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New Jersey Enacts Medicaid Employer Assessment

September 09, 2026
Employee Benefits Employee Benefits Compliance
2 min read
Regulatory & Legislative Strategy Group
New Jersey Enacts Medicaid Employer Assessment

Table of Contents

    Key Takeaways

    • New Jersey has enacted the New Jersey Medicaid Employer Assessment that will require employers with 50 or more employees enrolled in New Jersey Medicaid to pay a fee for each employee and dependent enrolled in New Jersey Medicaid.

    • The fee amount per employee and dependent will vary based upon the number of employees enrolled in New Jersey Medicaid.

    • The New Jersey Department of Treasury will notify covered employers of their initial assessed fee amount by March 1, 2027. Employers must remit this first fee payment by April 15, 2027.

    New Jersey recently enacted a new law (Bill A5324) establishing the New Jersey Medicaid Employer Assessment which will require covered employers to pay a fee for each employee and dependent covered under New Jersey Medicaid. This law applies to employers with 50 or more employees enrolled in New Jersey Medicaid, including private employers and potentially public employers (regardless of employer location).

    Fee Assessment, Amount, and Due Date

    Covered employers will be notified annually on or before March 1st of the fee amount assessed to the employer. Although the fee itself varies depending on the number of employees covered by Medicaid (not including dependents), the fee is assessed with respect to each employee and each dependent that is covered by Medicaid, as follows:

    • 50 – 249 employees who receive benefits through Medicaid = $325 per employee and per dependent who receives Medicaid benefits
    • 250 – 499 employees who receive benefits through Medicaid = $525 per employee and per dependent who receives Medicaid benefits
    • 500 or more employees who receive benefits through Medicaid = $725 per employee and per dependent who receives Medicaid benefits

    The fee (and any corresponding information to be filed) will be due to the State by April 15 of each year. Covered employers will pay the first assessed fee on April 15, 2027 (the State will provide notice to the employer of the fee amount by March 1, 2027). If an employer disagrees with the assessment, they will have the right to file an appeal with the New Jersey Department of Labor and Workforce Development.

    Employee Exemptions

    Currently, the fee will not be assessed for employees and dependents with a developmental disability, intellectual disability, or a permanent physical disability who enrolled in Medicaid. Additionally, as of July 1, 2027, additional exemptions will apply for (1) employees who have been employed for less than 90 days at the time the fee is determined and (2) employees who are part-time, per diem, seasonal, or temporary.

    Employer Action

    Employers with larger employee populations in New Jersey should begin budgeting for any potential financial exposure due to these fees. The administrative process underlying the fee assessment is still being developed and currently there are no employer notice or reporting requirements. Employers should continue to monitor developments to the New Jersey Medicaid Employer Assessment and begin preparing for the potential fee payment due by April 15, 2027.

    Please contact your Brown & Brown team with any questions or learn more about Brown & Brown's comprehensive compliance support using our secure form.