What is a Certificate of Need (CON)?

A Certificate of Need (CON) is a state regulatory process designed to control the growth and expansion of healthcare facilities by requiring approval based on demonstrated community need before capital expenditures or new services are allowed.

Do all states require a CON for surgery centers?

No. CON requirements vary state by state. Some states include ambulatory surgery centers under their CON programs, while others have no CON program or do not require CON for surgery centers. It’s important to check your specific state’s regulations.

How long does the CON application process take?

The timeline depends on the complexity of the proposal, state review schedules, required studies, and whether hearings are involved. Some reviews can take several months, so early planning is essential.

What happens if a CON application is denied?

If a CON application is denied, states may allow appeals, revised submissions, or additional supporting evidence. We help facilities assess the denial, adjust strategy, and prepare a stronger re-filing or appeal if appropriate.

Can Axiom assist with CON strategy and documentation?

Yes. Axiom provides CON consulting, market and regulatory analysis, strategy development, and preparation of the application and supporting documentation needed to pursue CON approval for surgery centers.

Certificate of Need (CON) Consulting for Surgery Centers

Certificate of Need requirements add a significant layer of regulatory complexity to surgery center development and expansion. CON programs are state-specific, highly procedural, and often involve competitive review, public notice, and formal approval processes that can directly impact project timelines and feasibility.

Our Certificate of Need Consulting services support ambulatory surgery centers, office-based surgery practices, and hybrid facilities navigating CON requirements with disciplined strategy, accurate documentation, and a clear understanding of how decisions are evaluated.

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Certificate of Need Consulting Services

CON Feasibility & Regulatory Strategy

We assess whether a Certificate of Need is required based on state law, service type, and project scope, and help facilities understand regulatory risk before moving forward.

Application Planning & Documentation Support

We support preparation of CON applications, including project narratives, service justification, utilization data, and supporting documentation aligned with state review criteria.

Project Scope & Regulatory Alignment

We assist with defining project scope, service offerings, and capacity planning to ensure alignment with CON thresholds and approval standards.

Review Process & Agency Coordination

We provide guidance throughout the CON review process, including regulatory timelines, agency interaction, and response to information requests.

Approval Conditions & Post-Decision Support

When approvals include conditions or limitations, we help facilities interpret requirements and align implementation plans to maintain compliance.

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Who We Support

New Surgery Centers

Early Certificate of Need strategy is critical when developing a new surgery center in a CON-regulated state. We help project teams evaluate whether CON requirements apply, assess feasibility based on state criteria, and align early planning decisions with regulatory expectations to reduce risk and avoid costly delays later in the process.

Existing Surgery Centers

Changes to an existing surgery center—such as expanding services, increasing capacity, relocating, or modifying ownership—can trigger Certificate of Need review. We help established facilities assess regulatory thresholds, evaluate project scope, and navigate CON requirements while maintaining alignment with licensure and operational goals.

Hybrid ASC / OBS Facilities

Hybrid ASC and office-based surgery models introduce additional complexity in CON-regulated environments. We support facilities navigating CON implications across mixed delivery models, helping clarify applicable requirements and align regulatory strategy across overlapping frameworks.

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Certificate of Need FAQs

A Certificate of Need (CON) is a state-level regulatory approval required in certain states before healthcare facilities can open, expand, or add specific services. CON programs are designed to control healthcare capacity and require applicants to demonstrate community need and regulatory justification.

Why Choose Axiom for Certificate of Need Consulting

Certificate of Need review is one of the most complex and high-risk regulatory processes affecting surgery center development and expansion. With over 25 years of healthcare regulatory and compliance experience, Axiom brings disciplined strategy, state-specific insight, and practical execution to CON-regulated projects. Our approach is grounded in how CON statutes are applied in real approval decisions, allowing clients to pursue projects with clarity, realistic expectations, and reduced regulatory risk.

✔ Experience navigating CON-regulated healthcare environments
✔ State-specific interpretation of CON statutes and review criteria
✔ Structured approach to high-stakes regulatory submissions
✔ Practical guidance aligned with real approval standards
✔ Support that complements licensure and accreditation planning

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Start a Certificate of Need Consultation

Whether you are evaluating a new project, planning an expansion, or responding to CON requirements, our team provides structured guidance to help you navigate the Certificate of Need process with clarity and confidence.

Request a Certificate of Need Consultation to discuss your project and regulatory considerations.

Call (312) 475-9401 info@chooseaxiom.com

Days	Hours
Monday	8:00 AM - 5:00 PM
Tuesday	8:00 AM - 5:00 PM
Wednesday	8:00 AM - 5:00 PM
Thursday	8:00 AM - 5:00 PM
Friday	8:00 AM - 5:00 PM
Saturday	Appointment Only
Sunday	Appointment Only

312-475-9401

info@chooseaxiom.com

Certificate of Need Consulting