New Tenn. law modifies rules for diagnostic imaging services

A new law in Tennessee marks the beginning of certificate of need (CON) reform and makes two key changes to requirements for PET and MRI services, according to experts at law firm Holland and Knight.

CON laws are state regulatory mechanisms for approving major capital expenditures and projects for certain healthcare facilities, the firm said.

To establish PET services without a CON under the new law, the provider only needs to become accredited by the American College of Radiology (ACR) within two years of being licensed.

To initiate MRI services or increase the number of MRI machines, the new law removes the CON requirement but requires a notification to the Tennessee Health Facilities Commission when initial MRI services begin. The notice must also indicate whether patients under age 14 will be treated.

Both changes take effect December 1, 2025.

The new law also affects freestanding emergency departments, removing the requirement for a CON for a hospital to establish a satellite emergency department facility that is within 10 miles of the affiliate hospital's main campus, provided that the location is 10 miles or more from another actively licensed acute care hospital or satellite emergency department facility. This change takes effect July 1, 2025.

In a blog post, Holland and Knight added that other reform efforts could be coming, as the bill mandates that the Tennessee Health Facilities Commission create a plan to study healthcare facility licensure following the changes.

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