Last updated: November 2026.
A Connecticut certificate of need is state approval for listed health care projects. Integral Healthcare Solutions (IHS) drafts application narratives, need and utilization worksheets, notice calendars and attachment checklists for provider planning, finance and legal teams. The applicant and counsel approve the work, and the applicant files; IHS provides no legal advice.
Which office runs Connecticut certificate of need review now?
The Department of Public Health. The Office of Health Strategy's certificate of need page states that under Public Act 26-68 the program transferred to the department effective July 1, 2026 (page opened 2026-11-05). The act's text differs: section 103, effective July 1, 2026, names the Commissioner of Public Health, while section 238, effective October 1, 2026, names the Commissioner of Health Strategy for applications filed on or before June 30, 2027 (Public Act 26-68, opened 2026-11-05).
What is Connecticut certificate of need review, and which rules apply?
It is the Chapter 368z process through which the Health Systems Planning Unit (the unit) issues the certificate that section 19a-638 requires. IHS's reading as of November 5, 2026: Public Act 26-68 sections 226–242 distinguish applications filed through June 30, 2027 from those submitted from July 1, 2027, but also date particular duties separately. Counsel should confirm the provisions applicable to the project. These sections took effect October 1, 2026; the act is the source for the amendments (page opened 2026-11-05).
| Item | Filed on or before June 30, 2027 | Submitted on and after July 1, 2027 |
|---|---|---|
| Who decides | The unit (19a-639a(d)) | A three-member panel chaired by the Commissioner of Public Health or designee (section 227(a)) |
| Hearings | The unit must hold a hearing if, within 30 days after it deems a properly filed application complete, it receives a written request from at least three individuals or one individual representing an entity with at least five people. For a large-group-practice transfer offered in response to a request for proposal or similar voluntary offer for sale, the threshold is at least 25 individuals or one individual representing at least 25 people (19a-639a(e)). Hospital ownership transfers filed after December 1, 2015 through June 30, 2027 require a hearing, and the unit may hold others (19a-639a(e) to (f)). | Under the standard section 231 pathway, a hearing within 90 days of completeness unless waived in writing within 30 days; waiver requires the applicant to be the only party with no intervenor and waives its section 4-183 appeal right (section 231(g)) |
Which projects need a certificate for filings through June 30, 2027?
A project on the fifteen-item list in section 19a-638(a), unless an exclusion in subsection (b) applies. The list includes the establishment of a new health care facility (1), a transfer of ownership of a health care facility (2), an outpatient surgical facility as defined in section 19a-493b or as established by a short-term acute care general hospital (6) and a freestanding emergency department (4). Other projects are in Public Act 26-68, section 239(a)(3), (5), (7) to (15) (effective October 1, 2026; page opened 2026-11-05). Section 19a-638(b) lists 25 exclusions, including home health agencies, hospice services and federally qualified health centers; the practitioner-office exclusion in (b)(2) does not apply where section 19a-493b or subdivision (3), (10) or (11) of subsection (a) requires a certificate.
From July 1, 2027, section 229 lists nine CON triggers. From July 1, 2027, Public Act 26-68 section 237 separately addresses indefinite hospital service-line termination and pauses longer than 90 days; its service-line definition excludes emergency-department services (page opened 2026-11-09).
What must a Connecticut applicant show?
For filings through June 30, 2027, the application addresses the guidelines in section 19a-639(a) and the department's regulations (19a-639a(a)), and the unit makes written findings on all twelve guidelines (Public Act 26-68, sections 240(a), 241(a), page opened 2026-11-05). For applications under section 231 from July 1, 2027, the applicant must show by a preponderance of the evidence that the proposal serves the public interest. Section 230(a) addresses quality, access including Medicaid, and cost-effective care in the applicant's primary service area; health-system financial stability, including applicant feasibility and evidence of prior financial mismanagement or misconduct; clear public need; and unnecessary service duplication.
What does the pre-filing notice require for filings through June 30, 2027?
The applicant takes four steps before filing (19a-639a(b), as in Public Act 26-68, section 241(b), page opened 2026-11-05): publish notice in a newspaper of substantial circulation where the project will be located, for not less than three consecutive days with the final date no later than twenty days before filing, with a brief description and the street address; publish it on the applicant's website in a clear, conspicuous location easily accessible to the public; request publication at two or more sites in the affected community that the public commonly uses, and on any existing municipal or local health department website; and submit it to the unit for posting. Community and applicant-website postings must remain until the decision; changes or removal on a community website outside the applicant's control do not invalidate notice. The application is due no later than ninety days after the newspaper notice, and the unit does not accept it without the fee and proof of compliance with these requirements.
How does IHS prepare a Connecticut certificate of need application?
IHS works as an outside drafting team under your leaders and counsel. It compares your plan to the rules for your filing date, maps each guideline or factor to its data, drafts the narrative, worksheets, calendar and attachment checklist for approval.
You supply the project facts, need, utilization and financial data, counsel, and the notice, filing, fee and attendance. IHS does not file with the state, attend or communicate with the reviewing agency for you, gives no legal advice, and does not guarantee approval.
IHS was founded in 2002 and is led by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC.
What should an applicant have ready for a Connecticut certificate of need?
Each item cites Public Act 26-68, effective October 1, 2026 (page opened 2026-11-05).
- Counsel's project classification and any determination request (sections 229, 239).
