Certificate of Need (CON) laws remain one of the most debated—and misunderstood—regulatory frameworks in healthcare. In this in-depth conversation, Chris Comeaux is joined by two of the nation’s most respected Hospice association leaders: Paul A. Ledford, President & CEO of the Florida Hospice & Palliative Care Association, and Tim Rogers, President & CEO of the Association for Home & Hospice Care of North Carolina.
Together, they unpack why Certificate of Need was created, what problems it was designed to solve, and why Hospice—unlike many other healthcare services—still requires thoughtful regulation. Drawing on decades of real-world experience, they compare CON and non-CON states, revealing how deregulation can unintentionally lead to provider oversaturation, cherry-picking, diminished rural access, fraud, and weakened patient experiences.
Part One lays the foundation for a deeper conversation about quality, equity, and patient protection at the end of life—and why thoughtful oversight still matters in preserving the integrity of the Hospice benefit.
The discussion moves beyond ideology into evidence: utilization data, patient outcomes, Hospice scale, quality reporting, and the lived experience of families navigating end-of-life care. The episode also explores how states like Florida and North Carolina structure CON to balance access, sustainability, and accountability—and what principles any state should consider if designing a Hospice regulatory framework from scratch.
This episode explores what actually happens in states without Hospice CON: oversaturation in urban markets, reduced access in rural areas, fragmented care, and increased vulnerability to fraud and abuse. The discussion challenges common assumptions about competition and access, using data, policy insight, and firsthand examples to illustrate the unintended consequences of deregulation.
👉 Don’t miss Part Two, where the conversation continues with a closer look at quality outcomes, bad actors, and what states can learn from one another moving forward. (dropping this Friday, January 30th)
Guests
Tim Rogers
President & CEO of the Association for
Home & Hospice Care of North Carolina
Paul A. Ledford
President CEO Florida Hospice & Palliative Care Association
Host
Chris Comeaux
MLAS, CPA
President / CEO TCN / TCG
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