Federal Leaders Should Protect Access to Critical Health Programs

The Honorable Robert F. Kennedy Jr.
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

RE: (Docket ID Docket: AHRQ-2025-0002) Opposition to Personal Responsibility and Work Opportunity Reconciliation Act; Interpretation of ”Federal Public Benefit”

Dear Secretary Kennedy,

New Jersey Policy Perspective (NJPP) is a nonpartisan think tank that drives policy change to advance economic, social, and racial justice through evidence-based, independent research, analysis, and strategic communications. For decades, NJPP has provided timely and insightful research to policymakers in New Jersey to improve outcomes and opportunities for families and individuals across the state.

NJPP strongly opposes any attempt to restrict access to Health and Human Services programs that help build healthy communities. All the programs now being considered “federal public benefits” under this rule proposal would harm the health of those individuals excluded and all residents of the state.

Federally Qualified Health Centers (FQHCs)

Federally qualified health centers provide critical health care to communities often underserved by the health care system as a whole. More than 1 in 4 FQHC patients are uninsured, substantially higher than the state average.[i] In 2023, the state’s 138 FQHCs served more than 570,000 patients, including 145,700 uninsured patients.

People get sick and require care regardless of immigration status. Pushing those people out of the health care system by treating them as a “public charge” does not make them healthier or reduce usage of public benefits. Instead, these punitive policies hurt overall health and well-being by pushing families with mixed immigration status away from care.[ii]

These restrictions ignore an important fact: the FQHCs provide a service for the general welfare. This policy ignores the role that better health, nutrition and education have on society as a whole. If one group of people is excluded from or avoided basic medical care, healthy pregnancy and infancy, or early childhood experiences, those costs multiply on everyone.

Also, immigrants have higher employment rates than native-born adults, contributing greatly to the state and local economy. In New Jersey, immigrants are a major driver of business growth. The roughly 2.2 million immigrants living in the state generate billions in economic activity and local and state tax revenue.[iii] Excluding large parts of this population from basic care will hurt their ability to remain economically independent. This aligns with research showing that the cost of insuring immigrant residents is generally lower than the cost of insuring native-born residents.[iv]

Other programs

Similar logic applies to the vast array of programs now being considered “federal public benefits” under this proposal. Almost all of these programs provide benefits to the community when they reach a broad population:

  • Head Start programs and high-quality early childhood education reduce lifetime costs for child participants and improve a wide range of health and academic outcomes.
  • Substance Use Prevention, Treatment, and Recovery Services help reduce the risks of overdose and substance use disorder on families and communities.
  • Title X Family Planning helps families plan how many children to have and keep a family size they can support economically.
  • Community Services Block Grants provide funding to Community Action Agencies to deliver services that reduce poverty and promote independence.
  • Education and Training Voucher programs support youth aging out of foster care in pursuing higher education and developing independent living skills.
  • Kinship Guardianship Assistance Program ensures relatives who take guardianship of youth receive the guidance and resources needed to strengthen families, increase kinship placements, and promote long-term cost savings.

 

Simply put, these programs do not act as “benefits” to the recipients. Instead, these programs seek to reduce the overall cost to society and government by providing preventative measures that encourage economic independence and security.

NJPP urges HHS to withdraw this proposed rule that misclassifies these prevention measures that benefit all residents as “federal public benefits” that go to a select few.

Sincerely,

Brittany Holom-Trundy
Research Director
New Jersey Policy Perspective


End Notes

[i] New Jersey Primary Care Association, Federally Qualified Health Centers in New Jersey, March 2024. https://www.njpca.org/wp-content/uploads/2024/04/March-2024_NJPCA-Bifold-FQHC-Snapshot.pdf

[ii] Dulce Gonzalez et al. Mixed-Status Families and Immigrant Families with Children Continued Avoiding Safety Net Programs in 2023. Urban Institute, Aug. 7, 2024. https://www.urban.org/research/publication/mixed-status-families-and-immigrant-families-children-continued-avoiding

[iii] Marleina Ubel, New Immigrants Drive Economic Growth in New Jersey, New Jersey Policy Perspective, Apr. 15, 2024. https://www.njpp.org/publications/report/new-immigrants-drive-economic-growth-in-new-jersey/

[iv] Neeraj Kaushal and Felix Muchomba. Cost of Public Health Insurance for US-Born and Immigrant Adults. JAMA Network Open. 2023;6(9):e2334008. doi:10.1001/jamanetworkopen.2023.34008

Federal Leaders Should Preserve the Quality of SNAP Data to Protect Program Integrity

Attn: James C. Miller, Administrator
Food and Nutrition Service
United States Department of Agriculture
1320 Braddock Place, 5th floor
Alexandria, Virginia 22314

Re: Notice of Proposed Rulemaking: Supplemental Nutrition Assistance
Program: Rescission of Changes to Civil Rights Data Collection Methods,
90 F.R. 20825 (RIN 0584-AF19, May 16, 2025)

Dear Mr. Miller:

I am writing on behalf of New Jersey Policy Perspective (NJPP) in response to the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) proposal to rescind the Supplemental Nutrition Assistance Program (SNAP): Revision of Civil Rights Data Collection Methods final rule, which ended the practice of visual observations to determine SNAP participants’ race or ethnicity. I appreciate the opportunity to provide comments expressing our concerns with this change in data collection methods.

