HB1295

I am writing to respectfully oppose this bill and urge the committee to vote it Inexpedient to Legislate (ITL). Continuing Care Retirement Communities (CCRCs) operate under a unique and highly regulated model. CCRCs offer life care contracts, which function in many ways like a long-term care insurance product. Residents pay significant entrance and monthly fees in exchange for a contractual promise of care across the continuum—independent living, assisted living, and skilled nursing—through the end of life. Because of this structure, CCRCs are regulated by the New Hampshire Insurance Department, not merely as housing providers, but as entities carrying long-term actuarial and financial obligations. Mandating open enrollment and requiring CCRCs to provide below-cost services to at least 20 percent of residents directly conflicts with existing New Hampshire Insurance Department regulations. These regulations are designed to ensure CCRCs remain financially solvent so they can meet their long-term promises to residents. Imposing below-cost care requirements undermines actuarial assumptions, threatens reserve requirements, and ultimately jeopardizes the financial stability—and potential survival—of CCRCs. Additionally, forcing CCRCs into Medicaid participation represents a reversal of long-standing state policy. CCRCs were intentionally structured to reduce reliance on Medicaid by encouraging private pre-funding of long-term care. Requiring Medicaid participation would not only increase state Medicaid expenditures but would also weaken the financial model that allows CCRCs to remain viable and self-sustaining. The bill’s requirement that providers “quantitatively demonstrate” that they reduce government burden is also problematic. This language is vague and subjective, and it conflicts with the existing legal standard outlined in RSA 72:23 I. Under current law, an organization qualifies as charitable if it provides a public benefit that advances the well-being of the general public. That standard does not—and should not—depend on whether an organization can prove direct cost savings to government programs. CCRCs already provide substantial public benefit by offering housing stability, health care access, workforce employment, and reduced strain on public long-term care systems. Altering the legal and regulatory framework in this way would create uncertainty, discourage investment, and place long-term care promises to current residents at risk. For these reasons, I respectfully urge the committee to vote this bill ITL (Inexpedient to Legislate). Thank you for your consideration. Michael Flaherty President/CEO Taylor Community

Thank you, Mr. Chair and members of the Committee. I write in opposition to this bill. Continuing Care Retirement Communities (CCRCs) provide life care contracts that function as a form of long-term care insurance, guaranteeing care through end of life. As such, CCRCs are already regulated by the New Hampshire Insurance Department to ensure financial solvency and consumer protection. Mandating open enrollment and requiring below-cost services for at least 20 percent of residents directly conflicts with these regulations and threatens the financial stability—and potential survival—of CCRCs. Additionally, forcing CCRCs to participate in Medicaid reverses longstanding state policy and would likely increase, rather than reduce, state Medicaid spending while undermining providers’ ability to remain viable. The bill’s requirement that providers “quantitatively demonstrate” a reduction in government burden is vague and inconsistent with RSA 72:23, I, which defines charitable status based on providing a public benefit that advances the well-being of the general public—not on whether an organization saves the government money. For these reasons, I respectfully urge the Committee to find this bill Inexpedient to Legislate (ITL). Thank you for your consideration. Respectfully, Christine Battisti

I support the spirit of this bill, but the current language is restrictive to the point of damaging the intention of the provision. For example, this is meant to apply to the elderly and disabled housing, but I(b) says service to elderly persons and could be construed to mean that all housing must have an open enrollment for elderly seeking services.

I oppose due to: 1. CCRCs are regulated by the Department of Insurance. 2. Mandating open enrollment and below cost services for at least 20% of residents directly conflicts with NH Department of Insurance rules for CCRCs, threatening the financial stability and even survival of CCRCs. 3. Forcing CCRCs into Medicaid participation would reverse previous state policy and would drive up state Medicaid spending while undermining providers’ ability to remain viable. 4. The bill’s requirement that providers “quantitatively demonstrate” they reduce government burden is vague and conflicts with the existing legal standard in RSA 72:23-I. Under current law, an organization is considered charitable if it provides a public benefit that advances the well being of the general public - not based on whether it saves the government money. 5. I urge the committee to vote this bill ITL.

