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Federal Stimulus for New Jersey Groups Not Subject to COBRA

Application of the Group Coverage Continuation Subsidy to Persons Who Worked for New Jersey Small Employers

Updated 06/08/09

On February 17, 2009, President Barack Obama signed the American Recovery and Reinvestment Act of 2009 (ARRA), commonly called the Stimulus Plan.  ARRA provides for premium reductions and additional election opportunities for health benefits under Federal continuation, commonly called COBRA.  Eligible individuals pay only 35% of the COBRA premium and the remaining 65% is reimbursed to the coverage provider (such as an insurance company or HMO or other plan) through a tax credit.  The premium reduction applies to periods of health coverage beginning on or after February 17, 2009 and lasts for up to nine months.

Many New Jersey employees work for employers that are not subject to COBRA because the employer employs fewer than 20 employees.  New Jersey law (N.J.S.A. 17B:27A-27) provides for continuation that is comparable to COBRA and thus the ARRA applies to employees of New Jersey small employers as well.  Except as identified below, ARRA applies to New Jersey Continuation under group coverage issued to New Jersey small employers in the same manner that it applies to COBRA continuation coverage and the information as it pertains to COBRA would apply.

For information regarding ARRA as it pertains to COBRA contact the U.S. Department of Labor Employee Benefits Security Administration at 1-866-444-3272 or visit the agency’s website: www.dol.gov/ebsa/COBRA.html

   
General Questions and Answers


Who is eligible for the premium reduction for New Jersey Continuation under the AARA?

The term used to identify an eligible individual is an “assistance eligible individual.” 

An assistance eligible individual is a person who:

    • loses group health coverage because of an employee’s involuntary termination between September 1, 2008 and December 31, 2009;
    • is eligible for New Jersey Continuation; and
    • is not eligible for Medicare or other group health plan coverage

Recall that New Jersey continuation is not available to a person whose employment is terminated for cause.  See the information below regarding involuntary terminations that occurred prior to February 17, 2009

There is an income threshold such that the premium reduction is only available to individuals whose same year income will not exceed $125,000 for individual filers and $250,000 for joint filers.  (If an individual takes advantage of the premium reduction and in the same year exceeds the income limit, he or she will be required to repay all or part of the premium reduction.)

What does it mean to be involuntarily terminated?

Involuntary termination is a termination as directed by the employer.  There can be some gray areas regarding whether a termination was actually an involuntary termination.  For information concerning whether a termination qualifies as an involuntary termination call the U.S. DOL EBSA at 1-866-444-3272.  In the event enrollment for premium reduction is declined because there is a dispute as to whether the termination was an involuntary termination, the affected individual can appeal to the U.S. Department of Health and Human ServicesThe COBRA ARRA web page has been updated with the application to request the Department's review of denials of the COBRA premium subsidy under the American Recovery and Reinvestment Act.  The application is available at www.dol.gov/ebsa/COBRA/main.html which is the first link, Review of Subsidy Denials, under For Employees.  Applicants are encouraged to file their application online.  The application can also be printed and faxed or mailed as indicated on the application.  For appeals of New Jersey Continuation premium reduction denials go to the www.dol.gov/ebsa/COBRA/main.html site and click on the link to the Department of Health and Human Services.

What if an employer goes out of business?  Is New Jersey Continuation still available?

No.  New Jersey Continuation is only available to the extent the employer continues to offer coverage under a group health plan.  If an employer ceases to be in business there will no longer be a group health plan.  Additionally, an employer may remain in business, but cease offering coverage to persons still working in the business.  In both instances, that of a business closing, or employer ceasing to offer coverage, New Jersey Continuation is not available and thus the premium reduction would not be available.

Additionally, while New Jersey Continuation may be available at the time the election is made, such availability will cease if the employer later ceases offering coverage to employees.  Continuation only remains an option to the extent the employer maintains the coverage.

How do individuals sign up for the premium reduction?

For employer groups subject to New  Jersey Continuation, the carrier is required to send a notice to terminated employees so that the former employees whose employment was/is terminated between September 1, 2008 and December 31, 2009 can elect to continue their group coverage and receive the premium reduction.  This is different than for COBRA eligible groups where the employer is required to send the notice. 

