Maryland Certificate of Need Laws
Maryland
Most Restrictive
Year Enacted
—
Services Regulated
—
National Rank
41 of 51
Top Systems
- Johns Hopkins Health$9.0B
- University of Maryland Medical$8.7B
- MedStar Health
Reform Status
Most Restrictive with no active reform bill.
Key Case
No Public Record of Denials
Maryland Health Care Commission (MHCC)
3 Services Behind the Gate
- ✓Hospitals
- ✓Nursing Homes / Long-Term Care
- ✓Home Health Agencies
The Permission Process
90 days (standard) to 150 days (with hearing)
Our investigation found no publicly documented instances of the Maryland Health Care Commission formally denying a Certificate of Need application. While approvals are noted in reports, specific details on denied projects, withdrawn applications under pressure, or legal challenges are not made available. This lack of transparency makes it impossible to quantify the full chilling effect of the law on potential healthcare innovators and the patients they would serve.
With 100% of its acute-care hospitals owned by large systems and a commercial insurance market dominated by two carriers, the state\\'s healthcare economy is a consolidated fortress. The CON law serves as the primary defense mechanism, protecting incumbents from new competition and preserving the status quo.
Johns Hopkins Health. $9.0B. Insurer Dominance.
Insurer Dominance
- Top Insurer Market Share
- Insurer Market Share (Fully Insured)
- CareFirst BCBS
Sources: Maryland statutes and regulations; Maryland Health Care Commission reports; academic and policy analyses; press releases and health system data.
No Public Record of Denials
No Public Record of Denials
Reform Status: Most Restrictive
~$9.0 Billion Revenue (FY25)
~$8.7 Billion Revenue (FY23)
~$1.85 Billion Revenue (Flagship)
Maryland has not undertaken a wholesale repeal of its CON program. Reforms have been piecemeal, focusing on adjusting capital thresholds for inflation (2006) and tightening the criteria for competitor interventions (2023). These changes do not fundamentally alter the restrictive nature of the law.
Data sourced from state agencies, Cicero Institute, and public records.
Last updated: April 2026