NJPP strongly disagrees with the proposed rescission, which would reinstate the allowance of visual observation as a program standard for the collection of race and ethnicity data of participants. This would be a step backward for the reliability and accuracy of data and would threaten the fair administration of SNAP. We recommend that the rule remain in place to continue improved data collection practices, maintain the accuracy of program analyses, and respect the civil rights of participants. 

The quality of data significantly impacts its usefulness, including the potential scope and accuracy of analyses that can be produced. In the case of visual observation of race, studies have shown that conclusions using this practice are often inaccurate when compared with self-reported data by the person whose race is being evaluated, if the goal is to determine the individual’s identity, family background, and lived experience.[i] Additionally, the perceptions of the interviewers or administrators visually observing race can vary, resulting in errors that do not follow predictable patterns or allow for reliable adjustments when evaluating the data. This makes it more difficult to produce program evaluations with high levels of confidence in their accuracy.[ii]

In addition to the accuracy of data collected, visual observation of race and ethnicity as a practice can threaten the process of the interview itself. Establishing a standard practice of asking an interviewer to potentially report the race or ethnicity of an interviewee primes the interviewer to think about and evaluate the characteristics of the participant throughout the interview. This can lead to an increase in biases within the interviewer’s approach and harm their rapport with the interviewee.

By diminishing the reliability and accuracy of demographic variables like race and ethnicity, any analyses that look to determine whether SNAP continues to be administered in ways that comply with federal civil rights requirements will be limited in their ability to confidently produce accurate results. Although allowing the interviewer to report the suspected race or ethnicity of a participant may lead to fewer unreported results and increase the number of “complete” questionnaire responses, the filling in of these gaps with unreliable data further reduces the data’s utility and harms program administration and outcomes.[iii] Researchers, program analysts, and lawyers would face greater difficulties reporting on the quality of the program’s administration and its legal standing with regard to civil rights requirements.

If officials are interested in filling gaps in the program data reported and wish to develop methods of producing more complete files, they must recognize that the most reliable and accurate data will come from the participant, who knows their family and individual background and identification. In order to encourage participants to answer this sensitive question more often, officials should look to methods of building trust between caseworkers and participants, improve and promote the security of the data provided, as well as adjust the structure of the questionnaire and potential answers to best allow for the participant to answer fully and accurately.[iv]

Due to the concerns outlined above, NJPP opposes the proposed rescission of this rule and hopes that the Department will consider other methods of filling data gaps and improving the overall quality of program evaluations.

Sincerely,

Brittany Holom-Trundy
Senior Policy Analyst
New Jersey Policy Perspective


End Notes

[i] Note that if the goal of a study is to record the race or ethnicity that external people may observe — thus, studying biases in observations — then the reporting of a visual observation of race and ethnicity would be valid in terms of what it seeks to capture. However, with program data, the aim is generally to better administer the program and ensure that there are no unintended or intended exclusions of communities based on their demographic characteristics.

[ii] This is not just a challenge for visual observation of race and ethnicity, but is also a broader challenge for any externally imposed completion of missing race and ethnicity data. For a discussion of statistical challenges, see Megan Randall, Alena Stern, and Yipeng Su (2021), “Five Ethical Risks to Consider Before Filling Missing Race and Ethnicity Data,” Urban Institute,

https://www.urban.org/sites/default/files/publication/103830/five-ethical-risks-to-consider-before-filling-missing-race-and-ethnicity-data-workshop-findings.pdf.

[iii] The USDA’s Civil Rights Impact Analysis for the original rule recognized that the removal of visual observation as standard practice would increase the accuracy of its data: https://www.federalregister.gov/d/2022-13058/p-35. Without additional study results showing outcomes to the contrary, the reinstatement of the practice remains unsupported and should be considered to most likely decrease accuracy.

[iv] The ability of participants to fully answer the question in a way that they identify as accurate can significantly impact the response rates and the validity of the data. See, for example: Garbarski, Dana, Jennifer Dykema, Cameron P. Jones, Tiffany S. Neman, Nora Cate Schaeffer, and Dorothy Farrar Edwards (2024), “Questioning Identity: How a Diverse Set of Respondents Answer Standard Questions About Ethnicity and Race.” Field Methods 36, no. 2: 113-130. For an in-depth discussion of data collection on race and ethnicity, see Sharghi, Sima, Shokoufeh Khalatbari, Amy Laird, Jodi Lapidus, Felicity T. Enders, Jareen Meinzen-Derr, Amanda L. Tapia, and Jody D. Ciolino. “Race, ethnicity, and considerations for data collection and analysis in research studies.” Journal of Clinical and Translational Science 8, no. 1 (2024): e182.

Legislators Must Protect the Rights of New Jerseyans & Invest in Long-Term Solutions for Mental Health Care

Good morning Chairman Vitale and members of the Committee. Thank you for this opportunity to provide my testimony in opposition to S4263. My name is Dr. Brittany Holom-Trundy, and I am a senior policy analyst at New Jersey Policy Perspective (NJPP). NJPP is a non-partisan, non-profit research institution that focuses on policies that can improve the lives of low- and middle-income people, strengthen our state’s economy, and enhance the quality of life in New Jersey.