The model notices that were released by the U.S. Department of Labor on March 19, 2009 are available on the agency’s web site (www.dol.gov/ebsa/COBRAmodelnotice.html).  The model notices include a notice that could be used for State continuation. 

However, since New Jersey Continuation includes some provisions that are not contemplated by the model notice, we are developing a notice for carriers to use to notify terminated employees of the premium reduction and it will be posted soon. 

Please visit the Latest News section of the Small Employer Health Benefits Program Board web site for the text of the sample notice carriers may use: www.state.nj.us/dobi/division_insurance/ihcseh/sehmain.htm

Does the employer have to do anything for New Jersey Continuation?

Yes.  Although the employers do not send the notice for New Jersey Continuation, the employers nevertheless have a significant role. 

First, whenever an employee ceases to work 25 or more hours per week the employee ceases to be eligible for coverage as a full-time employee.  This is the case whether the employer terminates the employee’s employment, the employee resigns, has a reduction in work hours, or goes out on disability.  Employers should immediately notify the carrier that the employee is not eligible for coverage as of a specific date.  By notifying the carrier promptly, the carrier will be in a position to provide the notice required under ARRA. 

Second, employers must cooperate with the carriers to verify whether a former employee who elected the premium reduction was in fact involuntarily terminated between September 1, 2008 and December 31, 2009. 

Third, if an employer no longer offers group coverage through the carrier whose plan was in effect on the date an employee was involuntarily terminated the employer must provide information regarding whether there is replacement coverage.  If there is replacement coverage, the former employee’s New Jersey Continuation option will be under the replacement carrier’s plan.  The employer must provide a copy of the election form to the replacement carrier. 

Involuntary Termination between September 1, 2008 and February 16, 2009
Employees who were involuntarily terminated between September 1, 2008 and February 16, 2009 must make an election for the premium reduction no later than 30 days following receipt of the notice from the carrier.  This is a special election period.  If the former employee was not already covered under New Jersey Continuation the former employee will also need to elect to continue coverage.  See the next question for more information on this election. 

The premium reduction applies to periods of coverage on or after February 17, 2009.  For plans where the period of coverage begins on the first of the month, the premium reduction was available as of March 1.  If the period of coverage begins on the 15th of the month, the premium reduction was available as of March 15.  Please note that neither the coverage nor the premium reduction will be retroactive to the date coverage endedFurther, a person may not defer the effective date of the continued coverage to a current date.  If the election is made, the coverage must be effective as of the first period of coverage on or after February 17, 2009.  This means a person taking advantage of this special enrollment period will be required to pay the reduced premium for the period beginning with the date the continued coverage takes effect.  Of course, if there were expenses incurred during such period the person may file claims to seek reimbursement.

If a former employee is not eligible for the premium reduction, there is no special enrollment period.  In that case, if the former employee did not previously elect New Jersey Continuation, there is no new opportunity to do so now. 

What happens if an employee was terminated between September 1, 2008 and February 16, 2009 but either did not elect New Jersey Continuation, or elected it then lapsed due to non-payment?

If an employee was involuntarily terminated between September 1, 2008 and February 16, 2009 and initially declined to elect New Jersey Continuation, or elected New Jersey Continuation and later stopped paying premiums, the carrier will notify the former employee of the special enrollment period to elect New Jersey Continuation and the premium reduction.  Such employee will have 30 days from receipt of notice from the carrier to enroll for New Jersey Continuation and elect the premium reduction. 

Coverage for eligible individuals who enroll during this period will:

  • Begin as of the first period of coverage on or after February 17, 2009; coverage is not retroactive to the original termination date, nor can it commence as of a later date. 
  • End on the date coverage would have ended if the eligible individual had elected New Jersey Continuation coverage when he or she first became eligible.  For example, if an employee was involuntarily terminated on September 1, 2008, did not elect New Jersey Continuation after the termination, but now chooses to elect New Jersey Continuation, his or her continuation coverage ends on March 1, 2010 which is 18 months from when he or she first became eligible for New Jersey Continuation. 

When providing coverage to former employees who elect group continuation coverage during this special election period, carriers may not apply pre-existing condition coverage limitations based on a gap in the coverage between the termination of coverage and the commencement of the New Jersey Continuation coverage.

Involuntary termination between February 17, 2009 and December 31, 2009
Employees who are involuntarily terminated between February 17, 2009 and December 31, 2009 must elect New Jersey Continuation within 30 days after receiving notice from the carrier.  The premium reduction must be elected within that same 30 day period. 

