New York Requires Health Equity Assessments for Healthcare Expansions

Other states explore similar reforms to address disparities in underserved communities

Mar. 23, 2026 at 12:31am

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Regulators across the country are making changes to Certificate of Need (CON) programs, with a growing focus on health equity. New York now requires healthcare providers to conduct independent Health Equity Impact Assessments (HEIAs) when seeking approval for material expansions, in order to demonstrate how the project will improve access and reduce disparities for medically underserved groups in the service area. Other states like North Carolina and Connecticut are also incorporating equity considerations into their CON approval processes.

Why it matters

These HEIA requirements elevate the importance of health equity in healthcare regulatory reviews, requiring providers to deeply engage with the communities they serve and critically assess how their expansion plans will impact access and outcomes for vulnerable populations. This shift is designed to ensure that healthcare growth benefits medically underserved groups and reduces longstanding disparities.

The details

New York's HEIA mandate breaks the assessment into four key parts: 1) Scoping the service area and identifying impacted medically underserved groups; 2) Analyzing the potential impacts on access and health disparities; 3) Proposing mitigation strategies to improve equity; and 4) Outlining plans for ongoing monitoring. Providers must engage with public health experts, community stakeholders, and residents throughout the process. While not always framed as binding 'conditions,' the commitments made in HEIAs can become the expectations by which regulators measure compliance.

  • In 2025, New York enacted a law requiring HEIA requirements for many CON applications.
  • In 2024, North Carolina implemented a policy requiring CON applicants to demonstrate how their projects will reduce health disparities in underserved communities.
  • In 2025, Connecticut approved a hospital acquisition with conditions related to community engagement, service maintenance, and access prevention based on HEIA-related concerns.

The players

New York

The state that has led the way in incorporating HEIA requirements into its CON program.

North Carolina

A state that now requires CON applicants to identify underserved communities, unmet needs, and disparity reduction strategies.

Connecticut

A state that has considered health equity concerns in its CON approval process, imposing conditions related to community engagement and access prevention.

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What’s next

As more states explore health equity-oriented requirements in their CON programs, healthcare providers will need to build robust community engagement, data collection, and mitigation planning into their expansion strategies to meet regulatory expectations and ensure equitable access to care.

The takeaway

The growing focus on health equity in CON reviews signals a shift towards a more holistic, community-centered approach to healthcare growth. Providers must now demonstrate how their expansion plans will tangibly benefit medically underserved populations, not just the overall service area.