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APA Comments on Employer-Integrated EIA in New Jersey

BY: Mike Linehan | 01/18/22

In comments to New Jersey Sen. Majority Whip and bill sponsor Nicholas Scutari and Chair of the Senate Commerce Committee Nellie Pou, the APA supported – with recommendations – amendments to S.B. 3611 regarding earned income access (EIA) services. With revisions, the bill passed favorably out of committee on December 16, 2021. The bill would need to be passed by both houses of the New Jersey legislature and signed by the governor to become a law.

Clarity Needed on Definitions

The bill would allow use of employer-integrated EIA services in the state but initially failed to recognize all models available to employers. In the revised version of the bill, the definition changed to show the bill does not apply to internal employer programs. Language also was added to clarify that the definition of EIA services does not include payday advances or direct-to-consumer models.

Program Limits Should be Data Driven

Original bill language included a limit on EIA services to two times a week or unlimited if employees are given a no-fee option. The APA expressed preference for employers to make the determination on program limits. In addition, any consideration of limits should be data driven. The revised bill eliminated the use limits.

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Mike Linehan is the Assistant Manager of Government Relations for the APA.