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Florida Certificate of Need Laws

Certificate of Need Intelligence

Florida

5/100

Mostly Free

Year Enacted

2019

Services Regulated

3

National Rank

14 of 51

Top Systems

  • AdventHealth$17B
  • HCA Florida
  • Orlando Health

Reform Status

Mostly Free with no active reform bill.

Key Case

Sarasota County Hospice Denial

Florida partially repealed its CON laws in 2019, eliminating them for general hospitals. However, CON requirements remain for nursing homes, hospices, and intermediate care facilities, protecting incumbent systems in the post-acute care sector.

01Scope of Regulation

3 Services Behind the Gate

  • Hospitals
  • Nursing Homes / Long-Term Care
  • Hospice
02The Application Process

The Permission Process

The process for remaining CON services is rigorous. Any 'substantially affected person,' including existing providers, can request an administrative hearing to object to a new competitor's application, creating significant barriers to entry.

This case highlights the core flaw of CON laws: they prioritize the financial stability of existing providers over the benefits of market competition. The state actively defended the incumbent's monopoly, forcing residents to rely on a single provider for end-of-life care.

03Market Concentration

3 Systems. One Market.

AdventHealth$17B
HCA Florida
Orlando Health

Orlando Area Hospital Market Share (Illustrative)

AdventHealth and Orlando Health are the two dominant players in Central Florida. While hospital CON is gone, their scale gives them immense leverage in the remaining regulated services like hospice and nursing homes.

04Case Law & Denials

Sarasota County Hospice Denial

Sarasota County Hospice Denial

Decided 2018 · Sarasota County, Florida · State Court

, Florida Court of Appeals, paraphrased
05Legislative Environment

Reform Status: Mostly Free

By repealing most of its CON law, Florida took a significant step toward a more competitive hospital market. However, by leaving protections for nursing homes and hospices, the state continues to shield some of the most profitable sectors from competition.

Florida (Partial Reform)

States With Full Repeal

Data sourced from Cicero Institute, National Academy for State Health Policy (NASHP), Agency for Health Care Administration (AHCA), KFF, and company financial reports.

Last updated: April 2026