Since carriers can only send notice to the former employees to the extent the employer has notified the carrier of the termination it is imperative that employers provide the carrier with timely notice of an employee’s termination. 

What happens if an employee was provided a severance package which included medical benefits when employment terminated? 

The triggering event for continuation is the date coverage was lost and not the date employment terminated.  For example, if an employee was terminated July 1, 2008 and provided a six-month severance package which extended medical benefits, the date coverage is lost will be December 31, 2008.  However, since employment was terminated July 1, 2008, the former employee would not have been involuntarily terminated between September 1, 2008 and December 31, 2009 and thus would not be approved as an assistance eligible individual.  Both the date of termination of employment and the date continuation commences must occur during the September 1, 2008 through December 31, 2009 timeframe.

Suppose both spouses worked and although dependent coverage was an option, each elected employee only coverage.  One spouse is involuntarily terminated from employment.  May such former employee be considered an assistance eligible individual?  May such former employee add the spouse to the former employee’s coverage so both get the benefit of the premium reduction?

No.  The former employee cannot qualify as an assistance eligible individual because such former employee is eligible for coverage under the spouse’s plan.  Eligibility for coverage under another group plan disqualifies a person from the premium reduction. 

As a follow-up to the prior question, suppose the other spouse is also involuntarily terminated and the business shuts down such that there is no opportunity for coverage under that plan.  Could both the former employee and spouse be treated as assistance eligible individuals under the plan of the former employee whose former employer continues to maintain coverage? 

Yes for the former employee.  No for the spouse.  In order to be eligible as an assistance eligible individual the dependent would have to have been covered under the former employee’s coverage on the date before employment terminated.  

How will the reduction be applied to New Jersey Continuation Coverage?

Former employees who qualify for the premium reduction will only be required to pay 35% of the New Jersey Continuation premium.  The carrier initially “pays” the remaining 65%, and the government will later reimburse the carrier through a payroll tax credit.  The New Jersey Continuation premium may actually be 102% of the premium.  The 35% and the 65% are applied to that 102% of premium amount. 

Since COBRA operates a little differently than New Jersey Continuation and the subsidy only lasts up to 9 months, does the new law change any of the provisions of New Jersey Continuation Coverage?

No. 

Duration
Although the premium reduction is available for only a maximum of 9 months, the maximum duration of New Jersey Continuation coverage continues to be 18 months for persons who lose coverage for involuntary termination of employment.  The 9 months of the premium reduction does not operate to reduce the total continuation period available.  The premium for the balance of the period, however, will not be eligible for the premium reduction. 

Coverage for dependents
Under New Jersey Continuation the only person entitled to make an election in the event of involuntary termination of employment is the former employee.  Dependents may be continued as “tag-alongs” but do not have an independent right to elect continuation due to involuntary termination of employment.  This is different from how COBRA operates.  Although a dependent does not have an independent right to elect under New Jersey Continuation, such dependent may nevertheless be independently eligible to be treated as an assistance eligible individual.  For example, if a terminated employee is already eligible for Medicare such former employee does not qualify as an assistance eligible individual.  If the terminated employee nevertheless elects NJ Continuation for himself or herself and dependents, the former employee would be responsible for the full continuation premium for his or her coverage and the reduced premium would apply to the dependents who qualify as assistance eligible individuals.

Election period
Under New Jersey Continuation in connection with the premium reduction, the former employee only has 30 days from receipt of the carrier’s notice in which to elect New Jersey Continuation and apply for the premium reduction.  Please note that all other New Jersey Continuation elections remain subject to the provisions of N.J.S.A. 17B:27A-27 and the 30-day election period is measured from the date coverage terminates.

Domestic partners and civil union partners
Under New Jersey Continuation a covered domestic partner and a covered civil union partner have the opportunity to remain covered as dependents when an employee elects continuation.  While they still have the opportunity to be covered as dependents of the former employee the premium reduction does not apply to coverage for such dependents.  Thus, the former employee may be eligible for the premium reduction and will pay only 35% of the continuation premium for the former employee’s coverage, and the premium to cover the civil union partner or domestic partner will be the full continuation premium for such coverage.