NJPP strongly opposes the permanent extension of involuntary commitment length, which threatens the health and rights of New Jersey residents. The role of involuntary commitment in treatment for those experiencing mental health crises has long been recognized as complicated and, often, problematic. Research has shown that racism, sexism, and other biases in health treatment settings lead to disparities not only in judgments about people’s pain or illness, but also in diagnoses of psychological disorders.[i] Because involuntary commitment requires medical judgments from healthcare professionals about whether a person is a “danger to self” or “danger to others or property,” emphasizing these situations further as a blunt tool for care without needed data opens doors to increased discrimination.[ii] Studies have shown that patients of color are more likely to be determined to be a “danger” and involuntarily committed than white patients.[iii] Meanwhile, there remains very little research on the medical effectiveness of 72-hour holds, let alone double that amount of time.[iv]

Though involuntary commitment may be necessary as a blunt tool to address an emergency situation, it is certainly not the ideal approach to care, and not one that should be prolonged arbitrarily. Hospitals often do not have the resources necessary to provide the standard of care for patients in involuntary commitment throughout its original 72-hour length; thus, extending the possible length of time simply invites worsening conditions resulting from staff and resource shortages.

The need for extended involuntary commitment remains low, and when it is utilized, it indicates other gaps in care. According to quarterly reports submitted to the Department of Human Services since the initial introduction of this extension, facilities requested extended holds for less than 1-2% of all hospitalizations due to psychiatric crises.[v] This means that these holds were needed for less than 1% of all patients screened for mental health crises, most of whom are discharged without hospitalization.

Such a small number does not indicate a pressing need to permanently suspend patients’ rights to reasonable, humane treatment in the standard timeframe. Instead, if our goal as leaders is to improve care, further decrease the number of cases in need of involuntary commitment, and address challenges within that system, then we must consider the question of why these patients were in need of help and were unable to receive that help within 72 hours (3 days), which should be achievable. In particular, attention to the following would allow for a better, more targeted response:

  • Whether and where beds were available at the time of the hold
  • Staff shortages at the facility holding the patient
  • Reports of refusals to accept patients based on complicating medical conditions, criminal history, insurance status, or other circumstances
  • Insurance status of patients held and payments charged

By considering these factors, lawmakers could determine if more psychiatric facilities and beds are needed; if increased staffing at hospitals should be prioritized; if staff need improved training, regulation, or support; or if facilities have financial incentive to keep some patients longer than others. Addressing these root causes of issues would provide better long-term solutions than the band-aid of simply extending involuntary commitment. Leaders could seek to invest state resources into long-term solutions to improve the mental health system so that we can decrease the number of people reporting mental health crises, improve treatment for those experiencing crises, and ensure the best, most efficient use of hospital care settings for both patients and healthcare workers.

New Jersey needs long-term investment in the mental health system, not a self-fulling solution that invites further abuse and ignores the cause in the first place.

We hope that the Committee will agree and hold this bill and consider these concerns today.

Thank you for your time.


End Notes

[i] Hamed, Sarah, Hannah Bradby, Beth Maina Ahlberg, and Suruchi Thapar-Björkert. “Racism in healthcare: a scoping review.” BMC Public Health 22, no. 1 (2022): 988; Zhang, Lanlan, Elizabeth A. Reynolds Losin, Yoni K. Ashar, Leonie Koban, and Tor D. Wager. “Gender biases in estimation of others’ pain.” The Journal of Pain 22, no. 9 (2021): 1048-1059; Garb, Howard N. “Race bias and gender bias in the diagnosis of psychological disorders.” Clinical Psychology Review 90 (2021): 102087.

[ii] Morris, Nathaniel P. “Detention without data: public tracking of civil commitment.” Psychiatric Services 71, no. 7 (2020): 741-744.

[iii] Shea, Timothy, Samuel Dotson, Griffin Tyree, Lucy Ogbu-Nwobodo, Stuart Beck, and Derri Shtasel. “Racial and ethnic inequities in inpatient psychiatric civil commitment.” Psychiatric Services 73, no. 12 (2022): 1322-1329.

[iv] Morris, Nathaniel P. “Reasonable or random: 72-hour limits to psychiatric holds.” Psychiatric Services 72, no. 2 (2021): 210-212.

[v] New Jersey Department of Human Services. Continued Hold Orders. https://nj.gov/humanservices/dmhas/publications/orders/

House Proposal Would Strip Health Coverage From 200,000 New Jerseyans, NJPP Warns

On Monday, May 12, the U.S. House Energy and Commerce Committee released its plan to cut Medicaid by over $700 billion. Debate on the bill begins Tuesday, May 13 — the next step that would take health insurance coverage away from 8.6 million people. Three members of New Jersey’s congressional delegation sit on the committee: Reps. Frank Pallone (D), Robert Menendez, Jr. (D), and Thomas Kean, Jr. (R).

In response, New Jersey Policy Perspective (NJPP) issues the following statement.

