Connecticut Certificate of Need (CON) Introduction

Like many other states, Connecticut has an extensive CON process in place for healthcare services and facilities. Winning approval for a CON application is often a time consuming and difficult undertaking. RPC provides clients with a team of consultants with experience working on CON projects.

When working on a CON project, RPC can prepare the entire CON application or sections of the application as the client prefers. When the client is defining the project and deciding whether to apply, RPC can help assess the market and regulatory situation to determine the relative likelihood of success for a project. RPC not only completes a thorough review of the competitive environment, market need and financial analysis, but also works seamlessly with the client’s staff, architects, engineers, and other outside consultants to create a solid CON application.

RPC is led by Ron Luke, JD, PhD, who has prepared CON applications and presented testimony in CON hearings since 1981 in over 20 states. RPC’s work on CON projects includes the opening of new acute care hospitals, hospices, physical rehabilitation and psychiatric specialty hospitals, ambulatory surgery centers and nursing homes, the relocation and addition of beds, and acquiring major medical equipment. Working with RPC during the CON process gives the applicant the advantage of a skilled, experienced team that can provide expert advice and produce an effective CON application.

Contents last updated on September 2026

State Agencies

Connecticut Department of Public Health

Connecticut Department of Public Health (DPH) – Health Systems Planning Unit

Connecticut’s Certificate of Need (CON) program is administered by the Department of Public Health (DPH) through its Health Systems Planning Unit. The CON program regulates certain healthcare facilities, services, equipment acquisitions, ownership transactions, and service terminations that may affect healthcare access, quality, and cost. The program is intended to prevent unnecessary duplication of healthcare services, protect access to care, and provide Connecticut residents with a voice in major healthcare decisions affecting their communities. The CON process also supports statewide healthcare planning and evaluates proposals based on public need, access to care, and cost-effectiveness.

Effective July 1, 2026, administration of Connecticut’s Certificate of Need program was transferred from the Office of Health Strategy (OHS) to the Connecticut Department of Public Health pursuant to Public Act 26-68. Connecticut also enacted significant revisions to its Certificate of Need laws in 2026. While several provisions become effective October 1, 2026, many of the operational changes to the CON review process are scheduled to be implemented July 1, 2027. As a result, applicants should consult current Department of Public Health guidance for the most up-to-date filing requirements and procedures.

DPH reviews CON applications, conducts hearings and investigations, evaluates proposed projects, and issues final decisions regarding Certificate of Need applications. Through the CON program, the agency seeks to improve access to high-quality healthcare services, minimize unnecessary duplication of services, facilitate healthcare market stability, and contain healthcare costs. Connecticut’s review process also considers the impact of a project on healthcare consumers, the financial feasibility of the proposal, and the overall strength of the healthcare system.

Office Contact Information

Connecticut Department of Public Health
Health Systems Planning Unit
450 Capitol Avenue, MS #51
P.O. Box 340308
Hartford, Connecticut 06134
Phone: (860) 418-7001
Fax: (860) 418-7053

Connecticut Superior Court

An applicant or affected party may seek judicial review of a final Certificate of Need decision through the Connecticut Superior Court. Connecticut law also provides procedures for reconsideration of agency decisions prior to judicial appeal.

Services that Require CON

Connecticut’s Certificate of Need law requires state approval before certain healthcare facilities, providers, and organizations may establish new services, expand capacity, acquire major medical equipment, transfer ownership, or terminate specified healthcare services. The CON program is intended to promote appropriate healthcare facility and service development, ensure continued access to healthcare services, avoid unnecessary duplication of resources, and evaluate the impact of proposed projects on healthcare consumers and the healthcare system.

The following projects generally require Certificate of Need approval in Connecticut:

  • Establishment of a new healthcare facility, including hospitals, specialty hospitals, freestanding emergency departments, mental health facilities, substance abuse treatment facilities, and certain other healthcare facilities.
  • Transfer of ownership of a healthcare facility.
  • Transfer of ownership of a large group practice consisting of eight or more full-time equivalent physicians under circumstances specified by Connecticut law.
  • Establishment of a freestanding emergency department.
  • Establishment of cardiac services, including inpatient or outpatient cardiac catheterization, interventional cardiology, and cardiovascular surgery services.
  • Acquisition of computed tomography (CT), magnetic resonance imaging (MRI), positron emission tomography (PET), and PET-CT scanners, unless specifically exempt.
  • Acquisition of non-hospital-based linear accelerators.
  • Acquisition of equipment utilizing technology not previously used within the State of Connecticut.
  • Increase in the licensed bed capacity of a healthcare facility.
  • Establishment of an outpatient surgical facility.
  • Increase of two or more operating rooms within a three-year period by an outpatient surgical facility or short-term acute care hospital.
  • Termination of inpatient or outpatient hospital services.
  • Termination of mental health or substance abuse services offered by a hospital.
  • Termination of an emergency department by a short-term acute care general hospital.
  • Termination of surgical services by an outpatient surgical facility, except in certain limited circumstances specified by statute.
  • Termination of inpatient or outpatient services operated by state facilities eligible for reimbursement under the federal Social Security Act.

