In the Matter of Hudson County medical/fiscal Administration, Etc.

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 1, 2025
DocketA-4144-23
StatusUnpublished

This text of In the Matter of Hudson County medical/fiscal Administration, Etc. (In the Matter of Hudson County medical/fiscal Administration, Etc.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of Hudson County medical/fiscal Administration, Etc., (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4144-23

IN THE MATTER OF HUDSON COUNTY MEDICAL/FISCAL ADMINISTRATION AT THE HUDSON COUNTY CORRECTIONAL CENTER. ____________________________

Argued September 16, 2025 – Decided December 1, 2025

Before Judges Rose, DeAlmeida and Torregrossa- O'Connor.

On appeal from the New Jersey Office of the State Comptroller.

Cindy Nan Vogelman argued the cause for appellant County of Hudson (Chasan Lamparello Mallon & Cappuzzo, PC, attorneys; Cindy Nan Vogelman, on the briefs).

Jennifer A. Hradil argued the cause for respondent New Jersey Office of the State Comptroller (Gibbons, PC, attorneys; Peter J. Torcicollo, Jennifer A. Hradil, Kevin W. Weber, Ryan P. Goodwin and Julia E. Browning, on the brief).

PER CURIAM The County of Hudson (County) appeals from the August 5, 2024 final

agency decision of the Office of the State Comptroller (OSC) finding the County

failed to comply with the notice and public bidding requirements established in

the Local Public Contracts Law (LPCL), N.J.S.A. 40A:11-1 to -60, when it

awarded a contract to provide medical care, mental health care, and related fiscal

management at the Hudson County Correctional Center (HCCC) for the period

April 1, 2024, to March 31, 2025, and directing the County to comply with the

LPCL when it takes any action to renew or award the contract for any period

beginning April 1, 2025, or thereafter. We affirm.

I.

This matter concerns the statutory authority of the State Comptroller with

respect to the procurement of contracts by local public entities. A review of the

relevant statutory provisions is necessary to place the facts in context.

The State Comptroller is authorized to "monitor the process of soliciting

proposals for, and the process of awarding, contracts made by . . . units of local

government . . . that involve a significant . . . expenditure of funds." N.J.S.A.

52:15C-7(b). To facilitate this authority,

[a] contracting unit shall inform the State Comptroller in writing . . . of the commencement of any procurement process involving consideration or an expenditure of [$12,500,000] or more at the earliest time practicable

A-4144-23 2 as the contracting unit commences the procurement process but no later than the time the contracting unit commences preparation of: any bid specification or request for proposal.

[N.J.S.A. 52:15C-10(b)(1).]1

Notification triggers a thirty-day pause in the procurement process.

N.J.S.A. 52:15C-10(b)(2) provides:

Unless waived by the State Comptroller upon request of the contracting unit, at least [thirty] days shall elapse from the time the contracting unit informs the State Comptroller pursuant to paragraph (1) of this subsection and the time the contracting unit may issue any public advertising, notice of availability of a request for proposals or any other public or private solicitation of a contract for a procurement that is subject to this subsection in order that the State Comptroller may complete a review that may be undertaken pursuant to [N.J.S.A. 52:15C-10(b)(4)].

Once a contracting unit provides information and documents concerning

the proposed procurement, "the State Comptroller may review such submission

and provide a written determination to the contracting unit regarding whether

1 Although N.J.S.A. 52:15C-10(b)(1) sets a threshold of $10,000,000 for notification, N.J.S.A. 52:15C-10(d) directs the State Comptroller, after consultation with the Department of the Treasury, to periodically adjust the notification threshold pursuant to specified criteria. The State Comptroller adjusted the notification threshold under N.J.S.A. 52:15C-10(b)(1) to $12,500,000, effective July 1, 2020. 52 N.J.R. 1443 (b). A-4144-23 3 the procurement process complies with applicable public contracting laws, rules,

and regulations." N.J.S.A. 52:15C-10(b)(4).

If the State Comptroller determines that the procurement process does not comply with applicable public contracting laws, rules, and regulations, the State Comptroller shall direct the contracting unit not to proceed with the procurement. In such an instance, the State Comptroller shall state the reasons for such determination and may include in its determination guidance to the contracting unit regarding an appropriate procurement process.

[Ibid.]

The State Comptroller may also "propose and enforce remediation plans" for

local government units "that are found by the State Comptroller to have deficient

practices or procedures." N.J.S.A. 52:15C-8(a).

"A contracting unit may proceed with a planned procurement . . . after the

expiration of the [thirty]-day period or the granting of a wavier" by the State

Comptroller "unless it receives a written determination not to proceed from the

State Comptroller within [fifteen] business days of the date the contracting unit

provided written notice to the State Comptroller." N.J.S.A. 52:15C-10(b)(4).

A. The 2018 HCCC Medical Services Contract.

The County is a local government unit whose contract procurement

practices are subject to the State Comptroller's review. N.J.S.A. 52:15C-10(a).

A-4144-23 4 On May 1, 2018, the County sent contract specifications to ten preselected

vendors soliciting proposals to provide medical care, mental health care, and

related fiscal management at the HCCC. The specifications indicated the

County sought not only the professional services of physicians , other medical

personnel, and unlicensed staff, but also related fiscal and administrative

services to operate all aspects of a health care facility within the HCCC. The

County did not publicly advertise it was issuing the contract specifications or

provide a means by which potential bidders, other than the ten preselected

vendors, could obtain a copy of the specifications.

On May 14, 2018, the County wrote to the State Comptroller informing

him for the first time it had solicited contract proposals from ten preselected

vendors and would not engage in competitive bidding for the HCCC services.

According to the County, neither public bidding nor competitive contracting was

necessary because the services sought in the contract were professional in nature

pursuant to N.J.S.A. 40A:11-5 and :11-2(6). The County stated it expected the

contract value to exceed $10 million, and it intended to select a vendor and

subsequently negotiate a contract with the vendor.2 The County expected

responses from the preselected vendors by June 11, 2018.

2 At the time, the statutory notification threshold was $10,000,000. A-4144-23 5 The County wrote to the State Comptroller again on May 24, 2018, stating

an emergent need existed to replace the then-existing contract for health care

services at the HCCC. The County requested the State Comptroller waive his

review of the contract specifications pursuant to N.J.S.A. 52:15C-10(b).

Alternatively, the County offered to postpone the June 11, 2018 contract

proposal due date.

On May 31, 2018, the OSC replied in writing, noting the County's failure

to comply with the notification provisions of N.J.S.A. 52:15C-10(b)(1), and

acknowledging the urgent nature of the procurement due to recent inmate and

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