- Public-need, population and financial evidence matched to the review factors (sections 230(a)(4), (5), 240(a)(3), (4), (7)).
- Past and proposed payer mix, including Medicaid and indigent access, for the earlier process (section 240(a)(5) to (6)).
- Project cost and the fee (sections 231(b), 241(a)).
- Notice calendar and supporting records (sections 231(c), 241(b)).
- Validity and information-request tracker, including the 30 days after expiration (sections 233(a), 242(a)).
A free introductory call with IHS sorts out what to build first.
How does an outside application build compare with the other routes?
An internal build uses your staff. Counsel makes the legal determinations IHS does not. The state's program page lists application, determination and modification forms and a filing portal (page opened 2026-11-05). IHS drafts; the applicant approves and files.
What does a Connecticut certificate of need application cost?
IHS scopes each engagement after a free introductory call. For applications submitted October 1, 2023 through June 30, 2027, the unit may retain a specialist when it cannot reasonably analyze the application without that expertise; applicants pay reasonable bills within 30 days of receipt (19a-639a(g), as in Public Act 26-68, section 241(g), page opened 2026-11-05). From July 1, 2027, consultant costs are capped at 100,000 dollars per application under section 230(b), with notice and an opportunity to withdraw before fees are incurred; consultants cannot be retained for expedited review unless it is referred for full review.
| Project cost (dollars) | Application fee (dollars) |
|---|---|
| Not more than 50,000 | 1,000 |
| Over 50,000, not more than 100,000 | 2,000 |
| Over 100,000, not more than 500,000 | 3,000 |
| Over 500,000, not more than 1,000,000 | 4,000 |
| Over 1,000,000, not more than 5,000,000 | 5,000 |
| Over 5,000,000, not more than 10,000,000 | 8,000 |
| Over 10,000,000 | 10,000 |
Source: Public Act 26-68, sections 241(a) and 231(b), page opened 2026-11-05. Verify current fees with the Connecticut Department of Public Health.
What this is not
It is not legal advice: IHS is a consulting firm, not a law firm, and counsel decides whether a project needs a certificate and how to handle an appeal. It is not a filing service or a guarantee of approval.
Frequently asked questions
What is a certificate of need in Connecticut and which projects need one?
Through June 30, 2027, section 19a-638(a) lists fifteen project categories requiring CON, subject to the statute's conditions and exclusions. Public Act 26-68 section 229 changes the list from July 1, 2027 (sections 239(a) and 229, page opened 2026-11-05).
Which office reviews Connecticut certificate of need applications now?
The state program page says the program transferred to the Department of Public Health effective July 1, 2026. Section 238 of Public Act 26-68 still names the Commissioner of Health Strategy for applications filed on or before June 30, 2027 (both pages opened 2026-11-05).
Does my project need a certificate in Connecticut?
For the process through June 30, 2027, read section 19a-638(a) with its exclusions. Under 19a-638(c), a person or facility unsure whether approval is required must send the unit a letter describing the project and requesting a determination; a facility proposing relocation under 19a-639c must also write and include the relocation information required there. The requester must supply information the unit requests, and the unit must determine the request within 30 days of receipt (Public Act 26-68, section 239(c), page opened 2026-11-05).
How long does Connecticut review take?
For applications filed through June 30, 2027, the usual review period is 90 days from website posting of completeness; it is 60 days for a large-group-practice transfer offered in response to a request for proposal or similar voluntary offer for sale (19a-639a(d), as amended by Public Act 26-68, section 241, page opened 2026-11-05). Without a hearing, the decision is due before the review period expires; the unit may extend review by up to 60 days on request or for good cause shown, with a decision before the extended period expires. With a hearing, the decision is due within 60 days after the unit closes the hearing record.
What is the Connecticut application fee?
It is nonrefundable and set by project cost across seven tiers, from 1,000 dollars for a project costing not more than 50,000 dollars to 10,000 dollars for a project over 10,000,000 dollars (Public Act 26-68, sections 241(a) and 231(b), page opened 2026-11-05). Verify current fees with the Connecticut Department of Public Health.
What happens if a project starts without approval in Connecticut?
A person, health care facility or institution required to obtain approval under 19a-638 that negligently fails to seek it is subject to a civil penalty of up to 1,000 dollars for each day it conducts the activity without required approval. The Department of Public Health imposes the penalty under 19a-653(a), as amended by Public Act 26-68, section 124, page opened 2026-11-05.
How long is a Connecticut certificate of need valid?
Section 19a-639b(a), as amended by Public Act 26-68 section 242, states project-specific, two-year validity but refers to section 19a-638a; counsel should confirm that cross-reference's application. For applications filed on or after July 1, 2027, section 233(a) expressly provides project-specific validity for two years from issuance. Both provisions require holders to provide requested project-development information during validity and for 30 days after expiration (page opened 2026-11-05).
What changes for applications submitted on and after July 1, 2027?
A three-member panel decides applications submitted on and after July 1, 2027. Under the standard section 231 process, applications go to the Certificate of Need Program on monthly deadlines, with notice at least 21 days before; section 230 requires proof by a preponderance of the evidence that the proposal is in the public's interest (Public Act 26-68, sections 227, 230 and 231, page opened 2026-11-05).
Related pages
Compliance Services overview | State licensing and certificate of need | Certificate of need application consulting.