373-26E•Kreyco, Inc., d/b/a Reimagine Education Group v. New Jersey Department of Education, Office of Recruitment, Preparation, and Certification, 9/16/26 (#373-26E)
Kreyco, Inc., d/b/a Reimagine Education Group v. New Jersey Department of Education, Office of Recruitment, Preparation, and Certification, 9/16/26 (#373-26E)
373-26ENjcommned
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373-26E OAL Dkt. No. EDU 12845-26 Agency Dkt. No. 334-07-26 New Jersey Commissioner of Education Order on Emergent Relief Kreyco, Inc., d/b/a Reimagine Education Group, Petitioner, v. New Jersey Department of Education, Office of Recruitment, Preparation, and Certification, Respondents. The record of this emergent matter, the sound recording of the hearing held at the Office of Administrative Law (OAL), and the recommended Order of the Administrative Law Judge (ALJ) have been reviewed and considered. Upon review, the Commissioner concurs with the ALJ that petitioner has failed to demonstrate entitlement to emergent relief pursuant to the standards enunciated in Crowe v. DeGioia, 90 N.J. 126, 132-34 (1982), and codified at N.J.A.C. 6A:3-1.6. Accordingly, the recommended Order denying petitioner’s application for emergent relief is adopted. This matter shall continue at the OAL with such proceedings as the parties and the ALJ deem necessary to bring it to closure. IT IS SO ORDERED. COMMISSIONER OF EDUCATION Date of Decision: September 16, 2026 Date of Mailing: September 17, 2026
New Jersey is an Equal Opportunity Employer State of New Jersey OFFICE OF ADMINISTRATIVE LAW ORDER DENYING EMERGENT RELIEF OAL DKT. NO. EDU 12845-26 AGENCY DKT. NO. 334-07-26 KREYCO INC., d/b/a REIMAGINE EDUCATION GROUP, Petitioner, v. NEW JERSEY DEPARTMENT OF EDUCATION OFFICE OF RECRUITMENT, PREPARATION, AND CERTIFICATION, Respondent. __________________________________ Melissa J. Hordichuk, Esq., for petitioner (AJP Law, attorneys) for petitioner Vijayasri Aryama, Deputy Attorney General (Jennifer Davenport, Attorney General of New Jersey, attorney) for respondent BEFORE, BARBARA SINGER, ALJ: STATEMENT OF THE CASE New Jersey Department of Education (NJDOE) withdrew approval for Reimagine’s Educators Preparation Program (EPP) since petitioner did not submit an application in its desired alternate name, Kreyco, as directed by the NJDOE, and NJDOE denied Kreyco’s
OAL DKT. NO. EDU 12845-26 2 pending applications due to Kreyco advertising as an approved provider when it was not. Was the NJDOE authorized to withdraw the EPP approval and deny the applications? Yes. The DOE is responsible for processing applications and to grant or deny approvals. N.J.A.C. 6A:9A-3.1. PROCEDURAL HISTORY On April19, 2024, NJDOE approved Reimagine Education Group as a provider of a Certificate of Eligibility Educator Preparation Program (CE-EPP), which is a training program for New Jersey public school teachers. Through the CE-EPP, the teachers can obtain a standard certificate of eligibility. On December 19, 2024, the DOE approved Reimagine’s participation as a CE-EPP provider in a limited pilot program, through September 1, 2027. On July 17, 2026, the NJDOE withdrew approval for Reimagine to run its EPP and also denied petitioner’s applications under its business name, Kreyco. That same day, July 17, 2026, petitioner immediately requested reconsideration and a partial stay to the action. On July 30, 2026, the DOE acknowledged receipt of the request and advised that the request was under review. On August 3, 2026, petitioner submitted a Petition for Appeal accompanied by a motion for emergent relief, with the DOE, Office of Controversies and Disputes, under N.J.A.C. 6A:3-1.6. On August 4, 2026, the DOE transmitted the motion for emergent relief to the Office of Administrative Law (OAL) for a determination as a contested case for a hearing under the Administrative Procedure Act, N.J.S.A. 52:14B-1 to -15, and the Uniform Administrative Procedure Rules, N.J.A.C. 1:1-1.1 to -21.6. On August 7, 2026, DOE submitted its opposition to the motion, and on August 10, 2026, Kreyco submitted its reply. On August 10, 2026, I held oral argument.