Brittany Holom-Trundy, Senior Policy Analyst, NJPP:

“The House plan to cut Medicaid would strip hundreds of thousands of New Jerseyans of their health insurance and roll back more than a decade of progress in making health care more affordable.

“Whether through block grants, work requirements, or other means, the outcome is the same: 8.6 million Americans would lose their insurance — including nearly 200,000 New Jerseyans, if cuts are distributed evenly across the states.

“These cuts are a direct attack on the health and well-being of families working hard to make ends meet.

“New Jersey cannot afford to reverse its successful, bipartisan Medicaid expansion just to pay for more tax breaks for billionaires and large corporations.”

For more on how proposed Medicaid cuts would harm New Jersey, read NJPP’s March publication on the impact of work requirements.

###

Federal Medicaid Reductions Would Have Disastrous Effects on New Jersey’s Communities

Good morning Chair and members of the committee. Thank you for the opportunity to testify.

Any reduction in federal Medicaid spending directly harms New Jersey’s budget and its residents. As a state-federal partnership, Medicaid depends on reliable and sustainable federal funding to balance state funds. Regardless of the specific method that Medicaid spending is cut, the end result is the same: less money for the state and costs pushed from the federal budget onto state budgets.

A $2 billion cut, no matter how you slice it

Analysis from national health care researchers estimates that the proposed cuts in the federal Medicaid budget would mean a $2 billion annual cut in New Jersey’s Medicaid budget. (See Appendix A). This corresponds with analysis by New Jersey’s Department of Human Services putting a cost of a minimum of $2 billion on proposed federal changes. (See Appendix B)

By way of comparison the entire proposed state appropriation for Medicaid is $5.7 billion for FY 2026.[i] Another way of contextualizing the numbers – the estimated cuts are the equivalent to the cost of 87% of kids enrolled in Medicaid. (See Appendix A)

I will leave to other experts to discuss the mechanics of particular proposals, whether a per capita cap, a change in federal reimbursement rate, or onerous work requirements. But regardless of the method, the state budget will face a multi-billion dollar hole with no solution.

A trickle-down budget disaster for states, localities, and health care providers

The state budget would take the immediate cut from whichever federal cuts are realized. Some of that effect may be spread out over multiple years but one way or another, the money will stop showing up in the state’s revenues.

But the ripple effects of these cuts would eat even further into the state’s budget.

  • If the state chooses to fill in the federal gaps with its own funding, it would have to generate new revenues to do so at a time when the budget is already running deficits.
  • If people become disenrolled from Medicaid, they will likely incur costs elsewhere in the health care system, whether in hospital charity care or other uninsured settings.
  • Health care providers depend on Medicaid payments, as detailed in the NJ DHS analysis (See Appendix B), and funding cuts would affect their revenues as well.

 

Limited solutions

Reducing costs for Medicaid at the state level would be difficult for a program that already runs at very low cost compared to the private insurance market. Medicaid costs less to insure an enrollee than the private market and spending has grown more slowly than the private market.[ii]

  • Already-low reimbursement rates: New Jersey already has comparatively low reimbursement rates for Medicaid,[iii] limiting options for provider availability if rates are capped or reduced.
  • Already-low overhead costs: Overhead costs for Medicaid are already low – around 4.4% for New Jersey.[iv]
  • Increased administrative costs of proposed changes: Creating a state system for work requirements or other potentially onerous federal mandates would increase, not decrease, those administrative costs.

One additional note of caution: recessions typically see an increase in demand for Medicaid, as people become unemployed or underemployed.[v] If economic uncertainty produces a recession, this would further increase the state budgetary cost of reduced federal Medicaid spending. In the 2001, 2008, and 2020 recessions, the federal government increased Medicaid reimbursement rates, but that may be unlikely this time around.

The takeaway: A Medicaid cut by any name would impose huge costs on the state budget, with few solutions and devastating effects on New Jerseyans’ health.


End Notes

[i] State of New Jersey, The Governor’s FY 2026 Budget: Detailed Budget (2025), p. D-209.

[ii] Hannah Katch et al., Frequently Asked Questions about Medicaid, Center on Budget and Policy Priorities (Nov. 22, 2019), https://www.cbpp.org/research/correcting-seven-myths-about-medicaid

[iii] New Jersey Health Care Quality Institute, Primary Care in New Jersey: Findings and Recommendations to Support Advoanced Primary Care (January 2024) https://www.njhcqi.org/wp-content/uploads/2024/01/Primary-Care-Report_2024_v11.pdf.

[iv] Medicaid and CHIP Payment and Access Commission (MACPAC), MACStats: Medicaid and CHIP Data Book (December 2024), p. 46 exh. 16, https://www.macpac.gov/wp-content/uploads/2024/12/EXHIBIT-16.-Medicaid-Spending-by-State-Category-and-Source-of-Funds-FY-2023.pdf.

