Oklahoma Certificate of Need Laws
Oklahoma
Mostly Free
Year Enacted
—
Services Regulated
—
National Rank
20 of 51
Top Systems
- Saint Francis$2.04B
- INTEGRIS$1.84B
- OU Health$1.64B
Market Concentration
Saint Francis dominates with 1,112-bed flagship; 56.2% of OK hospitals in monopoly markets (HHI>5,000)
Reform Status
Mostly Free with no active reform bill.
Key Case
No major case law on record.
Oklahoma has rolled back much of its Certificate of Need program, retaining CON only for long-term care facilities. Following the 2024 repeal of psychiatric CON requirements (HB 2330), the remaining regulations protect entrenched nursing home operators while the real story is what dominant systems do with the structural advantages they retain.
6 Services Held Hostage
- ✓Hospitals
- ✓Ambulatory Surgery Centers (ASCs)
- ✓Nursing Homes / Long-Term Care
- ✓Hospice
- ✓Psychiatric Facilities
- ✓Substance Abuse Treatment
4 Systems. One Market.
Oklahoma has systematically dismantled its CON apparatus over four decades. The broad CON law was largely repealed in the late 1980s, further narrowed in 2018 (SB 1388), and in May 2024, Governor Stitt signed HB 2330 repealing psychiatric and chemical dependency CON requirements. The remaining CON requirements cover:
Oklahoma State Dept. of Health (OSDH), Health Facility Systems Division
Blocked, Denied, Upheld
Oklahoma's multi-decade CON reform, from the late 1980s hospital deregulation through SB 1388 (2018) and HB 2330 (2024), has eliminated requirements for hospitals, ASCs, psychiatric facilities, and most acute care. This was real progress. But the remaining regulations in long-term care still create barriers where incumbent nursing homes weaponize the appeals process to block competitors (as documented in the Wood Manor and Hometown Memory Care cases), and the larger issue is that CON reform alone does not address the structural advantages that dominant systems like Saint Francis have accumulated through 340B, tax exemption, and market concentration.
Reform Status: Mostly Free
Significant Reform, Incomplete Victory (Updated 2024)
Data sourced from state agencies, Cicero Institute, and public records.
Last updated: April 2026