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05.29.2024 Legal News

First Look at 2025 North Carolina Health Care Opportunities

North Carolina’s Healthcare Planning Section has provided a first look at the opportunities for new health care development across our State. The 2025 State Medical Facilities Plan (the “2025 SMFP”) is expected to identify needs for various health care capacities in locations throughout North Carolina.

North Carolina’s annual health care planning process begins with data analysis and the announcement of expected need determinations for facilities, services, and equipment. In July, members of the State Health Coordinating Council will attend a series of virtual summer public hearings to receive information from providers petitioning for adjustments to those identified need determinations. Ultimately, a final roster of need determinations will be voted on and included in the draft 2025 SMFP presented to the Governor for signature. The 2025 SMFP will be official by year end and will serve as the guiding document for those seeking approvals for new health care capacities in North Carolina.

The 2025 SMFP will build on the Certificate of Need (CON) reforms passed in 2023. Notably, the 2023 CON Reform legislation changed the definition of health service facility to effectively eliminate the CON requirement for psychiatric and chemical dependency facilities statewide.

That same CON Reform legislation will eliminate the CON requirement in the fall of 2025 for surgery centers in high-population counties. Specifically, as of late November 2025, a CON will no longer be required for “qualified urban ambulatory surgical facilities” in North Carolina counties with a population greater than 125,000 according to the 2020 federal decennial census or any subsequent federal decennial census (Urban Counties). Currently, 23 of North Carolina’s 100 counties qualify as Urban Counties.

Notwithstanding CON reform, even after November 2025, new operating rooms will continue to require CON approval when proposed for development in sites other than qualified urban ambulatory surgical facilities. In 2025, health care planners are forecasting a need for two new operating rooms in Davidson County, three new operating rooms in Henderson County, six new operating rooms in Mecklenburg County, and five new operating rooms in the service area consisting of Pitt, Greene, Hyde, and Tyrell Counties. Of these counties, Mecklenburg and Pitt have populations exceeding 125,000 and thus would qualify as Urban Counties. In addition, acute care bed needs are expected to be shown in a range of North Carolina counties.  

In late 2026, the CON restriction will lift for new MRI scanners in Urban Counties. The 2025 SMFP is forecasted to include need determinations for one new MRI scanner in several service areas, including the Durham/Caswell/Warren multi-county service area and the following single county service areas:

Anson                          Mecklenburg               New Hanover              Wayne
Catawba                      Moore                          Onslow                        Wilkes
Guilford                       Nash                            Union                          

The 2025 SMFP is expected to show a need for a new Linear Accelerator in the service area comprised of Anson, Mecklenburg, and Union Counties as well as need for new cardiac catheterization equipment in four North Carolina counties, including Haywood, Johnston, New Hanover, and Wayne. Cardiac catheterization equipment can be approved for development on hospital sites or in licensed ambulatory surgical facilities (excluding endoscopy-only facilities). Both Johnston and New Hanover Counties are Urban Counties, which will not be subject to CON restriction on qualified ambulatory surgical facilities after November 2025. Wayne County is one to watch as its population now stands at 117,333.   

Post-CON reform, adult care home (ACH) beds—commonly referred to as assisted living beds—will continue to be CON-regulated statewide. The 2025 SMFP is expected to identify a need for 80 new ACH beds in Ashe County, 100 ACH beds in Perquimans County, and 140 ACH beds in Person County. As in years past, no new nursing home beds are expected to be identified as needed in 2025. With that, providers seeking to enter the skilled nursing facility market will be forced to do so via acquisition of existing beds. The 2025 SMFP does not forecast the need for any new home health agencies in North Carolina or any hospice home care agencies or hospice inpatient beds.

Those interested in adding capabilities that are not identified as a need have the option to file petitions to request adjusted Need Determinations. Although July 24, 2024, is the outside deadline for petitions, petitions should be prepared now to allow time for petitioners to offer presentations to the State Health Coordinating Council members in the series of upcoming summer public hearings.