Church groups
Under New Jersey Continuation a church group must allow for continued coverage.  The premium reduction is available to employees who are involuntarily terminated from a church group.  This is different from COBRA which does not require continuation for church groups. 

Does the premium reduction apply to Over Age Dependent Continuation (DU31) or to the extension for disability pursuant to N.J.S.A. 17B:27-51.12?

The premium reduction is not available for over age dependents continuing under P.L. 2005, c. 375, as amended or to a former employee who is disabled who lost coverage due to disability. 

Since New Jersey Continuation is available in the event of a reduction in hours below 25, does the premium reduction apply to an employee whose work hours were reduced below 25, such as to 20 hours per week?

No.  A reduction in work hours is not an involuntary termination of employment and therefore the premium reduction is not available.  New Jersey Continuation is nevertheless available. 

Can an individual lose eligibility for the group continuation premium reduction?

A person can lose eligibility for the New Jersey Continuation premium reduction in two ways.  First, the premium reduction lasts no longer than 9 months.  Second, a person becomes ineligible for the premium reduction when he or she becomes eligible for new group health coverage or Medicare.

  • Continuees must notify their former employer when they become eligible for new group health coverage.
  • Continuees who willfully neglect to notify their former employer of their eligibility for a new group health plan must repay 110% of the subsidy to the federal government.  No such penalty shall be imposed if the continuee demonstrates “reasonable cause” for the failure.

NOTE:  Rules governing eligibility for the premium reduction with New Jersey Continuation differ from rules governing eligibility for New Jersey Continuation without the premium reduction.  Eligibility for New Jersey Continuation without the premium reduction ends only when a continuee actually enrolls in new group coverage or Medicare.  However, simply being eligible for new group health coverage disqualifies an individual from receiving the New Jersey Continuation premium reduction.

What if a carrier fails to send the notice, refuses to allow a former employee whose coverage terminated between September 1, 2008 and February 16, 2009 to now elect New Jersey Continuation or fails to “pay” the 65% of the continuation premium?

The New Jersey Department of Banking and Insurance will take appropriate action to ensure carrier cooperation.  Please contact Ellen DeRosa at 609-633-1882 ext 50302 or by e-mail at ellen.derosa@dobi.state.nj.us or Gale Simon at 609-292-5427 ext 59333 or by e-mail at gale.simon@dobi.state.nj.us.

What if a former employee sends an election to the carrier for the premium reduction and the carrier states the former employee is not eligible? 

The U.S. Department of Health and Human Services will handle appeals related to denials of the premium reduction under State continuation laws.  The COBRA ARRA web page has been updated with the application to request the Department's review of denials of the COBRA premium subsidy under the American Recovery and Reinvestment Act.  The application is available at www.dol.gov/ebsa/COBRA/main.html which is the first link, Review of Subsidy Denials, under For Employees.  Applicants are encouraged to file their application online.  The application can also be printed and faxed or mailed as indicated on the application.  For appeals of New Jersey Continuation premium reduction denials go to the www.dol.gov/ebsa/COBRA/main.html site and click on the link to the Department of Health and Human Services.

What if a New Jersey small employer fails to provide information to a carrier regarding a former employee’s termination or the current status of coverage for the employer group?

The New Jersey Department of Labor and Workforce Development will take appropriate action in the event of an employer’s failure to comply with this law.  Workers who have concerns about their employer’s compliance and/or cooperation with New Jersey Continuation Coverage requirements under the ARRA may contact the New Jersey Department of Labor and Workforce Development, Division of Wage and Hour Compliance, in writing at P.O. Box 389, Trenton, NJ 08625-0389, by telephone at (609) 292-1704 or via e-mail at wage.hour@dol.state.nj.us.  

Workers whose employer is covered under federal COBRA should contact the U.S. Department of Labor, Employee Benefits Security Administration, at 1-866-444-3272.

 
Employers Want to Know….


Please note
:  The following answers apply ONLY if the employer asking the question is a New Jersey employer subject to New Jersey Continuation rather than COBRA. 

1.   I have heard a notice of the premium reduction has to be sent to employees who were terminated as far back as September 1, 2008.  Do I have to send it? 

No.  The carrier, and not the employer, is responsible to send notice to terminated employees.  Notices for people who have already been terminated will be sent to all terminated employees by April 18, 2009. 

