Illinois Certificate of Need Laws
Illinois
Restrictive
Year Enacted
1974
Services Regulated
6+
National Rank
27 of 51
Top Systems
- Edward Hospital
Reform Status
States That Reformed
Key Case
Edward Hospital, Plainfield Facility Denial. The case illustrates how the CON process can be weaponized, not just to protect incumbents from comp
Illinois calls it the Health Facilities Planning Act. It should be called the Incumbent Protection Racket Act. One insurer controls 97% of the HMO market. The state's CON law is the moat that protects this castle, ensuring no new competition can threaten the cozy arrangement between dominant insurers and hospital systems.
2 Services Behind the Gate
- ✓Hospitals
- ✓Major Medical Equipment
The Permission Process
The HFSRB reviews all applications for new healthcare facilities and major capital expenditures. The process allows incumbent systems to protest, effectively giving existing players a veto over new competition. Application fees can reach $150,000.
The Health Facilities and Services Review Board denied the application. The hospital's CEO alleged the denial was retaliatory after she exposed a kickback scheme within the review process. Despite the allegations, the board formally rejected the CON, leaving the community without the facility it needed.
The case illustrates how the CON process can be weaponized, not just to protect incumbents from competition, but potentially to punish those who challenge the system itself.
Data sourced from Illinois Health Facilities and Services Review Board, Centers for Medicare & Medicaid Services (CMS), Federal Trade Commission, American Hospital Association, and Cicero Institute.
The Illinois Healthcare Cartel
Three systems control 100% of Louisville's inpatient market.
Edward Hospital, Plainfield Facility Denial
Edward Hospital, Plainfield Facility Denial
States That Reformed
States That Reformed
Data sourced from Illinois Health Facilities and Services Review Board, Centers for Medicare & Medicaid Services (CMS), Federal Trade Commission, American Hospital Association, and Cicero Institute.
Last updated: April 2026