[v] Katherine Young et al., Medicaid Spending Growth in the Great Recession and Its Aftermath, FY 2007-2012, Kaiser Commission on Medicaid and the Uninsured (July 2014), pp. 5-6, https://www.kff.org/wp-content/uploads/2014/07/8309-03-medicaid-spending-growth-in-the-great-recession-and-its-aftermath-fy-2007-2012.pdf

Medicaid Cuts and Red Tape Jeopardize Health Care for Over 750,000 New Jerseyans

Every New Jerseyan deserves access to affordable health insurance and care. Medicaid coverage ensures that people can see a doctor for routine checkups and essential care, improving overall health and reducing medical debt for enrollees. However, recent federal proposals to slash Medicaid funding for states threaten gains in coverage for adults and children across New Jersey. Federal Medicaid dollars support New Jersey FamilyCare, which provides health insurance for low- and moderate-income households — making it a critical lifeline for families statewide.

Under the recently passed House budget resolution, one harmful proposal would impose work requirements for Medicaid. If Congress passes these onerous work requirements, about 765,000 New Jersey adults could lose health insurance 44 percent of all adult Medicaid enrollees. Other estimates, including from the New Jersey Department of Human Services, which administers Medicaid in New Jersey, conclude similarly, showing that hundreds of thousands of people risk losing health insurance with work requirements under these rules.

Overall, these counterproductive requirements would add burdensome and unnecessary red tape to insurance applications while threatening basic health insurance for nearly half of all enrollees. Most adult Medicaid enrollees already work, while those who are not are most often caring for family members, dealing with illness or disabilities, or pursuing education. Evidence from states with work requirements for health insurance demonstrate that these policies fail to increase employment, while access to affordable health insurance actually improves a person’s ability to get and keep a job.

Cuts that remove people from Medicaid shift costs onto working- and middle-class families who rely on it. These families already face rising housing, food, and health care expenses. If a New Jersey family in the lowest 20 percent of earners lost coverage, they would lose, on average, $11,909 annually.

New Jersey must protect NJ FamilyCare by rejecting Medicaid cuts that would undermine affordability, strain the state’s budget, and put hundreds of thousands of New Jerseyans at risk of losing lifesaving health insurance.

New Jersey’s Prescription Drug Price Council Must Act To Build on Federal Progress

No family should have to choose between life-saving medicine and buying groceries. Yet, prescription drug spending at pharmacies has nearly doubled over the last two decades, intensifying this struggle for many families.[i] Recent federal actions allowing prescription drug price negotiations in Medicare — a federal health insurance program for senior citizens and some people with disabilities or certain chronic conditions — are an important step forward for affordability that will benefit thousands of New Jersey families. However, millions who are not eligible for Medicare still need relief. Garden State leaders can build on the federal momentum by ensuring that, once the final appointments are made, the state’s Prescription Drug Affordability Council promptly holds its required public meetings to begin its critical work on data collection and legislative recommendations to improve affordability for all residents.

Recent Federal Actions Will Cut Prescription Drug Costs for Medicare Enrollees

Federal leaders have taken significant steps toward improved affordability by allowing negotiations of prescription drug prices for Medicare enrollees through the Inflation Reduction Act (IRA) of 2022. Previously, restrictions had prevented Medicare from pushing back on pharmaceutical companies’ price hikes.[ii] Other major steps in the IRA to address affordability in Medicare include capping out-of-pocket maximums for Part D (prescription drug) coverage and limiting the cost of insulin in the program to $35.[iii]

The first of the negotiated prices, announced in August 2024 and taking effect in January 2026, include 10 prescription drugs covered under Medicare, resulting in 38 to 79 percent in savings.[iv] Further, the IRA establishes a timeline for expanding these negotiations to cover even more drugs: 15 more drug prices from the prescription drug coverage in 2025, 15 from prescription drug and medical services coverage in 2026, and 20 more each year from 2027 onward. With each new list of drugs, the negotiated prices will become effective every other January — two years after for each new list, gradually increasing the number of drugs covered and providing increased cost relief for Medicare beneficiaries.[v]

Medicare Negotiated Rates Benefit a Majority of Senior Citizens, But Few Others

While these federal negotiations are promising, they only benefit Medicare enrollees — meaning that around 82 percent of New Jersey residents will not see cost reductions from the negotiated rates.[vi] Most Medicare enrollees in New Jersey are senior citizens, with 93 percent of residents who are 65 years old and older insured through the program.[vii] In contrast, only around 3 percent of working-age adults and 0.5 percent of children in the state are enrolled in Medicare.[viii] Consequently, the majority of children and working-age adults do not receive the affordability protections provided by these negotiated rates.

Although older adults are more likely to take multiple prescriptions and higher annual health care costs, younger residents with chronic diseases such as hypertension and diabetes also face significant financial strain from high drug prices. Across all age groups, many individuals are forced to alter how they manage their medications — such as cutting pills or forgoing prescriptions entirely — due to the unaffordable costs.[ix]

Empowering the New Jersey Prescription Drug Affordability Council Will Improve Affordability for All

To ensure affordability for all residents, New Jersey must fully activate its recently established Prescription Drug Affordability Council (PDAC). State leaders passed the prescription drug reforms, including PDAC, expecting them to “bring to light the inner workings and beneficiaries within the pharmaceutical industry and work to combat rising prices.”[x] However, leaders have been delayed in finalizing the last council members; in turn, this has prevented the scheduling of the council’s first meetings and collection of data.[xi]

State law directs the council to research the obstacles to affordability in the pharmaceuticals supply and demand chains, explore further state actions to improve affordability, and make recommendations regularly to the state legislature.[xii] Given the timeline needed to conduct this in-depth research, make the first policy recommendations, pass the policies in the legislature, and provide the departments time to establish new procedures and regulations, every day that delays the work means that relief remains out of reach for New Jersey families even longer.

