by Jose D. Roman | Mar 6, 2025 | Medicaid, Medicaid Planning
Since President Donald J. Trump’s re-election, discussions about the future of Medicaid have intensified. In January 2025, the Trump administration temporarily paused federal financial assistance—sparking widespread uncertainty about Medicaid funding. Although the order was later rescinded, concerns over potential funding disruptions remain.
In February 2025, House Republicans narrowly passed a budget resolution proposing $4.5 trillion in tax cuts paired with $2 trillion in spending reductions over the next decade. Notably, the budget includes $880 billion in cuts to Medicaid, a figure that has ignited debates, even within the GOP. And let’s be clear in case you hear anyone saying Medicaid is safe – the nonpartisan Congressional Budget Office has stated that Republicans cannot meet their $880 billion target without resorting to drastic cuts to Medicaid. To understand what’s at stake, let’s examine how Medicaid is structured in New Jersey.
What Is Medicaid?
Medicaid is a joint federal and state program that offers free or low-cost health coverage to eligible low-income individuals and families. It covers a broad range of services—from doctor visits and hospital stays to prescription drugs, preventive care, mental health services, and long-term care. Each state administers its own Medicaid program within federal guidelines, which means eligibility requirements and covered services can vary. Medicaid primarily serves very low-income adults, children, pregnant women, seniors, and individuals with disabilities, ensuring that vulnerable populations have access to essential healthcare. In New Jersey, Medicaid is divided into several programs, each targeting specific groups and each with their own eligibility criteria.
A. NJ FamilyCare Medicaid
NJ FamilyCare is a Medicaid program that provides free or low-cost coverage to eligible New Jersey residents under age 65. It includes Medicaid, the Medicaid expansion under the Affordable Care Act (New Jersey is one of the states that has opted in by accepting federal funding), and the Children’s Health Insurance Program (CHIP). The expansion Medicaid component is widely expected to be targeted for cuts because it includes the often unfairly maligned Affordable Care Act Medicaid – the “Obamacare” expansion of Medicaid.
- Who Does NJ FamilyCare Medicaid Cover?
Adults aged 19 to 64 can access NJ FamilyCare if their household income is at or below 138% of the Federal Poverty Level/FPL (133% plus a 5% income disregard). This is incredibly low and many adult minimum wage workers find themselves ineligible for Medicaid. For example this is a mere $21,597 per year for an individual and $44,367 for an adult living in a household of four. Pregnant people and children have more generous eligibility limits at 205% FPL for pregnant people and up to 355% FPL for children. These categories all fall under the umbrella of Modified Adjusted Gross Income (MAGI) Medicaid and only consider income, not assets when determining eligibility. Therefore, anyone of working age who abruptly loses their income can apply and receive health coverage without consideration of their assets such as retirement savings.
- Who Will Be Impacted When NJ FamilyCare is Cut?
The answer is simple. Pregnant women, children and low wage-earning adults who don’t have access to or cannot reasonably afford high-cost employer sponsored coverage will take the brunt of the impact.
B. SSI Medicaid and “Medicaid Only”
Individuals in New Jersey who qualify for Supplemental Security Income (SSI) benefits (a basic income support program) are automatically enrolled in Medicaid ensuring that they have access to health coverage. In addition, the “Medicaid Only” program extends coverage to individuals who have income and resources under the SSI limits but don’t actually receive SSI payments.
- Who Does SSI Medicaid and Medicaid Only Cover?
SSI is a program that provides income support to seniors 65 and over, blind individuals, and disabled individuals who have zero or very low income. For 2025, eligible individuals with countable income below $967 per month and $2,000 or less in assets can qualify for SSI payments. For a couple the figures are $1,450 per month and $3,000 in assets. Essentially these are individuals with almost nothing in terms of basic income and assets who are living month to month.
- Who Will Be Impacted When SSI Medicaid and Medicaid Only is Cut?
The answer is pretty straightforward, though depressing. Seniors and individuals who have been found to meet the federal government’s standards for blindness and permanent disability, who have zero or very little income. Essentially the poorest senior citizens and the poorest individuals with disabilities may find themselves without access to essential health coverage when SSI Medicaid and Medicaid Only is cut.
C. Disabled Adult Child (DAC) Medicaid
Disabled Adult Child (DAC) Medicaid is specifically targeted toward individuals with disabilities, whose condition began before age 22. It allows them to retain Medicaid benefits even when their income suddenly exceeds SSI eligibility parameters.
