New Jersey health care service firms should take a close look at the financial reporting documents they must submit when renewing their registration with the New Jersey Division of Consumer Affairs. Recent rulemaking and agency guidance make clear that every health care service firm must now submit an annual financial statement with its renewal.
Annual financial statements are now required
If a firm generated more than $10 million in gross income in any year, that year’s financial statement needs to be audited and submitted with registration renewal the following year. If a firm received more than $250 thousand in NJ Medicaid Personal Care Assistance during 2025, their 2025 financial statement also needs to be audited. Additionally, for these firms, their financial statements need to be audited every third year thereafter.
For firms that don’t meet these requirements, there is no required accountants report that must accompany the submitted financial statement. If a firm is unable to prepare a financial statement internally, choosing which accountants report is correct for your firm may be confusing. Accountants can issue three types of financial statement reports: audits, reviews, and compilations. Audits provide the highest level of assurance and are the most comprehensive and costly option. Reviews offer a lower level of assurance at a reduced cost, while compilations provide no assurance and are generally the least expensive.
Another CPA Prepared Report
For some firms, the annual financial statement will not be enough. If your firm received less than $250 thousand in NJ Medicaid Personal Care Assistance, and generated between $1 million and $10 million in gross income, the rules require an additional report from a CPA regarding certain financial transactions and business relationships.
Unfortunately, the requirements for this report, as described by the Division of Consumer Affairs are vague and may be difficult for CPAs not familiar with health care service firms to complete. Additionally, CPAs that don’t routinely provide assurance would be subject to additional scrutiny if they were to prepare such a report. This will limit which CPAs are able to provide this report at a reasonable cost.
Updated renewal timing matters
The Division has announced that health care service firm registrations now expire on September 30, and renewal applications must be submitted before October 1 each year together with any required financial statements, audits, or reports. That extended timeline may give firms additional time to coordinate with accountants, but it also raises the importance of early planning. A delay in assembling the required financial materials could put a firm’s renewal at risk.
Practical takeaway for providers
Health care service firms that operate in New Jersey should not treat their registration renewal as a routine filing. The new framework requires annual financial statements from all firms and may require CPA-prepared audits or other reports for firms that meet specific thresholds. Providers should review the current rules, confirm which filing category applies to their business, and begin working with a CPA familiar with healthcare service firms and the new reporting requirements early enough to avoid last-minute problems when renewing their registration with the New Jersey Division of Consumer Affairs.
Act Now to Stay Compliant
Taking a proactive approach now can help avoid last-minute challenges and ensure a smooth renewal process. Don’t risk delays or compliance issues with your upcoming renewal. Contact Henna Reit at Smolin today to review your requirements and get ahead of New Jersey’s health care service firm reporting deadlines.
Email hreit@smolin.com or call 732-978-4181.