Once the final members of the PDAC are appointed, they must move swiftly to hold public meetings and begin gathering the in-depth data needed for their work. By moving forward, state leaders will promote a more affordable future for all Garden State residents.


End Notes

[i] RAND Corporation, Prescription Drug Prices in the U.S. Are 2.78 Times Those in Other Countries, 2024. https://www.rand.org/news/press/2024/02/01.html. RAND estimates that retail prescription drug spending increased by 91 percent between 2000 and 2020.

[ii] Congressional Research Service, Negotiation of Drug Prices in Medicare Part D, 2022. https://crsreports.congress.gov/product/pdf/IF/IF11318

[iii] KFF, Explaining the Prescription Drug Provisions in the Inflation Reduction Act, 2023. https://www.kff.org/medicare/issue-brief/explaining-the-prescription-drug-provisions-in-the-inflation-reduction-act/

[iv] Centers for Medicare & Medicaid Services, Medicare Drug Price Negotiation Program: Negotiated Prices for Initial Price Applicability Year 2026, https://www.cms.gov/files/document/fact-sheet-negotiated-prices-initial-price-applicability-year-2026.pdf; KFF, FAQs about the Inflation Reduction Act’s Medicare Drug Price Negotiation Program, 2024. https://www.kff.org/medicare/issue-brief/faqs-about-the-inflation-reduction-acts-medicare-drug-price-negotiation-program/

[v] Centers for Medicare & Medicaid Services, Inflation Reduction Act: CMS Implementation Timeline, 2022. https://www.cms.gov/files/document/10522-inflation-reduction-act-timeline.pdf; KFF, FAQs about the Inflation Reduction Act’s Medicare Drug Price Negotiation Program, 2024. https://www.kff.org/medicare/issue-brief/faqs-about-the-inflation-reduction-acts-medicare-drug-price-negotiation-program/

[vi] NJPP Analysis of Census Bureau – American Community Survey,  Table S2704, ACS 1-Year Estimates 2023. https://data.census.gov/table/ACSST1Y2023.S2704?q=S2704&g=040XX00US34

[vii] NJPP Analysis of Census Bureau – American Community Survey,  Table S2704, ACS 1-Year Estimates 2023. https://data.census.gov/table/ACSST1Y2023.S2704?q=S2704&g=040XX00US34

[viii] NJPP Analysis of Census Bureau – American Community Survey,  Table S2704, ACS 1-Year Estimates 2023. https://data.census.gov/table/ACSST1Y2023.S2704?q=S2704&g=040XX00US34

[ix] For discussion of annual health care spending, see: Centers for Medicare & Medicaid Services, NHE Fact Sheet, 2022, https://www.cms.gov/data-research/statistics-trends-and-reports/national-health-expenditure-data/nhe-fact-sheet#. For discussion of prescription drug affordability across adult age groups, see: KFF, Public Opinion on Prescription Drugs and Their Prices, 2023, https://www.kff.org/health-costs/poll-finding/public-opinion-on-prescription-drugs-and-their-prices/. For discussion of behaviors associated with high prescription drug costs, see: Healthcare Value Hub, New Jersey Residents Worried about High Drug Costs; Support a Range of Government Solutions, 2023, https://www.healthcarevaluehub.org/advocate-resources/publications/new-jersey-residents-worried-about-high-drug-costs-support-range-government-solutions-1.

[x] Quote from Senator Vitale, Chair of the Senate Health Committee. Office of Governor Phil Murphy, Governor Murphy Signs Legislative Package to Make Prescription Drugs More Affordable for New Jerseyans, 2023, https://www.nj.gov/governor/news/news/562023/20230710a.shtml.

[xi] Politico Pro, Assembly Speaker recommends AARP lobbyist for prescription drug council position, 2024. https://subscriber.politicopro.com/article/2024/04/assembly-speaker-recommends-aarp-lobbyist-for-prescription-drug-council-position-00154731; Politico Pro, Murphy makes long-awaited drug council appointments, 2024. https://subscriber.politicopro.com/article/2024/03/murphy-makes-long-awaited-drug-council-appointments-00148915

[xii] New Jersey Policy Perspective, The Best Medicine: How the Drug Affordability Council Can Advance Future Drug Pricing Reforms in New Jersey, 2023. https://www.njpp.org/publications/blog-category/the-best-medicine-how-the-drug-affordability-council-can-advance-future-drug-pricing-reforms-in-new-jersey/

Beyond the Pandemic: New Data Reveals Growing Health Insurance Coverage Gaps

All New Jersey residents deserve affordable, quality health care, regardless of immigration status, race or ethnicity, gender, age, education, or employment status. However, access to coverage, which helps mitigate individuals’ rising health care costs, remains plagued by significant gaps and challenges.