- Who Does DAC Medicaid Cover?
Essentially the program allows individuals with disabilities, whose condition began before age 22, to maintain Medicaid coverage even if they become ineligible for SSI or Medicaid Only due to receiving Social Security Disability Insurance (SSDI) benefits based on a parent’s earnings record. This situation typically arises when a parent retires, becomes disabled, or passes away, triggering SSDI benefits for the adult disabled child. While the increase in income from SSDI may disqualify the individual from SSI, federal law ensures the continuation of Medicaid benefits for those who were previously eligible under SSI but have lost it due to SSDI benefits. This safeguard is crucial, as Medicaid often covers services and supports not provided by Medicare or private insurance, ensuring that individuals with disabilities continue to receive necessary care without interruption.
- Who Will Be Impacted When DAC Medicaid is Cut?
DAC Medicaid primarily benefits individuals with developmental and intellectual disabilities. However, since it impacts anyone whose condition began before the age of 22 it includes a wide variety of individuals struggling with physical, intellectual or mental disabilities. It’s sad but true – when this program is cut it will impact adult disabled individuals who have relied on Medicaid for most of their life.
D. Aged Blind Disabled (ABD) a/k/a Special Medicaid Program
In New Jersey, the Aged, Blind, and Disabled (ABD) Medicaid program, also known as Special Medicaid, provides supplemental healthcare coverage to seniors and individuals with disabilities who receive Medicare benefits. The program pays Medicare premiums, covers Medicare co-pays and deductibles, and offers services not covered by original Medicare Part A and B such as dental coverage.
- Who Does ABD/Special Medicaid Cover?
The program is open to low income individuals who are 65 years or older, blind or disabled and also receive Medicare. The income limits for ABD Medicaid are based on the Federal Poverty Level (FPL). As of 2025, the income limit is 100% of the FPL, which is $1,304 for an individual and $1,763 for a married couple. The program also has asset limits: for individuals, the limit is $4,000, and it is $6,000 for couples.
- Who Will Be Impacted When ABD/Special Medicaid is Cut?
Retired seniors with low income who are living month to month on social security will be impacted significantly. Essentially this will punish retired individuals who worked in low wage jobs. It will also impact low income blind and disabled individuals who receive Medicare. It is sad as these individuals living off of less than $2000 per month will now need to figure out how to pay additional healthcare expenses, including Medicare premiums, co-pays and deductibles, and essential non-covered services such as dental and home health aides. Many will forego essential medical care altogether due to the cost.
E. NJ Workability
NJ WorkAbility is a program that enables employed individuals with disabilities to obtain comprehensive Medicaid coverage. The program has generous limits compared to other Medicaid programs. Essentially it was designed to encourage individuals with disabilities to work without fear of losing their health insurance.
- Who Does NJ WorkAbility Medicaid Cover?
Eligibility for NJ WorkAbility Medicaid was recently expanded and is now relatively simple. You must be a New Jersey resident, have a disability determination by the Social Security Administration or the State, and have proof of employment. The program does not specify a minimum number of work hours or earnings to qualify, so even individuals with small part-time or irregular jobs can qualify as long as there is proof of employment. The program does not have an asset limit and does not count a spouse’s income. People with countable income above 250% FPL may have to pay a premium on a rising scale.
- Who Will Be Impacted When NJ WorkAbility Medicaid is Cut?
Working individuals with disabilities will lose insurance or have increased insurance and healthcare costs when NJ WorkAbility is cut. This is unfortunate, especially when the people advocating for Medicaid cuts often claim that Medicaid recipients choose not to work so they can keep public benefits.
F. Managed Long Term Services and Supports (MLTSS) Medicaid
Managed Long Term Services and Supports (MLTSS) is a New Jersey Medicaid program designed to provide comprehensive long-term care services to individuals who require assistance due to age, disability, or chronic illness. MLTSS covers services beyond those offered by standard Medicaid, including nursing home care, home and vehicle modifications, home-delivered meals, and assisted living services.
- Who Does MLTSS Medicaid Cover?
