Connecticut Health Law

On March 14, 2025, the Connecticut Office of Health Strategy (OHS) issued its biennial Statewide Health Care Facilities and Services Plan (the “Plan”), with an effective date of March 15, 2025. The Plan represents the first comprehensive update of this important regulatory publication since the original document was issued in 2012. Required by Connecticut General Statutes (CGS) §19a-634, the Plan is designed to serve multiple oversight and health planning purposes, including, but not limited to:

• Ensuring that health care facilities are financially stable;
• Monitoring the adequacy of the supply of health care services which are appropriate to meet the medical needs of consumers in the state of Connecticut (State);
• Showing gaps in the availability of, and access to, health care services and making recommendations for addressing these gaps; and
• Projecting future demand for health care services and the impact of technology on demand, capacity, or the need for services.

The Plan’s data is one of the 12 guidelines and principles that OHS must consider when analyzing certificate of need (CON) applications in accordance with CGS §19a-639. Notably, OHS must utilize the most recent version of the Plan in effect on the date of its decision—regardless of the date on which the CON application was filed or public hearing held. Similarly, in reviewing CON applications, OHS must use the latest version of the Inventory of Connecticut Health Care Services and Facilities and published utilization reports.  The agency’s 2022 Inventory was issued in late December 2022 through mid-2023; this document is required to be updated every two years pursuant to CGS §19a-634.

The Plan’s ten chapters provide comprehensive information about health care facilities, health care services, and health care equipment in the State. For example, Chapter 3 addresses acute care services and provides an overview of the hospital landscape in Connecticut-- including the number of licensed beds at each of the 27 hospitals in the State, the patient days and occupancy rate for each hospital in 2023, and hospital discharges by service line for the years 2018-2023. Subsequent chapters focus on outpatient surgery, imaging services and equipment (including new technology), behavioral health and substance use disorder treatments, primary care, and long-term services and supports and post-acute care services.  

Some of the Plan’s key findings are:

1. Major State health care trends impacting the use and affordability of health care facilities and services include: (a) above average rates of health insurance coverage, (b) Medicaid expansion to new populations, (c) the rising cost of health care coverage and shifts in costs from employers to employees, (d) industry consolidation, (e) the entry of private equity and other investors into the health care marketplace, (f) continued racial and ethnic disparities in utilization and health outcomes, (g) imbalance in the availability of key workforce sectors, including primary care and geriatrics, and (h) a growing population of older adults which is likely to present challenges to the current State workforce.
2. Avoidable emergency department visits declined between 2018 and 2023, but high rates in some areas of the State indicate gaps in access to primary and behavioral health care.
3. The demand for long-term services and supports and post-acute care for the aging population is rising, and meeting this demand is challenging due to staffing constraints. Further, there was a notable shift in post-acute care away from nursing homes toward home health over the past five years.
4. Except for the South Central Planning Region (the Greater New Haven Area), by 2030, all Connecticut Planning Regions are projected to have excess acute care hospital beds, which indicates a shift to outpatient alternatives and highlights the continuing effect of the Covid-19 pandemic on elective services (although shortages could remain for specific service lines, such as inpatient psychiatry).
5. Connecticut’s 106 health professional shortage areas (HPSAs), which include primary care, dental care, and mental health care HPSAs, potentially contribute to avoidable emergency department use.
6. The need for behavioral health care services has significantly increased over the last ten years (including higher rates of mental health conditions and substance use disorders). The number of specialized inpatient and outpatient treatment facilities has increased, although shortages remain in many parts of the State.
7. The impact of industry consolidation across the State, particularly hospital consolidation, likely contributes to higher health care prices, especially among privately insured patients, and fewer low-profitability services being provided in hospital settings.

OHS includes in the Plan the data sources used and the limitations of these sources. Among the limitations, the Plan notes a lack of complete data on current capacity and availability of known health care providers, a lack of complete data on the underlying need for specific health care services to measure demand for these services, and the impact of COVID-19 on typical utilization trends beginning in March 2020. The Plan’s appendices include tables, figures, and maps of health care facilities, health care services, and imaging equipment in Connecticut, as well as OHS’ responses to public comments on the draft plan issued in 2024.

The Plan is a valuable resource for providers and policymakers to understand the Connecticut health care landscape. 

If you would like more information about the Plan, or any other health care related matters, please contact one of our Health Care attorneys.