With a rising rate of residents who lack insurance, New Jersey’s leaders urgently need to address gaps in coverage. Extending existing programs that connect residents with affordable coverage regardless of immigration status and expanding coverage options for all residents would ensure that everyone can access the health coverage they need.

Coverage Gaps Re-appeared with the End of Pandemic-Era Protections

2023 marked the end of COVID-19 pandemic-era protections that kept many people covered by affordable health insurance, resulting in the first increase in uninsured residents since the pandemic began. The end of the main coverage protections was called the Medicaid “unwinding” — the reevaluation of every enrollee’s eligibility for the program after the pandemic-era pause on disenrollments ended.[i] The huge losses in coverage resulted in many families unexpectedly losing or having to change insurance.

In 2023 alone, over 660,000 New Jerseyans were uninsured, a nearly 6% increase from 2022, according to recently released data from the U.S. Census Bureau’s American Community Survey. This significant increase in state residents living without health insurance raises alarms about the recent reopening of pre-pandemic gaps in coverage and potential threats to the gains made since the introduction of the Affordable Care Act.

Racial and Economic Disparities Continue to Plague the Goal of Universal Coverage

In addition to an increase in uninsured rates, the data shows persistent racial and economic disparities in coverage rates. In particular, residents with incomes between 138 and 399 percent of the federal poverty level (between about $34,300 and $99,400 for a family of three, such as a single mother with two children) were more likely to lose coverage in 2023 than other income groups.[ii] These residents, ineligible for Medicaid and less likely to have employer coverage, faced increased uncertainty as their previous coverage options ended.

Gaps in coverage for low-wage workers and families struggling to make ends meet are closely tied to a history of racism and xenophobia; restrictions in programs like Medicaid, variations in the quality of employer-sponsored insurance, and even limitations on the state health insurance marketplaces have been structured to limit coverage for specific groups.[iii] Unfortunately, residents of color and immigrants still do not have equitable access to affordable coverage. Black residents remain twice as likely to be uninsured than white residents, while Hispanic/Latinx residents are over six times more likely to be uninsured than non-Hispanic/Latinx New Jerseyans. Immigrants, too, are far more likely to lack coverage, with non-citizens remaining over six times more likely to be uninsured than naturalized citizens and nearly 10 times more likely to be uninsured than citizens born in the United States.

Disparities continue at the county level, as counties with larger immigrant populations experience higher uninsured rates. Because of gaps in coverage, residents in counties with the largest communities of non-citizens are twice as likely to be uninsured than residents in counties with similar income levels but smaller communities of non-citizen residents.[iv]

State Leaders Need to Expand Affordable Coverage Options for All Residents

To provide affordable coverage for all, New Jersey leaders need to open the NJ FamilyCare program to older age groups and the state marketplace, GetCoveredNJ, to all residents regardless of immigration status. Additionally, the state should explore the opportunity to establish a state public option that would be available to all residents, covering adults and children who still lack affordable options due to income and immigration status.[v] Leaders must improve outreach and connections between programs so that no one loses coverage unnecessarily.

While state leaders have begun initiatives, such as the highly successful Cover All Kids program, to address gaps, persistent holes in the patchwork of coverage options will prevent the state from achieving significant improvement for all of New Jersey’s residents.[vi] As long as gaps continue for residents based on age, immigration status, and employment, universal coverage will stay out of reach.

With stronger stitching, our patchwork system of coverage can better provide accessible, affordable health coverage for all.


End Notes

[i] Stay Covered NJ, Eligibility Unwinding, 2023. https://nj.gov/humanservices/dmahs/staycoverednj/unwinding/

[ii] NJPP Analysis of U.S. Census Bureau American Community Survey, 2023, Table S2701 and 2023 Federal Poverty Levels at: https://www.healthcare.gov/glossary/federal-poverty-level-fpl/

[iii] Health Affairs, Structural Racism In Historical And Modern US Health Care Policy, 2022. https://www.healthaffairs.org/doi/10.1377/hlthaff.2021.01466; Center on Budget and Policy Priorities, Health Coverage Rates Vary Widely Across — and Within — Racial and Ethnic Groups, 2024. https://www.cbpp.org/research/health/health-coverage-rates-vary-widely-across-and-within-racial-and-ethnic-groups

[iv] The average percent of the population across counties made up of non-citizens is 8.6%, based on NJPP Analysis of U.S. Census Bureau American Community Survey, 2023 Table DP02.