Because Medicare does not cover long term care such as nursing home care, qualifying for Medicaid is typically the only way most people can pay for these services. However, this program is extremely complicated, and many individuals hire a lawyer when applying for the program. The application process includes a “five-year lookback,” which is a detailed examination of the income and assets of the applicant and their spouse in the prior 60-month period. To be eligible, an individual applicant’s monthly income must not exceed $2,901 (2025) and countable assets are limited to $2,000. The application process includes looking at a married couples combined assets even if they are not jointly owned. The application often will need to spend down assets in order to meet the $2000 limit. The non-applicant spouse may also need to spend down assets because the amount he or she can retain is limited to between $31,584 and $157,920. These guidelines are meant to ensure that poor and middle-class individuals have access to essential long-term care services while maintaining some financial stability.
- Who Will Be Impacted When MLTSS Medicaid is Cut?
With nursing care often costing in excess of $10,000 per month MLTSS Medicaid and similar programs throughout the county has become the backbone of our long term care system. Any cuts to this program will cause significant disruption to people in need of nursing home, assisted living or similar services at home.
Final Thoughts
The proposed Medicaid cuts could have far-reaching consequences for some of our most vulnerable citizens. In New Jersey, each Medicaid program serves a critical role—from providing essential coverage to low-income adults, pregnant individuals, and children to supporting seniors and those with disabilities. Drastic reductions in Medicaid funding would not only undermine healthcare access but also exacerbate financial insecurity for many families.
by Jose D. Roman | Feb 25, 2025 | Medicaid, Medicaid Planning, Trusts
Planning for the financial future of individuals with disabilities can often be challenging, especially when trying to maintain eligibility for essential public benefits. In New Jersey, ABLE accounts provide a solution that empowers individuals with disabilities and their families to save money without jeopardizing their eligibility for benefits such as Medicaid and Supplemental Security Income (SSI). Let’s explore what NJ ABLE accounts are, who qualifies, their benefits, and how they differ from Special Needs Trusts.
What Are NJ ABLE Accounts?
NJ ABLE accounts are tax-advantaged savings accounts established under the federal Achieving a Better Life Experience (ABLE) Act of 2014. These accounts are designed to help individuals with disabilities and their families save for disability-related expenses while protecting their eligibility for means-tested government programs.
Funds in an ABLE account can be used to pay for “qualified disability expenses,” which include costs related to education, housing, transportation, employment training, assistive technology, personal support services, funeral expenses, and health and wellness, among others.
To learn more about NJ ABLE accounts, visit NJ ABLE.
Eligibility Requirements for NJ ABLE Accounts
To open an NJ ABLE account, individuals must meet specific criteria:
- Disability Onset Before Age 26: The individual’s disability must have begun before their 26th birthday.
- Eligible Disability: The individual must have a qualifying disability as defined by the Social Security Administration (SSA) or blindness.
- U.S. Residency: The account holder must be a U.S. citizen or legal resident.
If someone qualifies, only one ABLE account is permitted per individual. However, family members and friends can contribute to the account.
Benefits of an NJ ABLE Account
- Maintain Public Benefits Eligibility:
- Medicaid: Funds in an ABLE account are not counted as resources when determining Medicaid eligibility.
- SSI: Up to $100,000 in an ABLE account is excluded from SSI resource limits. If the balance exceeds $100,000, SSI payments may be suspended until the balance no longer exceeds the limit, and Medicaid eligibility is preserved.
- Tax Advantages: Earnings on funds in the ABLE account grow tax-free. Withdrawals for qualified disability expenses are also tax-free.
- Financial Control and Independence: Individuals with disabilities can manage their own accounts, fostering greater financial independence.
- Broad Range of Uses: The account can cover a variety of disability-related expenses, enhancing the quality of life and long-term planning.
- Family Contributions: Family members, friends, and employers can contribute to an ABLE account, up to the annual federal gift tax exclusion amount (currently $19,000 in 2025). With the ABLE to Work Act, employed individuals with disabilities can contribute additional funds beyond the annual limit.
- Significant Savings: The current account balance limit is $305,000.00. This allows individuals who do not receive SSI to save even more.
NJ ABLE Accounts vs. Special Needs Trusts
While both ABLE accounts and Special Needs Trusts (SNTs) serve individuals with disabilities, they have key differences:
- Eligibility:
- ABLE accounts require the onset of disability before age 26, whereas SNTs do not have this restriction.
- First party SNTs must be established before the individual reaches the age of 65. There is no such restriction for ABLE accounts.