Certificate of Need Process Milestones

There are three types of CON review:

  • Nonsubstantive Review
    • No substantial change in health services or bed capacity
    • May be filed at any time
    • Quick decision
  • Formal Review
    • Most common and most involved application
    • Batched in cycles four times per year
    • Decision rendered in around 90 days

In its decision regarding a formal review application, the Cabinet considers compliance with the following core considerations:

  • Consistency with the State Health Plan
    • The latest criteria, inventories and need analysis figures maintained by the Cabinet and State Health Plan will be applied at like of public notice of the application
  • Need
    • Demonstrate need in the proposed service area and demonstrate an ability to meet that need
  • Accessibility
    • In terms of timeliness, amount, duration and sufficient personnel
  • Interrelationships and linkages
    • Appropriate and effective linkages with other services, facilities and elements of health care system in the region and state
    • Assurance of effort to achieve comprehensive care, proper utilization of services and efficient functioning of health care system
  • Costs, economic feasibility, and resource availability
    • Economically feasible for the applicant to implement and operate the proposal
    • If proposing more cost-effective way to meet the need identified in the application, must demonstrate how it is a more effective and economical use of resources
  • Quality of services
    • Prepared to and capable of undertaking and carrying out the responsibilities involved in the proposal
    • Ability to comply with applicable licensure requirements
  • Special needs and circumstances
  • Community support

Certificate of Need Process Milestones

The Connecticut Certificate of Need review process typically requires several stages of review, including public notice, application review, potential public hearings, and final agency approval. Depending on the complexity of the proposal and whether a public hearing is required, the review process can range from approximately 60 days to more than one year.

Connecticut has enacted legislation that will modify portions of the Certificate of Need review process beginning in 2027, including application deadlines, hearing procedures, expedited review options, and review criteria. Applicants should verify current procedural requirements with the Department of Public Health before filing.

Public Notice

Before filing a Certificate of Need application, the applicant must publish notice of its intent to file the application in a newspaper with substantial circulation in the area where the project will be located. The notice must be published for three consecutive days and must include a brief description of the proposed project and the project location. Applications must be submitted no sooner than 20 days and no later than 90 days after publication of the notice.

Application Submission

Connecticut applicants must submit a completed CON application through the State’s electronic CON portal together with all required forms, financial worksheets, supporting exhibits, and a $500 filing fee. Applications must include documentation demonstrating compliance with all filing requirements and evidence that public notice was properly published.

Completeness Review

The Department of Public Health reviews the application to determine whether sufficient information has been submitted to evaluate the proposal. The agency generally has up to 30 days to review an application for completeness. If additional information is needed, DPH will issue a completeness letter identifying deficiencies. Applicants generally have 60 days to respond to requests for additional information.

Public Comment and Hearing Request Period

Once an application has been deemed complete, a 30-day period is provided during which interested persons may submit comments or request a public hearing. A hearing may also be scheduled at the discretion of DPH. Public hearings are generally required if requested by three or more individuals or by an individual representing a group of five or more persons.

Public Hearing

When a hearing is held, the applicant, interested parties, and intervenors may present testimony, supporting evidence, and expert witnesses. DPH may also require additional information through interrogatories or other submissions. Public hearings provide an opportunity for community input regarding the proposed project and its impact on healthcare access, cost, and quality.

Agency Review and Decision

DPH evaluates the application using the statutory review criteria established under Connecticut law, including public need, access, quality, financial feasibility, utilization of existing services, and the impact on healthcare costs and provider competition. Applications may be approved, approved with conditions, denied, or resolved through an agreed settlement between the applicant and DPH. Most applications must receive a final decision within 90 days after the application is deemed complete.

Request for Reconsideration

If an application is denied, the applicant may petition DPH for reconsideration within 15 days. A petition for reconsideration must be based upon an error of fact or law, newly discovered evidence, or other good cause.

