North Carolina is one of 35 states with CON laws, which require health care providers to gain approval from the government before adding or expanding health care services, building or acquiring new facilities, or incurring capital expenditures above a specific dollar amount. In fact, with 61 different types of certificates of need, North Carolina has the 2nd most expansive CON program in the nation. And behind all this bureaucratic red tape are patients whose real need for health care goes unmet.