- Control: ABLE accounts are managed directly by the individual with a disability or an authorized legal representative. SNTs are controlled by a trustee.
- Contributions and Limits:
- ABLE accounts have an annual contribution limit ($19,000 in 2025) and a total cap tied to state 529 plan limits (in NJ, $305,000).
- SNTs have no annual contribution or total balance limits but must comply with complex legal and tax requirements.
- Usage Restrictions: ABLE accounts may be used for anything that helps a person with a disability improve their quality of life, while SNT funds may not be used to cover benefits paid for by a public assistance program.
How NJ ABLE Accounts Protect Public Benefits
For individuals receiving SSI or Medicaid, maintaining strict resource limits is crucial. Without tools like ABLE accounts, individuals are often unable to save more than $2,000 in personal assets without risking benefit eligibility. NJ ABLE accounts provide a way to build savings well above this threshold while ensuring compliance with program rules.
Additionally, an ABLE account can reduce reliance on credit or loans, allowing individuals to meet unexpected costs with funds already set aside. This fosters greater financial stability and reduces long-term financial stress.
Conclusion
NJ ABLE accounts offer a powerful tool for financial security and independence for individuals with disabilities. By allowing individuals to save and invest in their future without fear of losing essential benefits, these accounts provide a critical benefit for long-term financial planning. Whether you’re a person with a disability, a family member, or a caregiver, understanding and utilizing a NJ ABLE account can be a transformative step toward a more secure and fulfilling life.
by Jose D. Roman | Feb 8, 2025 | Medicaid, Medicaid Planning, Trusts
Supplemental Security Income (SSI) is a federal program that provides basic income support to individuals who are over the age of 65, are blind, or have been determined disabled by the Social Security Administration (SSA). In New Jersey, SSI recipients are automatically enrolled in Medicaid, which ensures access to essential medical services. This seamless integration creates a vital safety net for vulnerable populations who need extra financial and healthcare support.
In this post, we’ll break down what SSI Medicaid is in New Jersey and explain the eligibility rules—including income and asset requirements.
What is SSI Medicaid in New Jersey?
SSI Medicaid provides healthcare coverage to those who qualify for federal SSI benefits. Because New Jersey is designated as a “1634 state,” SSI recipients are automatically enrolled in Medicaid without needing to complete a separate application. This automatic enrollment guarantees that vulnerable residents have access to comprehensive healthcare services as soon as they become eligible for SSI.
Eligibility Criteria
To qualify for SSI Medicaid in New Jersey, applicants must meet the following federal SSI requirements:
1. Categorical Requirements
- Age: 65 or older,
- Vision: Blind,
- Disability: Have a qualifying disability as defined by the Social Security Administration.
2. Financial Requirements
- Income: Must fall within prescribed monthly thresholds.
- Assets: Must remain below specific limits.
3. Residency and Citizenship
- Residency: Must be a resident of New Jersey.
- Citizenship: Must be a U.S. citizen or have lawful non-citizen status.
Income and Asset Requirements
SSI Medicaid eligibility is closely tied to both income and asset levels, ensuring that benefits are directed toward those with truly limited financial resources.
In New Jersey, for 2025, income must not exceed $967 per month for an individual, and $1,450 per month for a married couple. Countable income includes not only traditional wages but also other sources of income such as pensions, Social Security benefits, or even certain types of assistance. It’s important to note that while many forms of income count toward these limits, there are also specific exclusions built into the system. For example, a modest portion of earned income is partially disregarded to encourage self-sufficiency. This means that not every dollar earned by a beneficiary will be counted on a one-to-one basis toward the income limit.
In tandem with income restrictions, asset limits are a critical factor in SSI Medicaid eligibility. For an individual, countable assets must remain below $2,000, and for couples, the threshold is set at $3,000. Here, “countable assets” refer to cash, bank accounts, stocks, and other financial resources that could be converted to cash. However, the program recognizes that certain assets are essential for an individual’s day-to-day life and therefore exempts them from consideration. For instance, the primary residence is excluded from the asset calculation up to an equity value of $1,033,000, ensuring that having a home does not disqualify someone from receiving assistance. Similarly, one vehicle is exempt—so owning a car, which is often necessary for transportation to medical appointments or work, does not negatively impact eligibility. Personal property, including household goods and certain burial funds (up to $1,500), are also not counted.
