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New York Certificate of Need Laws

Certificate of Need Intelligence

New York

65/100

Restrictive

Year Enacted

1964

Services Regulated

National Rank

27 of 51

Top Systems

  • Northwell Health
  • NYU Langone Health$14.2B
  • NewYork-Presbyterian$13.2B

Reform Status

New York (No Meaningful Reform)

Key Case

No major case law on record.

New York's CON program, the oldest in the nation, has been in place since 1964. It regulates a broad range of services, creating significant barriers to entry. In major markets like Long Island, incumbent systems like Northwell Health face little meaningful competition.

01Scope of Regulation

2 Services Behind the Gate

  • Hospitals
  • Ambulatory Surgery Centers (ASCs)
02The Application Process

The Permission Process

In 2013, an application was filed to establish a new multispecialty ambulatory surgery center (ASC) in Manhattan. The goal was to provide a lower-cost, more convenient option for outpatient surgical procedures.

This case is a clear example of how New York's CON process is used to protect existing hospitals from competition. By denying the ASC, the state ensured that patients would continue to have fewer choices and be forced to seek care in higher-cost hospital settings, benefiting the incumbent systems.

03Market Concentration

4 Systems. One Market.

Northwell Health
NYU Langone Health$14.2B
NewYork-Presbyterian$13.2B
Presbyterian$13.2B

Insurer Dominance

  • With a perfect score of 100, Kentucky has one of the most restrictive CON programs in the United States.

Three massive non-profit systems, Northwell, NYU Langone, and NewYork-Presbyterian, dominate the state, collectively pulling in over $46 billion in annual revenue.

Long Island market share for Northwell: 31.1%

05Legislative Environment

New York (No Meaningful Reform)

New York (No Meaningful Reform)

States That Reformed

States that have repealed or significantly reformed their CON laws have seen increased competition, lower costs, and improved access to care. Evidence from these states shows that markets, not regulators, are better at determining public need.

$18.6 billion in revenue

Data sourced from the New York State Department of Health, the PHHPC, Centers for Medicare & Medicaid Services (CMS), and the Cicero Institute.

Last updated: April 2026