Skip to content
Intelligence Briefing

Certificate of Need Laws:

The Architecture of a Healthcare Monopoly

In 35 jurisdictions, it is illegal to open a hospital, surgery center, or imaging facility without government permission. Your competitors sit on the board that decides. This is how the monopoly was built.

35
Jurisdictions
Where competition is illegal
1964
First CON Law
Enacted in New York
1987
Mandate Repealed
Deemed ineffective by Congress
5-11%
Higher Costs
In CON states vs. free market
01The Mechanism

How Certificate of Need Works

A four-step process designed so that your competitors decide whether you are allowed to exist.

1

You want to build a surgery center

2

You apply to the state board

3

Your competitors sit on that board

4

Your competitors vote on whether you exist

It's like asking McDonald's for permission to open a Burger King.

02The Evidence

What CON Laws Actually Do

The FTC and DOJ have found no reliable evidence that CON programs achieve any public benefits.

5-11%

Higher Healthcare Costs

In CON states compared to free market states.

Mercatus Center

44-47%

More ASCs After Repeal

Increase in ambulatory surgery centers per capita.

FTC/DOJ Joint Statement

92-112%

Rural ASC Growth

Increase in rural surgery centers after CON repeal.

Journal of Health Economics

0350-State Overview

Every State, Ranked

Darker orange means more restrictive. Click any state with a CON law to view its full intelligence dossier.

04State Dossiers

Start With the Worst Offenders

Four states where the monopoly is most entrenched. The data below is the rest of the map.

All 36 States

Sorted by restrictiveness (most to least)

NV100

Nevada

Most Restrictive

Sunrise (HCA) + Dignity. 100% score. No reform efforts since 1971.

View Dossier →

NJ100

New Jersey

Most Restrictive

RWJBarnabas $7.5B. 25+ regulated services. The Garden State cartel.

View Dossier →

NC100

North Carolina

Most Restrictive

Two systems control nearly 100% of Charlotte. BCBS NC holds 62%.

View Dossier →

VT100

Vermont

Most Restrictive

Green Mountain Care legacy. UVMHN dominates the state.

View Dossier →

WA100

Washington

Most Restrictive

Providence Swedish + MultiCare + Virginia Mason Franciscan. 100% score.

View Dossier →

MD95

Maryland

Most Restrictive

Johns Hopkins $9B. University of Maryland $8.7B. All-payer rates.

View Dossier →

CT90

Connecticut

Highly Restrictive

Yale New Haven Health $6.1B. 40+ years of hospital mergers.

View Dossier →

IA90

Iowa

Highly Restrictive

Entrenched hospital lobby. No reform efforts in recent years.

View Dossier →

MA90

Massachusetts

Highly Restrictive

Mass General Brigham $18.5B. 15-year stranglehold on surgical competition.

View Dossier →

MS90

Mississippi

Highly Restrictive

40-year moratorium on home health, lifted only by federal court order.

View Dossier →

DC90

Washington, D.C.

Highly Restrictive

MedStar dominates tertiary care. George Washington + Children's.

View Dossier →

TN85

Tennessee

Highly Restrictive

HCA + Ascension + Ballad. Governor Lee has not pushed reform.

View Dossier →

AL80

Alabama

Highly Restrictive

Decatur monopoly (HHI 10,000). BCBS controls 84% of the market.

View Dossier →

MO80

Missouri

Highly Restrictive

SB 1268 partial repeal pending. BJC + SSM + Mercy dominate.

View Dossier →

RI80

Rhode Island

Highly Restrictive

Amended 25+ times, never repealed. 2026 repeal bill introduced.

View Dossier →

HI65

Hawaii

Restrictive

Queen's Health System: $1.7B. Last fully-regulated Pacific state.

View Dossier →

IL65

Illinois

Restrictive

BCBS controls 97% of the HMO market. CON sunsets in 2029.

View Dossier →

ME65

Maine

Restrictive

MaineHealth + Northern Light. Repeal efforts consistently fail.

View Dossier →

MI65

Michigan

Restrictive

Bureaucratic MDHHS process. Corewell + Henry Ford + Trinity dominance.

View Dossier →

NY65

New York

Restrictive

Northwell $17.6B. 26 regulated services. Started it all in 1964.

View Dossier →

OR65

Oregon

Restrictive

ASC exemption 2009. Providence + Legacy core-state control.

View Dossier →

AK55

Alaska

Restrictive

Premera BCBS owns 79% of the insurer market. HHI 2,785.

View Dossier →

LA55

Louisiana

Restrictive

Ochsner dominates New Orleans. 2024 reform entrenched FNR process.

View Dossier →

DE45

Delaware

Moderate

ChristianaCare $2.5B. 45% restrictiveness. One-system state.

View Dossier →

NE45

Nebraska

Moderate

Narrow CON, primarily a moratorium on new long-term care beds.

View Dossier →

MN30

Minnesota

Moderate

CON repealed 1984, replaced with hospital construction moratorium.

View Dossier →

OK20

Oklahoma

Mostly Free

Saint Francis: $2.04B revenue. INTEGRIS $1.84B. OU Health $1.64B.

View Dossier →

AR15

Arkansas

Mostly Free

Transitioned to Permit of Approval system. 2 services regulated.

View Dossier →

FL5

Florida

Mostly Free

Mostly repealed in 2019. AdventHealth still pulls in $17B.

View Dossier →

MT5

Montana

Mostly Free

Mostly repealed in 2021. Limited CON scope remains.

View Dossier →

ND5

North Dakota

Mostly Free

Effectively repealed. Sanford + CHI St. Alexius dominate.

View Dossier →

WI5

Wisconsin

Mostly Free

CON repealed post-1987. Only nursing home bed moratorium remains.

View Dossier →

No other publisher has built this.

Not KFF. Not Mercatus. Not Cicero. Not the AHA. The definitive Certificate of Need intelligence platform. Free, fully indexable, built for physicians, executives, and lawmakers.