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Virginia Certificate of Need Laws

Certificate of Need Intelligence

Virginia

100/100

Most Restrictive

Year Enacted

1973

Services Regulated

19

National Rank

43 of 51

Top Systems

  • Sentara Health$13B
  • Inova Health System$6.5B
  • UVA Health System$5.6B

Reform Status

Current State: No Meaningful Reform

Key Case

No major case law on record.

Services Requiring CON Approval

01Scope of Regulation

3 Services Behind the Gate

  • Hospitals
  • Ambulatory Surgery Centers (ASCs)
  • Imaging (MRI, CT, PET)
03Market Concentration

3 Systems. One Market.

Sentara Health$13B
Inova Health System$6.5B
UVA Health System$5.6B

Insurer Dominance

  • Top Insurer Market Share

A few large systems control the majority of hospital revenue in Virginia, a sign of a concentrated market.

05Legislative Environment

Current State: No Meaningful Reform

Current State: No Meaningful Reform

Despite numerous attempts, Virginia's COPN law remains largely intact. Bills to repeal or significantly reform the law have consistently failed in the General Assembly, often due to strong opposition from the hospital lobby.

States That Reformed

States that have repealed their CON laws have seen increases in healthcare availability, particularly in rural areas, and lower costs. For example, after repealing its CON law, New Hampshire saw a significant increase in the number of ambulatory surgery centers.

Data sourced from the Virginia Department of Health, Centers for Medicare & Medicaid Services (CMS), Mercatus Center, and the Institute for Justice.

Last updated: April 2026