Certificate of Need Data: Applications, Approvals, and Sites

Executive Summary

Certificate of need (CON) data describe regulatory projects and decisions, not a census of operating acquisition targets. An application can identify a proposed facility, an expansion at an existing address, equipment, or a control change. The research task is to establish which object the record describes and what happened afterward. North Carolina defines a certificate as an opportunity to develop a project; Louisiana explicitly places facility-need approval before seeking licensure or certification. ^{[1] [2]} Those distinctions should determine how a private-equity market map counts sites and capacity.

The evidence crosswalk needs separate fields for application, decision, completion, license, provider identifier, and verified operations. Hawaii's opening procedure distinguishes licensing from Medicare and Medicaid certification, while Pennsylvania explains that licensure permits operation. ^{[3] [4]} An exemption belongs on a separate decision branch: Illinois states that exemptions are not based on need. ^[5] Neither an exemption nor an approval establishes acquisition interest. A transaction-related filing should remain a proposed event until independent evidence establishes its disposition.

The state-by-state matrix below covers all states and D.C., using official project routes or explicitly limited licensing routes checked for this report. It is not a current national count of CON jurisdictions. Service scope and effective dates matter: Tennessee describes transitions from CON to licensure between December 1, 2025 and July 1, 2030, and South Carolina's statute schedules a hospital-related provision's repeal for January 1, 2027. ^{[6] [7]} Washington also warns that project-status updates can lag by two to three weeks. ^[8] Search date, decision date, and legal effective date therefore cannot share one timestamp.

In the fictional calculation below, requested new capacity is 80 beds, approved capacity 52, licensed capacity 24, and capacity verified as operating 16. A separate ownership-change record concerns existing capacity and contributes no new beds. These are worksheet arithmetic, not market estimates or completion probabilities. The practical priority is to reconcile the approved project to its exact licensed site, preserve unmatched records, and investigate capacity differences. Florida's implementation monitoring continues until licensing; Kentucky requires progress reporting for projects not fully implemented. ^{[9] [10]} A defensible map reports a pipeline and an operating inventory separately, with the unresolved difference visible.

Introduction and Background

A search for certificate of need applications can produce a useful origination lead without producing a countable operating site. The record might concern a new service at an established facility, a proposed location, or a change involving an existing operator. New York's application system explicitly accommodates entities not yet established as certified or licensed operators. ^[11] Importing every applicant into an operating-target universe would discard that distinction at the first step.

Certificate of need (CON) is not even the only program name an analyst must search. Arkansas uses Permits of Approval, Massachusetts uses Determination of Need, and Virginia uses Certificate of Public Need. ^{[12] [13] [14]} Program names, searchable objects, and covered activities differ. A national certificate of need database assembled for acquisition research therefore needs jurisdiction-specific definitions rather than a single standardized interpretation of the word “approved.”

For Docket's private-equity origination audience, the useful question is whether a public record supports the mandate's required facility, service, capacity, and operating status. This report concentrates on that application-to-operation handoff. It does not attempt to reconstruct ultimate ownership or estimate a company's willingness to sell. Those are separate research decisions, which require their own evidence.

The National Conference of State Legislatures (NCSL) April 29, 2025 reference reports 35 states and Washington, D.C., with its coverage table anchored to January 2025. ^[15] The National Academy for State Health Policy (NASHP) tracker reports a September 3, 2026 update but notes that several named states remained in its review process. ^[16] These references support discovery; the official state routes below provide the jurisdiction-specific evidence. Their vintages should not be combined into an unqualified current state count.

The reference date is October 18, 2026, the date of this review. The matrix distinguishes a source checked on that date from a rule taking effect on a date stated by the source. Where only a licensing route was verified, CON scope remains unresolved. Alaska's agency expressly describes CON and facility licensure as separate processes; that is a useful starting principle for reading the rest of the evidence. ^[17]

Key Changes

Replace a single status with an evidence crosswalk

The recommended status ladder is an editorial research framework. It records increasingly relevant evidence while preserving branches that do not imply progress toward operation. Exempt, denied, and withdrawn are decision outcomes, not intermediate operating stages. North Carolina's section can approve, deny, or condition an application; the disposition must be read at project level. ^[18]

Table 1 compares the objects a researcher should retain and the limit of each object's inference.