Appeals

Following a final agency decision, applicants may seek judicial review in Connecticut Superior Court. Appeals generally must be filed within 45 days of the final decision or the denial of a petition for reconsideration.

Compliance Monitoring

After approval, DPH monitors compliance with the terms and conditions contained in the Certificate of Need decision or agreed settlement. Certificate holders may be required to submit reports and other information demonstrating continued compliance with project commitments and approval conditions.

What Criteria Are Used to Review a CON?

Connecticut’s Certificate of Need review process is governed by Connecticut General Statutes §19a-639. The Department of Public Health evaluates each proposal to determine whether the project serves a clear public need, improves access to healthcare services, and supports the overall strength and efficiency of Connecticut’s healthcare system. Applications are reviewed using multiple statutory criteria, including the following:

  • Consistency with State Planning Policies – Whether the proposal is consistent with policies, regulations, and planning objectives established by the Department of Public Health and the Statewide Health Care Facilities and Services Plan.
  • Public Need – Whether the applicant has demonstrated a clear public need for the proposed facility, service, or equipment. The burden is on the applicant to demonstrate that the proposal benefits the public, not merely the applicant.
  • Financial Feasibility – Whether the proposal is financially feasible and whether it will strengthen or adversely affect the healthcare delivery system.
  • Quality, Accessibility, and Cost Effectiveness – Whether the project will improve healthcare quality, patient access, and cost effectiveness within the service area, including impacts on Medicaid recipients and indigent patients.
  • Service to Medicaid and Underserved Populations – The applicant’s historical and proposed commitment to serving Medicaid beneficiaries, indigent patients, and other underserved populations.
  • Population to be Served and Unmet Need – Whether the applicant has adequately identified the population to be served and demonstrated an unmet need for the proposed services.
  • Existing Utilization – Utilization of existing healthcare facilities and services within the proposed service area.
  • Avoidance of Unnecessary Duplication – Whether the proposal would result in unnecessary duplication of healthcare services or facilities.
  • Access to Care Record – Whether an applicant that has previously reduced access for Medicaid or indigent patients can demonstrate good cause for doing so. Differences in reimbursement alone are not sufficient justification.
  • Provider Diversity and Patient Choice – Whether the proposal would negatively affect provider diversity or reduce patient choice within the service area.
  • Impact of Consolidation – Whether any consolidation or ownership change resulting from the proposal would adversely affect healthcare costs or accessibility of care.

Certificate of Need Application Filing Fee

Connecticut requires payment of an application fee when a Certificate of Need application is filed. The applicable fee may depend on the type and cost of the proposed project, and applicants should confirm the current fee and submission instructions using the Department of Public Health’s CON forms and electronic filing portal before filing. The fee is submitted with the application materials through the Connecticut CON filing process.

Additional Sources

(links good as of July 2026)

Connecticut Department of Public Health – Certificate of Need Program
https://portal.ct.gov/dph/certificate-of-need

The Connecticut Department of Public Health’s CON website provides access to CON applications, public hearings, filing instructions, application forms, the CON portal, healthcare facility inventories, state planning resources, and other Certificate of Need program materials. It is the primary source for current Connecticut CON information.

Connecticut Certificate of Need Portal
https://dphconwebportal.ct.gov/Report
Search pending and approved Certificate of Need applications, decisions, determinations, modifications, and public notices.

Connecticut Certificate of Need Guidebook
https://portal.ct.gov/dph
Provides an overview of Connecticut’s Certificate of Need program, application procedures, review process, public hearing requirements, and compliance obligations.

Connecticut General Statutes – Certificate of Need Laws
https://www.cga.ct.gov/current/pub/chap_368z.htm
Contains Connecticut’s Certificate of Need statutes, including application requirements, review criteria, ownership transactions, public hearing provisions, and other CON-related requirements.

Contact RPC Consulting

Should you or your client need an expert team to help you with the Connecticut Certificate of Need process (CON) please contact Regulatory Practice Manager Darcy Schaeffer, MLS at 512‑371‑8011.

Disclaimer: The information on this page has been compiled by RPC based on sources believed to be reliable. It was updated in September 2026. Where possible we have had the material reviewed by state CON officials or others knowledgeable of the state’s CON program. The information is not offered as legal advice. A state may change its rules, forms and procedures at any time and RPC offers no assurance that the information will be correct on the date it is viewed. Therefore the reader is urged to use this information only as a starting point for any CON application and to speak with state officials or seek legal or consulting advice early in the process.

Learn More About RPC’s Certificate of Need Services