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11.19.2024 Legal News

2025 North Carolina Health Care – Several Exciting Opportunities

North Carolina’s Healthcare Planning Section has now forwarded the 2025 State Medical Facilities Plan (the “2025 SMFP”) to Governor Roy Cooper for his review and signature. If signed as proposed, the 2025 SMFP will include several exciting health care development opportunities in North Carolina. Coupled with new options arising from CON reform initiatives, North Carolina is poised for a banner year ahead.

The stage is set for new hospital proposals in Mecklenburg County. The 2025 SMFP is expected to show both a need for new acute care beds and operating rooms in Mecklenburg County, paving a clear path for one or more new hospital CON applications. The 2025 SMFP will likely allow for the approval of up to 210 new acute care beds and up to five new operating rooms for Mecklenburg County. Bed/OR applications are due June 16, 2025. In addition, a Mecklenburg County MRI CON approval will be up for grabs later in 2025.

New hospital proposals also may be a possibility in other North Carolina service areas. In 2024, an Administrative Law Judge upheld a CON approval for a new hospital proposed with beds and procedure rooms but no operating rooms, a decision that remains before the appellate court.

In terms of other needs identified – a need for 82 new beds has been identified for the Durham/Caswell/Warren service area. An MRI need is also shown in Durham County. Both Cabarrus County and Union County are predicted to show significant bed needs of 126 and 136 beds, respectively. The 2025 SMFP is expected to show a need for yet another tranche of 129 new acute care beds in the multi-county service area including Buncombe County. Largest of all, the Wake County service area is expected to show a need for 267 new acute care beds. Both Union County and Wake County will each show a 2025 MRI need.

As a result of CON reform, as of the fall of 2025, new surgery centers can be developed in counties with populations of 125,000+ (Urban Counties) without CON approval. Providers long constrained by CON requirements will no doubt move quickly on new ASC projects in Urban Counties across North Carolina.   

In late 2026, the CON restriction for new MRI scanners also will lift in Urban Counties. Those in lower-population counties will continue to require CON approval for the acquisition of an MRI. In addition to the MRI opportunities noted above, the 2025 SMFP is expected to give providers a shot at a 2025 MRI CON approval in Alamance, Catawba, Forsyth, Guilford, Moore, Nash, New Hanover, Onslow, Wayne and Wilkes Counties. Of these, Moore, Nash, Wayne, and Wilkes Counties are likely to see continued MRI CON regulation for some years to come.       

In a surprising development arising from corrected data, a need for a new hospice home care agency is expected for Cumberland County.

New PET scanner opportunities are anticipated to be identified in the 2025 SMFP, including a need in each of three of the large multi-county Health Service Areas. A need is expected in the Health Service Area that includes Asheville and much of Western North Carolina, in the Health Service Area that includes Winston-Salem, Greensboro, and surrounding areas, and in the Health Service Area including the Triangle and neighboring Counties.

The 2025 SMFP is now projected to show a need for new cardiac catheterization equipment in three North Carolina counties: Catawba, Haywood, and Henderson. Catawba County is an Urban County that will soon be free to host a new surgery center. Cardiac catheterization equipment can be approved for development in a licensed surgery center.

The 2025 SMFP is expected to identify a need for new ACH beds, commonly referred to as assisted living beds, in Ashe County (80 beds), Perquimans County (100 beds), and Person County (140 beds), a county that borders both Orange and Durham Counties.

The Governor is poised to review and sign the 2025 SMFP within weeks, signaling the start of an exciting year of health care development opportunities across North Carolina.