Key Takeaways
Impacted Employers: Employers with 50 or more Medicaid beneficiaries
Key Dates:
- Enforcement date: July 1, 2026.
- Notification date: On or before March 1 of each year, employers will be notified of their fee and filing information. Employers must pay the fee by April 15.
- Beginning July 1, 2027, certain types of employees will be excluded from fee calculations.
Summary: Covered employers must pay a fee for employees and their dependents who receive New Jersey Medicaid benefits.
Next Steps: Look for communications from the state regarding fee assessments and processing.
The Details
New Jersey has enacted legislation, Assembly Bill 5324, which requires certain employers whose employees receive benefits through the New Jersey Medicaid program to pay fees to help defray program costs. The assessment will be enforced as of July 1, 2026.
Covered Employers
Under the law, the following employers must pay these fees for each covered employee and dependent receiving New Jersey Medicaid benefits :
- 50-249 employees that receive Medicaid benefits: $325 per person
- 250-499 employees that receive Medicaid benefits: $525 per person
- 500 or more employees that receive Medicaid benefits: $725 per person
Note: An employer is not required to pay the fee for any employee or a dependent of the employee who has a disability.
Exemptions
Beginning July 1, 2027, part-time, per diem, temporary, and seasonal employees, or employees who are employed for fewer than 90 days, will not be included for coverage purposes when calculating the number of employees receiving Medicaid benefits.
The law will provide a credit/refund for fees paid before July 1, 2027, for the above employees who would have qualified for this exemption prior to July 1, 2027. See the text of the law for further details.
Notice
Employers will receive a notice from the New Jersey Division of Revenue and Enterprise Services (the Division) on or before March 1 of each year, indicating the number of employees and dependents receiving Medicaid benefits, and notifying the employer that they must:
- Pay the fee (through an electronic method specified by the Division, which may include electronic funds transfer, payment card, or any other electronic method approved by the Division); and
- File the required information for payment processing and tracking. Filing information must be submitted over the Internet or through any other electronic method approved by the Division.
Note: All payments and filings are due on or before April 15.
Nondiscrimination
Under the law, employers cannot use information about a candidate's status as a state Medicaid beneficiary when making decisions about offering or retaining employment.
Note: The New Jersey Civil Rights Act also protects applicants from adverse employment decisions under the law.
Recordkeeping
Under the law, individually identifiable information about an employee (or dependent) who receives state Medicaid benefits is confidential and privileged. See the text of the law for further details.
Penalties
Employers may face penalties for failing to pay the fee or for improperly classifying employees to avoid the fee. See the text of the law for details on penalties, the appeals process and refunds.
Next Steps
Look for communications from the state regarding fee assessments and processing.