business Licensure Portal. On average, the Division of Consumer Affairs (Division) processes applications within 30 days to 60 days.

As part of the application process, an applicant must:⁴

• disclose the HCSF's ownership, management and operating locations
• provide criminal history certifications for owners, officers and principals
• maintain a $10,000 surety bond (unless eligible for a net-worth-based waiver)
• disclose healthcare licenses held in other states, along with any disciplinary or enforcement actions

The annual registration fee is $500 for each primary location.⁵

Once registered, an HCSF must timely notify the Division of changes to ownership, management, criminal history disclosures and other information in its application.

HCSFs must renew their registration annually. As part of the renewal, HCSFs must update ownership, location, licensure and compliance information, as well as maintain the required $10,000 surety bond unless exempt.⁶

HCSFs must also obtain accreditation from a New Jersey Department of Human Services-recognized accrediting body within 12 months after initial registration and maintain that accreditation going forward.⁷ Any loss of accreditation must be reported to the Division within 10 days.⁸

Recent Developments

On July 22, 2026, Gov. Mikie Sherrill signed Public Law (P.L.) 2026, c.45 into law, modifying certain HCSF financial reporting requirements. Key changes include:

• Financial Reporting Requirements Suspended. The Division has suspended the audit and enhanced financial reporting requirements under N.J. Admin. Code 13:45B-13.5A(b)-(e), which previously imposed additional obligations on certain HCSFs based on Medicaid personal care attendant (PCA) revenue and gross income. The suspension will remain in effect while the Division updates its regulations.
• New Registration Deadline. The annual registration expiration date has changed from June 30 to September 30. Current registrations now expire September 30, 2026, and HCSFs that already renewed for 2026-2027 will be automatically extended to September 30, 2027.

Even with the enhanced reporting requirements suspended, HCSFs must still submit the annual financial statement required by N.J. Admin. Code 13:45B-13.5A(a), summarizing assets, liabilities, gross income, operating expenses and Medicaid PCA revenue. HCSFs should continue to monitor Division guidance for updates on implementation of P.L. 2026, c.45.

Practical Takeaways for HCSFs

Organizations that qualify as HCSFs should review their current registration and compliance processes in light of the Division's recent guidance. In particular, HCSFs should confirm they are meeting ongoing requirements for annual financial statements, accreditation and bonding, as well as monitor future Division guidance as New Jersey implements P.L. 2026, c.45 and updates its HCSF regulations.

Footnotes

1. N.J. Stat. Ann. 34:8-45.1 and N.J. Admin. Code 13:45B-13.2.

2. N.J. Stat. Ann. 34:8-45.1 and N.J. Admin. Code 13:45B-13.2.

3. N.J. Admin. Code 13:45B-13.1(c).

4. N.J. Admin. Code 13:45B-13.3.

5. N.J. Admin. Code 13:45B-7.1.

6. N.J. Admin. Code 13:45B-13.5(a).

7. N.J. Stat. Ann. 34:8-45.1.

8. N.J. Admin. Code 13:45B-13.5.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.