These statuses should coexist. An approved project can have a partially licensed configuration and unresolved operating capacity. A licensed facility can have a pending expansion. Store the project outcome, completion evidence, license status, and operating observation as separate fields, rather than overwriting them with the most favorable label. For the recommended operating test, seek a dated utilization submission reporting activity, an official service-opening confirmation, or a current operator statement corroborated by the matched license. Record the period and service each document actually covers. An operating conclusion should describe the supported capacity, with remaining capacity left unresolved.

Separate recommendations, decisions, and completion

Hawaii distinguishes standard review from administrative review. Under standard review, advisory councils or panels make recommendations before the agency's final decision. ^[22] The worksheet should identify the issuing body and document type so that a recommendation cannot silently become a final approval. An administrative route should likewise remain a review classification, not an operating-status flag.

Completion is another distinct object. Illinois requires permit and exemption holders to notify its review board upon completion. ^[20] Florida describes monitoring implementation of approved projects until licensing, with continued monitoring of approved conditions. ^[9] Those sources support searching beyond the decision letter. They do not support assuming that every approved project subsequently reached a licensed or operating stage.

Make changes date-specific and service-specific

Tennessee describes phased movement of services from CON to licensure through July 1, 2030. ^[6] South Carolina's statute contains a hospital-related repeal effective January 1, 2027. ^[7] Both dates require a prospective marker in an October review. A future change must not be applied to an earlier project simply because the updated statute is already online.

Process changes also affect the document trail. Iowa states that public hearings ceased being required beginning July 1, 2026. ^[23] An analyst should therefore search for the state's actual decision and project record rather than use the presence or absence of a hearing as a universal status test.

Implementation Considerations and Process Changes

Build a project-status worksheet before counting sites

The recommended worksheet keeps a project record distinct from the facility record it may eventually affect. Missouri's published law ties a certificate to its named premises and persons, while New York exposes project, facility, operating-certificate, review-status, and project-status fields. ^{[24] [11]} Those are useful models for designing explicit keys rather than relying on applicant names.

Retain the following field groups, using a blank or a documented “not applicable” value where the source does not support an answer:

• Jurisdiction and scope: State, service category, governing rule, rule effective date, and applicability question.
• Project identity: Project identifier, application version, applicant legal name, project type, and predecessor or successor record.
• Location: Proposed facility address, building or suite, relocation origin, and geography used for the mandate.
• Requested capacity: Proposed beds, rooms, equipment, or services, preserving the source's unit and existing baseline.
• Decision: Final status, decision date, conditions, authorized capacity, and the document's issuing body.
• Implementation: Progress-report date, extension, completion evidence, and completion scope.
• License and identifiers: License identifier, holder, status, service and capacity; National Provider Identifier (NPI) or Centers for Medicare & Medicaid Services (CMS) Certification Number (CCN), where applicable.
• Identity evidence: Corporate entity identifier and jurisdiction, operating brand, exact supporting document, and the match rationale.
• Provenance and conflict: Source web address, quoted passage, retrieval date, source update date, unresolved conflict, and next research action.

The last field group is essential for certificate of need project tracking. Washington explicitly warns that its online project-status updates may lag. ^[8] A newly collected page may therefore describe an older state of the project. Preserve when the agency says an event occurred and when the team observed it, rather than treating retrieval as the event itself.

Use a repeatable decision sequence

The following workflow is a proposed analytical process, not a statement that every state follows the same legal sequence. Louisiana expressly separates facility-need approval from seeking licensure, and Nebraska separately conditions hospital operation on inspection and a licensing determination. ^{[2] [25]}

• Route the service: Confirm the facility category and activity against the relevant jurisdiction's current official source.
• Read the whole disposition: Distinguish filing, completeness, staff analysis, recommendation, final decision, and any conditions.
• Trace the authorized project: Search subsequent versions, progress reports, extensions, and completion documents.
• Match the license: Reconcile holder, physical site, service, capacity, and relevant dates to the authorized project.
• Verify operations: Seek dated, site-specific operating evidence; record what remains uncertain rather than infer full use from permission.
• Count under a stated rule: Include each site and capacity unit only in the cohort whose acceptance requirements it meets.

For transaction applicability, qualified state counsel should confirm the operative rule, exemption conditions, and effective date before the team treats a public filing as evidence that a contemplated transaction is cleared. In Illinois, state-maintained health care facilities, including long-term care facilities, must seek a permit before closing. ^[5] The research worksheet should preserve that qualification instead of flattening every ownership event into “CON approved.”

