Skip to content

North Carolina Certificate of Need Laws

Certificate of Need Intelligence

North Carolina

100/100

Most Restrictive

Year Enacted

1977

Services Regulated

National Rank

43 of 51

Top Systems

  • Atrium Health
  • Novant Health
  • UNC Health

Reform Status

Most Restrictive with no active reform bill.

Key Case

No major case law on record.

North Carolina's CON law is a textbook case of regulatory capture. In Charlotte, two hospital systems, Atrium and Novant, control nearly 100% of the market. The state uses its power to pick winners and losers, stifling competition and leaving patients with fewer choices and higher costs.

01Scope of Regulation

2 Services Behind the Gate

  • Hospitals
  • Imaging (MRI, CT, PET)
02The Application Process

The Permission Process

The review process is lengthy and allows incumbent systems to file a 'contested case' against a new applicant. This legal challenge mechanism significantly raises the cost and time required to bring new services to a community, protecting established players from competition.

, Dr. Gajendra Singh, whose application for a new hospital was blocked

In 2021, both UNC Hospitals and Duke University Health System submitted competing applications to acquire a new PET scanner. The state’s healthcare planning agency determined that only one scanner was needed in the service area.

Instead of allowing both qualified providers to offer the service and compete on quality and price, the state regulators engaged in central planning. They evaluated both proposals and ultimately decided that Duke's application was a 'more effective alternative.'

As a result, UNC's application was denied. This case is a stark illustration of how CON laws replace market competition with government decision-making. The state, not patients or referring physicians, decided who was better equipped to provide a critical service. This process limits patient choice and reinforces the market position of state-favored incumbents.

Data derived from state Department of Health and Human Services filings, public court records, and reports from the Mercatus Center at George Mason University and the National Conference of State Legislatures.

03Market Concentration

3 Systems. One Market.

Atrium Health
Novant Health
UNC Health

Insurer Dominance

  • Market share of Blue Cross and Blue Shield of NC
  • Learn about the history and impact of CON laws across the United States.

Combined hospital market share of Atrium & Novant in Charlotte

Novant Health's estimated market share in Coastal North Carolina

04Case Law & Denials

, North Carolina Court of Appeals, 2023

, North Carolina Court of Appeals, 2023

Explore the case of Kentucky, one of the most restrictive CON states in the nation.

05Legislative Environment

Reform Status: Most Restrictive

National Reform Efforts

An overview of the legislative battles to repeal or reform CON laws.

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

Last updated: April 2026