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Vermont Certificate of Need Laws

Certificate of Need Intelligence

Vermont

100/100

Most Restrictive

Year Enacted

Services Regulated

National Rank

43 of 51

Top Systems

  • University of Vermont Health

Reform Status

Most Restrictive with no active reform bill.

Key Case

No major case law on record.

Vermont's Green Mountain Care Board is the only regulatory body in the nation that combines Certificate of Need authority with hospital budget review and rate-setting power. This means the GMCB doesn't just decide who can build, it decides what they can charge.

01Scope of Regulation

3 Services Behind the Gate

  • Hospitals
  • Nursing Homes / Long-Term Care
  • Home Health Agencies
02The Application Process

The Permission Process

Reviews and approves hospital budgets annually

Any project over $3M requires GMCB approval

Vermont is the smallest state with a full CON program, and it has the most comprehensive regulatory apparatus in the country. The GMCB reviews hospital budgets, sets rates, and controls market entry. In a state with fewer people than most mid-size cities, this creates a regulatory environment where one dominant system faces virtually no competitive pressure. UVM Health Network's ~75% market share is not the result of consumer choice, it's the result of regulatory design.

Sources: Green Mountain Care Board public filings and annual reports; Vermont Department of Health; UVM Health Network financial disclosures; National Conference of State Legislatures CON database; Mercatus Center CON research; Vermont Act 48 (2011) legislative record. All data verified as of March 2026.

03Market Concentration

The Vermont Healthcare Cartel

University of Vermont Health

Controls market entry for all major healthcare services

In 2011, Vermont passed Act 48 to create Green Mountain Care, a single-payer healthcare system. Governor Peter Shumlin championed it as a national model. By 2014, the projected costs ($2.6 billion in new taxes) forced Shumlin to abandon the plan entirely. The failure demonstrated that even total regulatory control cannot overcome the fundamental economics of a healthcare market distorted by decades of anti-competitive policy.

05Legislative Environment

Reform Status: Most Restrictive

What Reform Would Look Like

Compare all 35 jurisdictions. Interactive table with scores, tiers, and reform status.

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

Last updated: April 2026