What New Jersey Telehealth and Virtual Care companies need to know about the October 15 registration deadline *Note: Deadline extended to January 3, 2022*

*Update October 15, 2021: Please note that the deadline for telehealth/telemedicine registry has now been extended to January 3rd*

If you're providing telehealth services in New Jersey, then this post will help you understand the requirements for registration of your business by October 15, 2021 [now January 3*]. We've even included a helpful to-do list at the end of this email. 

As always, if you need our help please contact us asap so we can help you meet this fast-approaching deadline.

Here are the details you need to know:

If you are a telehealth, telemedicine, remote patient monitoring, or other virtual care services provider or organization operating in New Jersey, then October 15, 2021 is an important deadline for you to know!

New Jersey's Registration and Reporting Rules for Telehealth and Telemedicine Organizations are now in effect. 

If you operate in New Jersey as a telehealth or telemedicine provider or organization exclusively, you are required to file a registration application with the New Jersey Department of Health which must be renewed annually. (N.J.A.C. 8:53). Under the law, a “telemedicine or telehealth organization” is defined as a “corporation, sole proprietorship, partnership, or limited liability company that is organized for the primary purpose of administering services in the furtherance of telemedicine or telehealth.” (N.J.S.A. 45:1-61).

Here, “telehealth” and “telemedicine” are broadly defined. “Telehealth” means "the use of information and communications technologies, including telephones, remote patient monitoring devices, or other electronic means, to support clinical health care, provider consultation, patient and professional health-related education, public health, health administration, and other services" (N.J.S.A. 45:1-61 et seq.).

“Telemedicine” is defined as "the delivery of a health care service using electronic communications, information technology, or other electronic or technological means to bridge the gap between a health care provider who is located at a distant site and a patient who is located at an originating site, either with or without the assistance of an intervening health care provider..." (N.J.S.A. 45:1-61 et seq.). This means that, in addition to traditional telehealth services, where an in-person healthcare visit is replaced by a virtual one, the New Jersey statute also covers virtual care management services like remote patient monitoring (“RPM”), chronic care management services (“CCM”), and even behavioral health integration services (“BHI”).   

How do I register as a Telehealth or Telemedicine organization in New Jersey?

If you were operating a telemedicine or virtual care services practice or company on August 16, 2021, the deadline to submit your registration application is no later than October 15th, 2021. The application must be completed online at Telemedicine  · Department Of Health (nj.gov). 

If you began operating a telehealth or telemedicine practice or company after August 16th, you must submit your registration application within the first 60 days of operations. 

The registration is to be renewed annually and carries a $1500 fee.

Companies that fail to register or keep registry information current must cease providing the services within the state of New Jersey or face enforcement actions and penalties, which may include suspension, revocation, or refusal to issue or renew an organization's registration for failure to comply with the standards, as well as fines of $1,000/day beginning from the date of the first provided unauthorized service. 

What are the Reporting Requirements for Telehealth and TelemedicineOrganizations in New Jersey?

We are awaiting details on how the state will require each registered organization operating in the state to submit its annual report (which is different than the registration and renewal).  For now, we know that the annual report must include de-identified encounter data including, but not limited to:

• total # of encounters conducted;

• type of technology utilized to provide services using telemedicine or telehealth;

• category of medical condition for which services were sought;

• the geographic region of the patient and provider;

• patient's age and sex; and

• prescriptions issued.

Within approximately six months thereafter, the following information must also be included in the annual report for each encounter:

• patient's race and ethnicity;

• diagnostic codes;

• evaluation management codes; and

• the source of payment for the encounter.

If you are a telehealth or telemedicine provider or organization that provides, administers or supports remote care services in New Jersey, please reach out to us so that we can assist you in ensuring compliance with these regulations.

NJ Telehealth/Telemedicine Provider To-Do List:

1. Contact NGL ASAP if you have any questions about whether this requirement applies to you or if you need assistance registering.

2. If you were operating on or before August 16th, register at Telemedicine  · Department Of Health (nj.gov)   by NO LATER THAN OCTOBER 15, 2021. 

3. If you began operating after August 16th, register at Telemedicine  · Department Of Health (nj.gov)  within 60 days of the first day of operation.

4. Review the data elements listed above ("Reporting Requirements") that will be required to be reported annually and confirm that this information is captured and retained for de-identification and reporting in accordance with the regulation.