NJ's Certificate of Need: Full Review, Expedited Review, and the Exemption Map

NJ CN at a glance

• Administered by NJDOH Office of Certificate of Need and Healthcare Facility Licensure.
• Two review tracks — full review and expedited review.
• 12 review cycles per year in both tracks, each beginning the first business day of the month.
• Decisions rendered in 90-180 days depending on track and batch size.
• Large list of exempt services via statutory exemptions layered over decades.

Primary source: nj.gov/health (Office of Certificate of Need and Healthcare Facility Licensure).

Full review — what requires it

Full review covers extensive changes and new facilities/services:

• Long-term care projects (general, ventilators, pediatric).
• Establishment of a new facility or service.
• Rehabilitation beds.
• New assisted living facilities.
• Maternal and child health projects.
• Pediatric intensive care.
• Children's hospitals.
• Psychiatric beds.
• Transplantation services.
• Mobile intensive care units.
• Trauma units.
• Home health services.
• Burn centers and programs.
• New general hospitals.
• Capacity changes to hospital sub-acute care units.
• Termination/discontinuance of a service or facility and/or reduction of licensed bed capacity.
• Transfer of a healthcare service/facility.

Expedited review — what qualifies

• Change in capacity of an existing facility or service.
• Acquisition or replacement of major movable equipment.
• Change in scope or location of an unimplemented CN.
• Change in cost of an unimplemented CN.
• Extension of time for an unimplemented CN.
• Transfer of ownership of a general hospital.

Exempt services

Not all healthcare projects trigger CN. NJ's deregulation since 1998 removed review for:

• Community-based primary care centers.
• Outpatient drug and alcohol services.
• Hospital-based medical detoxification.
• Ambulance and invalid coach services.
• Non-bed related outpatient mental health services.
• Residential health care facility services.
• Dementia care homes.
• Capital improvements and renovations to healthcare facilities.
• Ambulatory surgical centers (per 1998 Reform Act).
• Lithotripsy and certain other technologies (1998 Reform Act).
• Basic obstetric and pediatric services (1998 Reform Act).
• Inpatient psychiatric hospital beds for psychiatric + substance use dual-diagnosis treatment (2017 legislation).

This exemption map is the single biggest reason NJ CN feels less burdensome than some neighboring states' CONs for certain project types (ASCs, outpatient services). Verify exemption status with counsel against current statute before assuming.

Fee structure

• Total Project Cost (TPC) ≤ $1,000,000 — flat $7,500 fee.
• TPC > $1,000,000 — $7,500 plus 0.25% of TPC.
• Change in cost for projects ≥ $1,000,000 — 0.25% of additional project cost over $1,000,000.
• Change in scope or extension of time — $7,500.
• Large projects (>$15,000,000) — additional independently-verified historical and projected financial and utilization information required.

Fees payable to "Treasurer, State of New Jersey" via certified check, cashier's check, or money order. Non-refundable.

Full review timeline

1. Annual schedule publication. Commissioner publishes an annual anticipated schedule for receiving full review CN applications in the NJ Register, typically February, covering a two-year period.
2. Needed services identified. The published notice identifies needed services, geographic areas, and application due dates.
3. Minimum 90-day notice. At least 90 days between notice publication and application submission deadline.
4. Application submission per scheduled deadline.
5. Completeness review. Only complete applications processed; incomplete applications may be rejected with fee returned.
6. State Health Planning Board recommendation. Within 90 days after application is deemed complete.
7. Commissioner's decision. For batched applications <20: no later than 120 days after SHPB recommendation. For batches ≥20: no later than 180 days.
8. Non-batched full review applications flow through 12 monthly cycles.

Expedited review timeline

• 12 review cycles per year, first business day of each month.
• Commissioner renders decision no later than 90 days after the first day of the review cycle (unless otherwise specified).

The application packet

• Forms: CN-1 (Long Term Care), CN-3 (Hospital-Related Projects), CN-19 (Expedited Review).
• Submission: one electronic media copy plus paper copies — 35 for full review, 10 for expedited.
• Filing fee as above, non-refundable.
• Track record reports — out-of-state applicants provide compliance history for 12 months preceding application.
• Construction requirements — architectural plans to Department of Community Affairs; construction cost and space breakdown report with application.
• Financial information — project costs, financing methods. Large projects (>$15M) require independently verified financial and utilization info.
• Pre-application consultation strongly encouraged with NJDOH staff.

Post-approval workflow — construction to licensure

• DCA construction approval. Architectural plans reviewed for construction under NJ UCC (see our Camden UCC essay for the UCC model).
• Operational survey arranged 45 days before planned opening with the relevant NJDOH inspection unit (Ambulatory/Medicare Inspections for ambulatory care; Certificate of Need and Licensing for hospitals).
• Licensure mandatory before commencement of new/expanded services. Issued after:
  • DCA construction approval,
  • Regulatory compliance verification,
  • Certificate of Occupancy.

How NJ CN compares to the other Mid-Atlantic states

• Delaware CPR. $5.8M inflation-adjusted capital threshold, HRB administration. See our DE CPR essay.
• Virginia COPN. Seven batching groups, 120/190-day review window, DCOPN administration. See our VA COPN essay.
• Maryland CON. MHCC administration with OHCQ licensure separation.
• Pennsylvania. No CON (repealed 1996). Licensure only.
• New Jersey CN. Full/expedited split, extensive exemption map from multiple deregulation rounds, monthly review cycles.

For the broader comparison, see our Certificate of Need Across the Mid-Atlantic essay.

What to do with this

If you're planning an NJ healthcare project: determine first whether the project is exempt, expedited-review, or full-review. This shapes cost, schedule, and complexity dramatically.

If expedited: file into a monthly cycle; 90-day decision timeline.

If full review: track the annual schedule publication in the NJ Register; work backward from application deadlines.

If project cost >$15M: prepare independently-verified financial documentation early.

If out-of-state applicant: gather 12 months of compliance track record documentation.

For CN vs licensure context, see our CON vs Licensure essay.

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