Strategies to Maintain Eligibility
Maintaining eligibility for SSI Medicaid requires ongoing attention to financial details and proactive planning. Beneficiaries can use a variety of strategies to protect their benefits while working toward greater financial independence. Below are some key strategies:
1. Timely Reporting of Changes
One of the most critical aspects of maintaining eligibility is promptly reporting any changes in your circumstances to both the Social Security Administration (SSA) and New Jersey Medicaid. This includes changes in income, marital status, residency, or asset levels. Keeping these agencies updated helps avoid overpayments, penalties, or even termination of benefits.
2. Avoiding Improper Asset Transfers
It can be tempting to make gifts or transfer assets to a family member, but doing so without proper planning can lead to penalties or periods of ineligibility. Transferring assets at below-market values or without appropriate legal guidance can count against you. Before making any such transfers, it’s wise to consult with a legal expert or benefits counselor.
3. Creating a Special Needs Trust (SNT)
A Special Needs Trust is a powerful tool for individuals who wish to preserve their eligibility for SSI Medicaid while setting aside funds for future needs. By placing assets into an SNT, beneficiaries can ensure that these resources are used for supplemental purposes (such as education, therapy, or unforeseen medical expenses) without counting toward the asset limits. This trust is carefully structured so that while the funds are available to enhance quality of life, they do not disqualify an individual from receiving benefits.
4. Monitoring Income and Savings
Regularly reviewing your income sources and savings is crucial. Even small changes in earnings—whether from part-time work, inheritances, or other windfalls—can push you over the eligibility thresholds. Establishing a budgeting strategy and working with a financial advisor familiar with SSI rules can help you plan effectively and avoid unintentional disqualifications.
5. Utilizing Work Incentives Wisely
For those able to work, taking advantage of the work incentives offered under SSI is a great way to boost income while safeguarding benefits. However, it is important to plan carefully. Make sure to keep track of how much you earn each month and consult with a benefits counselor to understand how your work might affect your eligibility. Programs like the trial work period can provide a buffer as you transition into employment, but adherence to reporting guidelines remains essential.
6. Professional Guidance
Given the complexity of the rules surrounding SSI Medicaid, partnering with professionals—a Medicaid planning attorney, benefits counselor, or financial advisor—can be invaluable. These experts can help you navigate the nuances of income limits, asset management, and work incentives while ensuring you remain in compliance with all reporting requirements.
By incorporating these strategies into your financial planning, you can help secure your SSI Medicaid benefits and maintain a safety net for essential healthcare coverage.
Key Considerations
- SSI vs. SSDI:
Remember that SSI is a needs-based program, while Social Security Disability Insurance (SSDI) is based on work history. Medicaid rules differ between the two programs.
- NJ FamilyCare:
SSI Medicaid is part of New Jersey’s broader Medicaid initiative, NJ FamilyCare, which aims to provide comprehensive healthcare coverage to all eligible residents.
Conclusion
SSI Medicaid in New Jersey offers a lifeline for those who need extra financial and healthcare support. By understanding the intricacies of income and asset rules and staying informed about work incentives and reporting requirements (a topic for another day), beneficiaries can maintain uninterrupted coverage while exploring opportunities to improve their financial independence. If you’re facing complex situations—whether it involves asset management or navigating the work rules—it’s wise to consult with a Medicaid planning attorney or a benefits counselor.
Navigating SSI Medicaid can be challenging, but with the right information and careful planning, you can secure the benefits you need to ensure your well-being and move toward greater self-sufficiency.
by Jose D. Roman | Jan 28, 2025 | Irrevocable Family Trusts, Legal Bulletin, Medicaid, Medicaid Planning, Trusts
In a recent Superior Court of New Jersey, Appellate Division decision, W.F. v. Morris County Department of Family Services, the court reversed the imposition of a Medicaid transfer penalty for funds placed in trust to meet future child support obligations.
Background of the Case
The case involved W.F., an incapacitated individual living in a Care One nursing home due to a long-term alcoholism-related disease. Years before his incapacitation, W.F. entered into a property settlement agreement (PSA) during his divorce, agreeing to pay $23,400 annually in child support and cover half of his children’s future college expenses.
