Skip to content

Minnesota Certificate of Need Laws

Certificate of Need Intelligence

Minnesota

30/100

Moderate

Year Enacted

Services Regulated

National Rank

21 of 51

Top Systems

  • Mayo Clinic
  • Allina Health

Reform Status

CON Law Repealed 1984

Key Case

2024 Rehab Hospital Denial Recommendation

Minnesota replaced its traditional CON program with a hospital construction moratorium, creating a unique and complex regulatory environment.

01Scope of Regulation

4 Services Held Hostage

  • Hospitals
  • Ambulatory Surgery Centers (ASCs)
  • Nursing Homes / Long-Term Care
  • Imaging (MRI, CT, PET)
02The Application Process

The Permission Process

Notably, ambulatory surgery centers and imaging centers are not subject to this review.

150 days for MDH review, plus legislative action

Minnesota repealed its formal CON law in 1984 but replaced it with a hospital construction moratorium that functions as a significant barrier to entry. While not a comprehensive CON regime, the moratorium and the associated Public Interest Review process still require legislative approval for new hospitals and bed expansions, effectively limiting competition.

03Market Concentration

The Minnesota Healthcare Cartel

Mayo Clinic
Allina Health

Insurer Dominance

  • Insurer Market Share
  • The insurance market is similarly concentrated:
  • Our comprehensive overview of Certificate of Need laws across the United States.

The Twin Cities market is dominated by three systems controlling ~70% of revenue:

Virtual monopoly in the Rochester hospital market.

04Case Law & Denials

2024 Rehab Hospital Denial Recommendation

2024 Rehab Hospital Denial Recommendation

05Legislative Environment

CON Law Repealed 1984

CON Law Repealed 1984

Minnesota's moratorium primarily targets:

Data sourced from state agencies, Cicero Institute, and public records.

Last updated: April 2026