State-by-State Source Routing

The following matrix is a source-routing reference, checked for this report, rather than a certification that a project is reviewable or that a state has no restrictions. C means an official CON or similarly named project route. S means the cited source establishes a special or limited need-review route. L means a licensing-first source was verified while current CON scope remains unresolved in this review. These labels describe the research route, not a national legal census.

Table 2 lists the lead source, useful public records, and the principal boundary to preserve. License not assessed means the separate license lookup was not independently checked for that row. Date not established means this review did not verify a controlling effective date from the cited source. Unless a row states a source date or effective date, those dates remain unverified. Document-access limits are stated only where observed; an application link does not guarantee a full public file.

The matrix supports certificate of need by state research without converting unknown scope into “no CON.” Its licensing-first rows are starting points for finding facilities, while the project rows are starting points for finding proposed or authorized changes. A mandate covering outpatient surgery should not reuse a nursing-home-specific route as a complete census. Florida's service exclusions and Nebraska's explicit bed-category limitation illustrate why the service must remain part of the routing key. ^{[9] [46]}

Public-access boundaries also matter. An authenticated filing system, a downloadable report, and a searchable decision register are different interfaces. Ohio's appointment requirement for complete files and Delaware's instruction to request older records are concrete limits on what a web-only collection can establish. ^{[52] [31]} Keep a route-level update log and a record-level evidence log; they answer different freshness questions.

Reconcile Applicants, Facilities, and Provider Identifiers

The recommended identity model links applicant, authorized project, licensed facility, operating brand, and legal entity without treating them as interchangeable. New York's separate project and facility fields support that separation, and Rhode Island's description of effective-control changes explicitly distinguishes owner, operator, and lessee. ^{[11] [56]} An applicant-name match is a candidate link, not an accepted merger of records.

National Plan and Provider Enumeration System (NPPES) data add provider identifiers to that crosswalk. CMS describes the NPI as a 10-digit identifier ^[66] that persists through changes in name or address. ^[66] CMS also states that issuance does not validate licensure or credentialing. ^[21] Consequently, an NPI attached to a proposed address cannot independently promote a project to licensed or operating status.

Use the following acceptance rules as a worksheet policy:

• Preserve roles: Store applicant, license holder, operator, and property owner in separate fields when identified.
• Match physical locations: Retain suite, building, relocation origin and destination; do not equate a mailing address with the project site.
• Require corroboration: Accept a link using explicit identifiers or documented continuity, with supporting address and service evidence.
• Keep subparts visible: Do not use a provider identifier as a universal physical-site count; CMS permits organizational subpart enumeration. ^[67]
• Date each relationship: A later license holder should not silently replace the applicant on an earlier decision.
• Retain rejected matches: Record why similar names or neighboring addresses were not joined, so a later analyst can revisit them.

CMS Provider of Services data provide another object, organized around certification information rather than CON applications. The methodology describes certification, termination, accreditation, name and location characteristics organized by CCN. ^[68] Record the provider type and source period before comparing that identifier with a state license. A certification record can corroborate the crosswalk, but it cannot replace the state decision or prove that the full approved configuration is operating.

This is especially important for certificate of need acquisition research. A control-change request can concern an already operating site, while a new-service request can concern an existing legal entity. Texas even provides a hospital license application category for initial licensing, ownership change, or relocation. ^[60] The filing's activity type should determine whether the map records a new site, a modification, or an ownership-related event. Acquisition interest remains unknown unless separately evidenced.

Data Analysis and Evidence

Define the denominator before calculating a rate

For certificate of need healthcare market mapping, the recommended quantitative output is a set of comparable capacity cohorts, with an explicit unit, geography, service definition, observation cutoff and treatment of revisions. Keep the latest valid scope for each project while retaining earlier versions. Avoid combining submitted applications with decisions issued in the same period and calling the result a completion rate.

Some official quantities describe the regulatory route rather than the market. Michigan states a clinical-service-area expenditure threshold of $4,272,500 effective January 1, 2026. ^[41] That figure is not a facility valuation, revenue estimate, or minimum acquisition size. Similarly, Kentucky's six-month progress-reporting interval describes administrative monitoring rather than the time an approved project normally takes to open. ^[10]

Data extracts also require version control. CMS stopped supporting Version 1 of its monthly and weekly NPPES files effective March 3, 2026. ^[21] The Provider of Services methodology includes active providers and certain terminated providers, so record presence alone does not establish active certification. ^[68] Preserve the file version, provider status and source period before joining an extract to the CON worksheet.