As W.F.’s financial situation deteriorated, his assets became insufficient to cover both his nursing home debts and child support obligations. To ensure his children received the necessary support, an irrevocable Family Trust was established with the approval of the court. This led to a dispute with the Morris County Department of Family Services regarding the classification of these trust funds in the context of Medicaid eligibility. When considering his eligibility for long-term Medicaid (MLTSS), the County argued that the transfer of funds to the trust was improper and imposed a 190 day transfer penalty.
Legal Arguments and Court’s Analysis
The County considered the funds in the Family Trust to be W.F.’s available assets or money he could have used to pay for his care. The County further found the transfer to the Trust for his children to be an improper gift for the purpose of qualifying him for Medicaid. As a result the improper transfer/give resulted in a period of ineligibility for Medicaid benefits, that is, a transfer penalty. However, W.F.’s guardian challenged the imposition of a penalty, arguing that the child support payments were legitimate, court-ordered debts and should not be treated as voluntary transfers.
The Appellate Division examined several key points:
- Definition of Available Resources: Under N.J.A.C. 10:71-4.1(b), resources include any property that can be converted to cash for support and maintenance. Only resources that are “available,” meaning the individual has the right or power to liquidate them, are counted towards Medicaid eligibility. N.J.A.C. 10:71-4.1(c).
- Transfer Penalty Rules: N.J.A.C. 10:71-4.10(a) imposes a penalty if assets are transferred below fair market value during a look-back period (the 60-month period before the Medicaid application is filed). The presumption is that such transfers are made to qualify for Medicaid, unless proven otherwise by the applicant.
- Court-Ordered Transfers: The regulations specify that transfers ordered by a court, not acting at the individual’s behest, may indicate that the transfer was for purposes other than establishing Medicaid eligibility. N.J.A.C. 10:71-4.10(k).
Court’s Decision
The Appellate Division reversed the Division of Medical Assistance and Health Services’ (DMAHS) decision, which upheld the County’s imposition of the transfer penalty. The court found several faults in the DMAHS’s approach:
- Misinterpretation of Gifts: The court held that the transfer of assets to the Family Trust was not a gift by W.F. but a court-ordered reallocation to fulfill pre-existing child support obligations. This distinction is crucial because gifts imply voluntary transfer of assets, whereas court-ordered payments are mandatory and binding.
- Lack of Control Over Assets: W.F. had no control over the funds once they were placed in the irrevocable trust. The trial court, recognizing the children’s entitlement to support, ordered the division of W.F.’s assets accordingly.
- Erroneous Legal Standards: The Appellate Division found that DMAHS misapplied the legal standards of eligibility, and that its actions were unreasonable, arbitrary and capricious. The court emphasized that the allocation of assets to meet pre-existing child support obligations, as mandated by a divorce judgment, was clearly not a gift under the circumstances of this case.
Final Thoughts
By reversing the transfer penalty, the court has once again shown that it favors upholding court-ordered support obligations versus strict interpretation of Medicaid regulations. This case will provide further guidance to Medicaid planning professional dealing with the issue of allocating competing debts and support obligations. It reinforces the principle that mandated child support payments are not gifts but essential support mechanisms protected by law.
by Jose D. Roman | Jan 27, 2025 | Legal Bulletin, Medicaid, Medicaid Planning, Medicaid Updates
The New Jersey Department of Human Services, Division of Medical Assistance and Health Services issued Medicaid Communication No. 25-01 on December 24, 2024. The document includes updates to certain eligibility and post-eligibility calculations, and reflects a 2.5% federal cost-of-living adjustment (COLA) for SSI eligibility standards.
Notable changes effective January 1, 2025, include:
- Assisted Living Residence (ALR) and Comprehensive Personal Care Home (CPCH): Monthly room and board rates set at $973.40, with a maintenance needs allowance of $143.65.
- Adult Family Care (AFC): Monthly room and board rates set at $854.60, with a maintenance needs allowance of $143.65.
- Community Spouse Resource Allowance: Minimum increased to $31,584; maximum raised to $157,920.
- MLTSS Income Cap/Living at Home Monthly Standard: Increased to $2,901.
- In-kind Support Income Amounts: Updated to $342.33 for individuals and $503.33 for couples.
For full details on eligibility calculations, refer to the updated administrative manual sections (N.J.A.C. 10:71-4.8, 5.4-6, and 5.9). Practitioners should be mindful of these changes and update staff to ensure clients receive the most up to date advice. Read the full document here.