To the Committee: I am the executive director of Alice Peck Day Lifecare Center in Lebanon. The Sponsor’s intent to target just CCRCs in HB 1295 is misinformed. The bill would impose broad new requirements on all nonprofit senior housing and care providers—not just CCRCs. Our independent living facility, The Woodlands, is regulated as a CCRC but we are not a true CCRC. This bill would negatively affect my organization. The bill’s requirement that providers “quantitatively demonstrate” they reduce government burden is vague and conflicts with the existing legal standard in RSA 72:23 I. Under current law, an organization is considered charitable if it provides a public benefit that advances the well-being of the general public—not based on whether it saves the government money. I urge the committee to vote this bill ITL (Inexpedient to Legislate). With urgency, Nicole Fortier

To Whom It May Concern: New England Deaconess Association has served older adults in New England for 136 years and currently serves at Wesley Woods. We offer reasonably priced housing and community life to 40 individuals and couples in Gilford New Hampshire. It is the role of the board of a not for profit to define mission and service and we are proud of both - providing significant charitable contributions to countless individuals over the past decades. The Sponsor’s intent to target just CCRCs in HB 1295 is misinformed. The bill would impose broad new requirements on all nonprofit senior housing and care providers—not just CCRCs. Wesley Woods has already been defined as a CCRC by the state of New Hampshire despite a number of facts that identify it otherwise. These regulations are driving up costs for the middle market . By definition, we as officers The bill’s requirement that providers “quantitatively demonstrate” they reduce government burden is vague and conflicts with the existing legal standard in RSA 72:23 I. Under current law, an organization is considered charitable if it provides a public benefit that advances the well being of the general public—not based on whether it saves the government money. We are proud that we provide services to all income levels and regulations can have the unintended consequence of increasing the cost to the average consumer. I urge the committee to vote this bill ITL (Inexpedient to Legislate). Sincerely, Chris Sintros

I strongly oppose HB 1295 because its eligibility requirements would make it significantly harder for charitable and nonprofit housing providers to operate in New Hampshire. The bill imposes unrealistic financial burdens, creates multiple new veto points for municipalities, and conflicts with how affordable housing is financed and regulated. Nonprofit developers are essential to producing deeply affordable and supportive housing, and narrowing their eligibility will reduce housing supply and harm the very residents these organizations serve. New Hampshire needs fewer barriers to nonprofit housing, not more.

Dear Members of the Committee, I am writing in opposition to HB 1295, relative to eligibility requirements for charitable and nonprofit housing projects. Area agencies across New Hampshire are already struggling to meet growing demand with limited funding, staffing shortages, and increasing operational costs. These agencies provide essential housing, support, and services to individuals with disabilities, seniors, and low-income residents. Any policy change that creates additional financial uncertainty or administrative burden puts those services at risk. HB 1295 restricts the ability of municipalities to apply local eligibility standards when determining tax exemptions for charitable and nonprofit housing projects. This loss of local discretion could destabilize existing partnerships between municipalities and area agencies that depend on predictable tax and funding structures to operate sustainably. If municipalities are required to grant broader tax exemptions without the ability to assess local impact, the resulting strain on municipal budgets may lead to reduced support for the very programs and services that area agencies rely on. In turn, area agencies may face higher costs, reduced capacity, or delays in expanding or maintaining housing options for vulnerable populations. Affordable housing policy must recognize current system pressures. At a time when area agencies are already operating at capacity, HB 1295 risks adding new challenges rather than meaningful solutions. Local governments must retain the flexibility to balance housing needs with fiscal responsibility and community-specific considerations. For these reasons, I respectfully urge the Committee to oppose HB 1295. Thank you for your time and consideration. Respectfully submitted, Angela Fletcher Stoddard NH

Position recorded without written comment.

Position recorded without written comment.

Position recorded without written comment.

Position recorded without written comment.