Capacity bridge (Fictional Example)

The following invented specialty-facility portfolio is a calculation exercise. Every project, quantity and status in this example is fictional; no real facility, state inventory or acquisition target is represented. All beds use the same hypothetical service definition and geographic boundary.

Table 3 separates requested new beds, approved new beds, currently licensed new beds, and new beds verified as operating at the fictional cutoff.

The fictional approved-to-requested ratio is 52/80 = 65%. Verified operating new capacity is 16/80 = 20% of requested beds, or approximately 16/52 = 30.8% of approved beds. Neither ratio estimates a future completion probability: these are mixed-status records at a cutoff, without follow-up time or a representative population. The licensed-to-approved gap is 28 beds; the licensed-to-verified gap is 8 beds. Those gaps prioritize research rather than establish physical nonexistence.

Report the following outputs separately:

• Submitted capacity: Includes the fictional denied record because the chosen denominator is the submitted cohort.
• Active proposed capacity: Excludes denied or withdrawn versions under a stated cutoff rule.
• Approved capacity: Uses the decision's authorized amount, with conditions retained.
• Licensed capacity: Uses the matched license's relevant service and capacity fields.
• Verified operational capacity: Includes only the amount supported by the specified operating evidence.
• Existing transaction capacity: Remains separate when a control change adds no beds or locations.

Hawaii has published an official historical table expressly comparing planning-agency-approved and licensing-agency-licensed bed capacity as of December 31, 2022. ^[69] That is useful precedent for keeping the measures separate, not a current operating inventory. The fictional bridge adds a further analytical requirement: current operating evidence must be assessed independently.

Implications and Future Directions

The useful future database is a dated event ledger linked to facilities, not a growing stack of application names. The recommended design permits a project to acquire a new decision, extension, license match or operating observation without deleting its earlier state. New York's distinction between review status and project status, and Kentucky's continuing progress reports, provide practical source patterns for this design. ^{[11] [10]}

Prioritize review according to the unanswered question that matters to the mandate:

• Approved without a license match: Investigate completion, extensions, changed address, and authorized scope.
• Licensed without operating verification: Seek current site-specific service evidence and retain capacity uncertainty.
• Pending near the target geography: Track competitive supply proposals separately from today's operating universe.
• Ownership-related filing: Reconcile affected entities and the event's outcome before changing the operator hierarchy.
• Competing or related applications: Preserve cross-references and mutually dependent conditions; do not automatically sum overlapping proposals.
• Changed legal scope: Revisit affected services and dates, preserving the rule used for each earlier assessment.

Refresh triggers should include newly posted decisions, progress materials, license changes, and a jurisdiction's announced rule transition. The appropriate timing depends on the source: Georgia publishes a weekly tracking report, whereas Washington warns of a lag before project-status updates appear. ^{[33] [8]} Neither cadence proves that every project has changed or that a page checked today is current to today.

For prioritization, treat “unresolved” as an owned research action with a specific missing document, not an implicit rejection or a favorable assumption. A filed project may warrant monitoring, but it does not establish that an acquisition target is operating, controlled by the named applicant, or available for sale. Keeping these questions separate makes a map easier to review as the evidence changes.

Conclusion

Certificate of need data become useful for acquisition research when each record retains its object, jurisdiction, scope, and dates. The main decision is whether the source establishes a proposal, an authorized project, a completion milestone, a licensed facility, or verified operations. The state routes in this report provide starting points for that investigation, with unverified scope and access limits stated explicitly.

The recommended handoff is an application-to-operation worksheet that preserves the requested and approved configuration, attaches license and provider identifiers only where the match is supported, and keeps the operating conclusion separate. Exemptions and ownership-related events require their own branches. A control-change application should not create new capacity, and a provider identifier should not supply missing operating evidence.

For a mandate-specific market map, report the proposed pipeline and verified operating inventory as separate outputs. Make capacity units, cohort membership, cutoff dates, and unresolved differences visible. The fictional bridge illustrates how the same records can support different totals without any arithmetic contradiction: the totals answer different questions.

The resulting research is useful because another analyst can inspect each inference, reproduce the count, and identify the next missing document. It supports a defensible prioritization decision while leaving acquisition interest and other unsupported conclusions unknown.