2.   Former employees are calling me saying they only need to pay 35% of the cost for continuation coverage.  Is that true?

For former employees who qualify for the premium reduction, the premium for continuation coverage will be reduced to 35% of the cost for up to nine months. 

3.  Some former employees who are already on New Jersey Continuation are telling me they do not need to pay the full continuation premium for March and April.  How should I handle that?

Until a former employee completes the Request for Treatment as an Assistance Eligible Individual, and the Carrier approves it, the former employee must continue to pay the full continuation premium.  If the request is approved, the former employee will receive a credit or refund from the Carrier for the 65% paid for March and April.

4.  I have heard that the employers are required to pay the 65% balance.  What happens if I don’t?

Although it is true that employers subject to COBRA are required to pay the 65% balance it is not true for employers subject to New Jersey Continuation.  For employer groups subject to New Jersey continuation the Carrier, and not the employer, is responsible to “pay” the 65% for the premium reduction.

5.  I don’t have to send notices about the premium reduction and I don’t have to pay 65% of the premium, correct?  So there is nothing an employer has to do in order for a terminated employee to get the premium reduction?

Not exactly, the employer is not responsible for the notice or the 65% payment.  But the employer does have other responsibilities as listed below.

a.   As soon as you have to terminate an employee notify the Carrier and provide the termination date.  If there are employees that you terminated from September 1, 2008 and forward that have not notified the carrier about – do it now!  Unless the carrier knows an employee was involuntarily terminated the Carrier cannot send the notice!

b.  Former employees will receive a package of forms from the Carrier.  There are several forms in the package.  Former employees will complete the forms and send them to the former employer.  There are two forms that require your input. 

Form for Switching Plan Options Please respond to the questions the former employee asks about other plan options.  If there is an alternate plan option available to active employees that would be the same or a lower cost than the plan the former employee had, the former employee may switch.

Employer Information and Verification The carrier has no way of knowing if a person who was terminated from the plan was involuntarily terminated from employment or instead had a reduction in hours that resulted in the loss of coverage.  For employers who may have switched carriers the old carrier has no way to know if the employer still offers a plan.  Please complete the form and sign it.

c.  The former employee will mail all the forms to you.  You must mail the entire package to your current carrier.  If you no longer offer coverage, please mail it to the former carrier so the Carrier will know the terminated employee has no opportunity to elect continuation.  Please complete the Employer Information and Verification immediately since the premium reduction cannot be approved until the carrier has received all the forms.

d.  The premium for former employees electing New Jersey Continuation is paid through the former employer.  Former employees who qualify for the premium reduction will send you 35% of the continuation premium.  Add that money to your monthly premium and mail to the carrier.

6.  Since carriers are now sending notices about continuation, that means I have no more responsibility for notices, right?

Not exactly.  The carrier is responsible for sending notices to involuntarily terminated employees where the termination is between September 1, 2008 through December 31, 2009After December 31, 2009 the employer will again be responsible for providing notice in the event of involuntary termination of employment.

Employers remain responsible for providing notice for all other circumstances that entitle a person to elect continuation.  For example, if a person’s work hours are reduced below 25 the person loses coverage as a full-time employee but has the right to elect New Jersey Continuation.  Other examples are employees who voluntarily resign, or dependents in the event of death or divorce or ceasing to be an eligible dependent.

7.  Where can I find more information?

Please visit the Department of Banking and Insurance website at www.state.nj.us/dobi/division_insurance/arra.html

 

Employees Want to Know…


Please note
:  The following answers apply ONLY if the former employee asking the question worked for a New Jersey employer subject to New Jersey Continuation rather than COBRA. 

1. How do I know if my former employer is subject to New Jersey Continuation or COBRA?

The best way to find out is to ask your former employer.  The general rule is that employers with 20 or more employees are subject to COBRA.  Small employers are subject to New Jersey Continuation.  There are exceptions, and counting to 20 is not as easy as 1, 2, 3 etc.  So, check with your former employer.

2.  I read that a law to help me pay continuation coverage premiums was signed back in February.  I am having a very hard time paying my continuation coverage premiums and I need help now.  How do I get this help?

For people who are eligible, there is help, but it is not automatic.  Former employees need to fill out a request and if it is approved, will have premiums reduced to 35% for up to nine months.  For employer plans subject to New Jersey Continuation the insurance company will send a package of information including the request form.  For people who have already been terminated and elected continuation keep paying the full premium until the request is approved.  After it has been approved the excess already paid (65%) will be credited or refunded to you.