[v] See footnote below on the Cover All Kids program. This program was broken into three phases of insurance enrollment goals for: (1) kids who were already eligible for NJ FamilyCare but not enrolled, (2) kids who were income-eligible but previously ineligible for NJ FamilyCare due to immigration status, and (3) kids who are both income-ineligible for NJ FamilyCare but don’t have access to other affordable options such as GetCoveredNJ due to immigration status. As of September 2024, the first two phases have been implemented, but the third phase still remains unaddressed. The law, P.L.2021, c.132., allows for the state to explore public options to fill this gap.  https://www.njleg.state.nj.us/bill-search/2020/S3798

[vi] NJ Spotlight News, Big enrollment of undocumented kids in NJ health insurance program, 2023. https://www.njspotlightnews.org/2023/08/large-number-undocumented-children-enrolled-for-nj-health-insurance-program/; New Jersey Department of Human Services, Cover All Kids, 2024. https://nj.gov/coverallkids/

Medical Debt Protections Paired with Debt Elimination and Addressing High Health Care Cost Leads to Health Equity

Good afternoon Chairman Sarlo and members of the Committee. Thank you for this opportunity to provide my testimony on S2806, the Louisa Carman Medical Debt Relief Act. My name is Dr. Brittany Holom-Trundy, and I am a senior policy analyst at New Jersey Policy Perspective (NJPP). NJPP is a non-partisan, non-profit research institution that focuses on policies that can improve the lives of low- and middle-income people, strengthen our state’s economy, and enhance the quality of life in New Jersey.

NJPP supports the goals of S2806, which are to prohibit the reporting of medical debt to credit reporting agencies and ensure that patients are protected from financial ruin just from seeking medical care. This is particularly crucial for the well-being of the state’s residents with lower incomes. Many with lower incomes avoid preventative medical care due to costs and time restrictions, meaning that those with the least are also the most likely to face medical emergencies.[i] Beyond the burden of the debt, the current status quo means that this debt can be reported to credit reporting agencies and impact other vital needs: with a reported debt, suddenly housing and other means of support may be inaccessible, making more medical issues even more likely. This is true not only for those without insurance, but for those with insurance coverage and up-to-date preventive medical care as well, as unexpected medical emergencies happen and affordability remains a critical issue.[ii]

However, there are a few amendments that would make this bill stronger for the patients that it is seeking to assist. For example, it is important to strengthen the ability of patients to take action when violations of the bill occur, as well as ensure that the care-providing entity remains responsible for offering a reasonable payment plan. Additionally, it is important that all means by which patients pay for care are included in this reporting ban — meaning that things like certain medical care credit cards and the broad category of “secured debt” should not be excluded.

It is important to note that this bill does not address the root issue of high costs in our health care system, nor does it eliminate medical debt altogether. However, this will at least provide families with the knowledge that medical debt will not pervade their lives and create obstacles to other basic necessities. This bill is crucial to addressing calamities and the ways that our expensive health care system currently cripples families for life. By prohibiting the reporting of debt to credit reporting agencies and ensuring that patients are protected, we can bring more humanity to our health care system and promise residents that medical debt will not control their future.

We hope that the Committee will agree and release this bill with the adoption of the proposed amendments suggested by the groups here today.

Thank you for your time.


End Notes

[i] U.S. Census Bureau, Most Vulnerable More Likely to Depend on Emergency Rooms for Preventable Care, 2022. https://www.census.gov/library/stories/2022/01/who-makes-more-preventable-visits-to-emergency-rooms.html

[ii] Commonwealth Fund, The Cost of Not Getting Care: Income Disparities in the Affordability of Health Services Across High-Income Countries, 2023. https://www.commonwealthfund.org/publications/surveys/2023/nov/cost-not-getting-care-income-disparities-affordability-health

Strengthening Access to Affordable Reproductive Health Care Coverage Advances Equity

Good afternoon Chairman Sarlo and members of the Committee. Thank you for this opportunity to provide my testimony on S3452. My name is Dr. Brittany Holom-Trundy, and I am a senior policy analyst at New Jersey Policy Perspective (NJPP). NJPP is a non-partisan, non-profit research institution that focuses on policies that can improve the lives of low- and middle-income people, strengthen our state’s economy, and enhance the quality of life in New Jersey.

NJPP strongly supports S3452, which looks to protect and improve reproductive health care access and ensure equity across state coverage here in New Jersey.

All Garden State residents deserve the ability and freedom to choose how and when they grow their families. To truly be a family-friendly state, we need to ensure that all those who are pregnant or who may become pregnant have confidence in their health care. This means guaranteeing that they will have access to affordable and quality care, regardless of their health conditions, income, immigration status, and other circumstances. By requiring that all state programs consistently offer all critical coverage for pregnancy, including abortion, and removing financial barriers to that care, this bill gives families the knowledge and certainty that is so desperately needed for the delicate, and often unpredictable, processes of reproductive health.

While we do not yet have a published OLS fiscal note on this bill, we know that the costs, especially because many state programs have already offered this coverage, will likely be minimal in comparison to other spending in the state budget. Additionally, each dollar that is committed to guaranteeing this coverage across programs represents an investment in the future; with health care, we know that accessing vital care when it is needed reduces long-term health problems and future — and, often, growing — costs for on-going medical issues. As a result, this investment saves the state money in the long run.

There is simply no need to artificially continue gaps in coverage and needlessly threaten uncertainty in health care for any New Jersey residents. Doing so creates economic hardship and discourages families from growing and investing in their own futures. It continues sexist, racist, and xenophobic tropes that we know we should leave far behind in our history. In the year 2024, no one in our state, which offers such great opportunities for advanced medical care, should have to wonder if they can access or afford life-saving reproductive care.

We hope that the Committee will agree and release this bill today.

Thank you for your time.