OAL DKT. NO. EDU 12845-26 3 FINDINGS OF FACT Based on the papers the parties submitted in support of and in opposition to the motion for emergent relief, and based on the arguments the parties presented during oral argument, I FIND the following as FACT for purposes of this motion only: On July 12, 2021, the New Jersey Department of the Treasury, Division of Revenue and Enterprise Services, issued a Certificate of Alternate Name to petitioner, Kreyco, Inc., for the alternate names, Reimagine Education Group and Helping Hands Art & Exercise, which was valid until July 12, 2026. Almost three years later, on April 19, 2024, the NJDOE approved Reimagine Education Group (Reimagine) as a provider of a CE-EPP program under the business name Reimagine Education Group (Reimagine), and on December 19, 2024, the NJDOE approved Reimagine’s participation as a CE-EPP provider in a limited pilot program through September 1, 2027. Almost nine months later, in September 2025, petitioner asked DOE if it could use the corporate name Kreyco instead of the business name Reimagine and followed up with DOE in the ensuing months to learn the answer. On March 12, 2026, the NJDOE withdrew its previous approval for Reimagine to operate the CE-EPP program, based on the name change request. The NJDOE reminded petitioner that the DOE needed to approve the corporate name, Kreyco, before it could allow petitioner to use it. Petitioner had to immediately cease enrolling new candidates under either name, submit a roster of current enrollees, and submit a teach- out plan. However, if Kreyco applied for the CE-EPP under the previously approved CE- EPP for Reimagine, then it could continue to enroll candidates under the corporate name, Kreyco. Finally, the NJDOE advised petitioner that it needed to create a new provider profile under the Kreyco name in the application portal and could not work under a revised portal profile for Reimagine.
OAL DKT. NO. EDU 12845-26 4 Soon after March 12, 2026, petitioner applied to the NJDOE to run new and different programs under the name Kreyco but never applied to run the previously approved CE-EPP under the name Kreyco. On April 24, 2026, the NJDOE advised petitioner that because its applications were for new EPPs for Kreyco which did not align with the previously approved EPP for Reimagine, the applications required complete review. The NJDOE also reiterated that it could expedite Kreyco’s application process for the previously approved CE-EPP if petitioner applied to run that exact previously approved program. Moreover, the NJDOE reiterated that the previously approved program for Reimagine could continue to operate if Kreyco applied for approval with that same program. Meanwhile, during the review process for the new Kreyco applications, the NJDOE learned that Kreyco was already holding itself out to the public as an approved program provider for the NJDOE, that additional program endorsements were coming soon, and that those approvals were expected by September 2026. On July 17, 2026, the NJDOE notified petitioner that it must cease enrolling new candidates under both Kreyco and Reimagine immediately. It also withdrew approval of the CE-EPP for Reimagine based on lack of an application from Kreyco which would have allowed the program to continue running under the requested alternate name. The NJDOE directed petitioner to submit a plan for closure of its CE-EPP for Reimagine. The July 17, 2026, letter from the NJDOE also rejected Kreyco’s pending applications for new program approvals and instructed petitioner to cease its misleading marketing. CONCLUSIONS OF LAW To prevail on a motion for emergent relief or a stay, the petitioner must submit a letter memorandum or brief, which addresses the standards for emergent relief set forth in Crowe v. DeGioia, 90 N.J. 126 (1982): (1) the petitioner will suffer irreparable harm if the requested relief is not granted; (2) the legal right underlying the petitioner's claim is settled; (3) the petitioner has a likelihood of prevailing on the merits of the underlying claim; and (4) the equities and interests of the parties are balanced, the petitioner will