3.  I asked my former employer about the premium reduction and he said he knows nothing about it.  What can I do?

If your former employer is subject to New Jersey Continuation the insurance company, not the former employer, will be the one sending you information. 

4.  When can I expect the information from the insurance company?

If you were already terminated the information will be set no later than April 18, 2009.  For new terminations it will be sent after the employer notifies the insurance company of the termination of employment.

5.   What do I have to do?

The package of information will include a cover letter that will provide general information.  There will be some forms included.

a. New Jersey Continuation Election Form.  If you were involuntarily terminated between September 1, 2008 and December 31, 2009 and have not already elected New Jersey Continuation you can use this form to elect continuation.

b.  Form for Switching Plan Options.  Some employers offer more than one plan.  If your former employer does, and other option would be the same or lower cost than the coverage you had before you were terminated, you may switch.  Contact your former employer for details on other plans options, if any.

c.  Employer Information and Verification.  All you have to do with this form is fill in your name.  The former employer will complete the rest.

d. Request for Treatment as an Assistance Eligible Individual.  This is the form to apply for the premium reduction.  Answer all questions, front and back.

Complete and mail all the forms to your former employer. 

6.  After I mail the forms, then what?

Your former employer will complete the information necessary and forward the forms to the current insurance company. 

If your request for Treatment as an Assistance Eligible Individual is approved your continuation premium will be reduced to 35% for up to nine months. 

If your request for Treatment as an Assistance Eligible Individual is not approved you will have a right to appeal to the U.S. Department of Health and Human Services.  Health and Human Services is working on the process for an appeal and an appeal form.

7.  Who do I pay?

Send the 35% payment to your former employer who will add it to the premium being sent to the insurance company.  The 35% you send will be accepted as the total amount you are responsible to pay for up to nine months.

8.  Could the premium reduction end before nine months are up?

Yes.  The premium reduction will end earlier if:

a. If you become eligible for coverage under a group plan or under Medicare.  If you do become eligible you will need to notify the insurance company right away.  There is a form the insurance company will send to you that addresses eligibility for group health plan coverage or Medicare.  Be sure to send it in right away because failure to notify the insurance company of such eligibility will result in a penalty equal to 110% of the premium provided after your eligibility for the premium reduction ends.

b.  You fail to pay the premium

c.   Your former employer ceases offering group health coverage to employees.

9.  What should I do if I was involuntarily terminated and do not get a package with forms from the insurance company?

First, it would be a good idea to check with your former employer.  Did your former employer notify the insurance company that your employment was terminated?  If no, the insurance company would not have known to send you a package of information.  Ask the former employer to notify the insurance company that you were terminated and the date of termination.  If the former employer is not cooperative you may contact Ellen DeRosa at 609-633-1882 ext 50302 or by e-mail at ellen.derosa@dobi.state.nj.us or Gale Simon at 609-292-5427 ext 59333 or by e-mail at gale.simon@dobi.state.nj.us  or the New Jersey Department of Labor and Workforce Development, Division of Wage and Hour Compliance, in writing at P.O. Box 389, Trenton, NJ 08625-0389, by telephone at (609) 292-1704 or via e-mail at wage.hour@dol.state.nj.us.

If the former employer did notify the insurance company that you were involuntarily terminated from employment, contact Ellen DeRosa at the contact information listed above.  Please be prepared to give the name of the insurance company and the ID number you had when you were covered.

10.  What should I do it my former employer fails to send the forms to the insurance company?

If the former employer does not send the forms to the insurance company the insurance company will have no verification as to your status and will deny the request to be an assistance eligible individual.  You will have a right to appeal the denial to the U.S. Department of Health and Human Services.  Health and Human Services is working on the process for an appeal and an appeal form.  Additionally, you may contact the New Jersey Department of Labor and Workforce Development, Division of Wage and Hour Compliance, in writing at P.O. Box 389, Trenton, NJ 08625-0389, by telephone at (609) 292-1704 or via e-mail at wage.hour@dol.state.nj.us.

11.  Where can I find more information?

Please visit the Department of Banking and Insurance website at www.state.nj.us/dobi/division_insurance/arra.html


 
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