01

Tennessee: A Market Captured

Incumbent giants like HCA Healthcare leverage highly restrictive CON laws to dominate the landscape, stifling competition in America's healthcare capital.

Tennessee Score Card

Governor: Bill Lee (R)

Highly Restrictive

85/100

Top 5

Most Restrictive

14+

1973

State Intel

Nashville, the nation's healthcare capital, is home to HCA Healthcare, the world's largest for-profit hospital operator, whose $60B+ empire benefits directly from CON's anti-competitive barriers.

02

What CON Covers in Tennessee

Regulated Healthcare Services

Hospitals & ASCsYes
Nursing Homes & Home HealthYes
Rehabilitation FacilitiesYes
Diagnostic Imaging (MRI, CT, PET)Yes
Cardiac CatheterizationYes
Burn & Neonatal Intensive CareYes
Organ TransplantationYes

Application & Approval

The Health Services and Development Agency (HSDA) administers the CON program, a process often criticized for favoring established players.

Governing BodyHSDA
Application CostVaries, can be substantial
Incumbent AdvantageHigh
Judicial ReviewLimited
03

Who Benefits from CON?

Tennessee's CON laws create a protected market for incumbent hospital systems, limiting patient choice and inflating costs.

HCA Healthcare

World's largest for-profit hospital company, headquartered in Nashville.

Vanderbilt University Medical Center

Major academic medical center with significant market share.

04

The Human Cost of CON

Incumbent Protectionism in Action

The HSDA has a documented history of favoring applications from existing providers like HCA and Vanderbilt while denying or delaying those from new, potentially lower-cost competitors. This "rubber-stamping" for incumbents preserves their market share and revenue streams at the expense of innovation and patient access. Critics argue this system creates a healthcare oligopoly, particularly in the lucrative Nashville market.

05

Reform Status

Current Law

Tennessee maintains one of the most comprehensive and restrictive CON programs in the United States. The law covers a wide array of services and equipment, making it difficult for new providers to enter the market or for existing providers to expand services without state approval.

Reform Efforts

Despite the clear market distortions, legislative efforts to significantly reform or repeal CON laws have consistently failed. The powerful lobbying influence of incumbent hospital systems, particularly HCA, presents a formidable barrier to meaningful change. Minor tweaks have occurred, but the core structure remains intact.

05Editorial

The Rojas Report Take

"Tennessee is the poster child for regulatory capture. In a city that prides itself on being the heart of American healthcare, the state's CON laws serve only to protect the titans like HCA. It's a system that actively works against the principles of a free market, leading to higher costs, less choice, and a chilling effect on the very innovation Nashville claims to foster. It's not a healthcare system; it's a cartel sanctioned by the state."

The Rojas Report
07

Related Content

Data sourced from state statutes, reports from the Mercatus Center, and the National Conference of State Legislatures.