OAL DKT. NO. EDU 12845-26 5 suffer greater harm than the respondent will suffer if the requested relief is not granted. N.J.A.C. 6A:3-1.6. The petitioner must prove each element by “clear and convincing” evidence. Waste Management of N.J. v. Union County Utilities Authority, 399 N.J. Super. 508, 520 (App. Div. 2008). Irreparable harm is described as “‘substantial injury to a material degree coupled with the inadequacy of money damages.’” Judice’s Sunshine Pontiac, Inc. v. General Motors Corp., 418 F. Supp. 1212, 1218 (D.N.J. 1976) (citation omitted). Irreparable harm must be more than a risk of irreparable harm or threat of future injury. Continental Group, Inc. v. Amoco Chemicals Corp., 614 F. 2d 351, 359 (D.N.J. 1980). Regarding this first prong, Kreyco has not demonstrated that it will suffer irreparable harm if emergent relief is not granted. In March 2026, the NJDOE presented Kreyco with an expedited path forward to obtain approval for a CE-EPP for Kreyco. However, petitioner did not pursue that option. That was petitioner’s prerogative but choosing not to pursue that path does not convert petitioner’s circumstance into an emergent one. Petitioner is not foreclosed from reapplying. With respect to irreparable harm to any current enrollees, Kreyco previously advised the NJDOE that it did not have enrollees in its programs. In court though, petitioner presented an unverified list of 28 names registered from May 15, 2026, through July 17, 2026. Even if verified, Kreyco did not present evidence of irreparable harm to them. Furthermore, on July 17, 2026, Kreyco was directed to establish a teach-out plan by August 14, 2026, which would assist the enrollees in their next steps. Therefore, I CONCLUDE that petitioner has not demonstrated irreparable harm. Regarding the second and third prongs, the law is well settled, but petitioner did not demonstrate that it has a likelihood of success on the merits. The DOE is responsible for processing applications and grant or deny approvals. N.J.A.C. 6A:9A-3.1. The NJDOE is authorized to withdraw program approval or to require corrective action for a failing program or program at risk of failing. N.J.A.C. 6A:9A-3.3(d). DOE granted program approval to petitioner under its business name, Reimagine, and advised petitioner that its
OAL DKT. NO. EDU 12845-26 6 corporate name, Kreyco, required a separate program approval. The NJDOE also provided corrective action. Yet petitioner chose not to follow this advice or take this action. With respect to the new Kreyco applications still under review, the NJDOE denied them. This action is within their statutory authority. Therefore, I CONCLUDE that Kreyco has not demonstrated a likelihood of success on the merits. Finally, regarding the fourth prong, when balancing the equities and interests of the parties, petitioner will not suffer greater harm if the requested relief is not granted. In short, the NJDOE is responsible to the public to ensure that educators improve the quality of instruction and prepare New Jersey’s students for their future. N.J.A.C. 6A:9A-1.2. It would ultimately be most equitable to the NJDOE and the public’s interest to have appropriate standards and requirements followed for each provider’s application to ultimately ensure these goals. Therefore, I CONCLUDE that petitioner has not demonstrated that it will suffer greater harm if the requested relief is not granted. ORDER Given my findings of fact and conclusions of law, I ORDER that petitioner’s motion for emergent relief is DENIED.
OAL DKT. NO. EDU 12845-26 7 This order on application for emergency relief may be adopted, modified, or rejected by the COMMISSIONER OF EDUCATION, who by law is authorized to make a final decision in this matter. The final decision shall be issued without undue delay, but no later than forty-five days following the entry of this order. If the COMMISSIONER OF EDUCATION does not adopt, modify, or reject this order within forty-five days, this recommended order shall become a final decision on the issue of emergent relief in accordance with N.J.S.A. 52:14B-10. August 14, 2026 DATE BARBARA SINGER, ALJ Date Received at Agency: 8/14/26 Date Mailed to Parties: 8/14/26 BCS/id
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