Connecticut Disbands Office of Health Strategy and Reassigns Health Care Oversight and Policymaking Authority Across State Agencies

By Conor Duffy, Michael Lisitano & Ivy Miller

June 29, 2026

Connecticut Governor Ned Lamont recently signed Public Act No. 26-68 (“the Act”), which includes the elimination of the Office of Health Strategy (OHS) and reassignment of its statutory authority over the health care delivery system in Connecticut. The Act’s repeal of OHS’s enabling statute and the transfer of its authority to other state agencies are scheduled to take effect on July 1, 2026.

Certificates of Need

Previously, OHS oversaw the Connecticut Certificate of Need (CON) program; however, under the Act the CON program will move to DPH. We have previously written about the Act’s changes to the CON program. Please see here for our analysis of the Act’s changes to the CON process, and here for our analysis of the new process for hospitals seeking to pause or terminate service lines.

For now, it is important for CON applicants and parties to understand that from July 1, 2026, until July 1, 2027, DPH will oversee the CON program in its current state until the newly established CON processes go into effect July 1, 2027.

Functions Moving to DPH

Aside from authority over the CON process, several notable functions previously vested in OHS shift to DPH:

Health Systems Planning Unit – The Act re-establishes the Health Systems Planning Unit within DPH, under the direction of the Commissioner of Public Health, rather than within OHS.
Nonprofit hospital transactions and related health care market reporting – The Act moves several hospital and group practice transactions and other reporting functions from OHS to DPH. For nonprofit hospital sales, all authority previously conferred to the Commissioner of Health Strategy is now granted to the Commissioner of Public Health. Hospital, hospital system, and group practice reporting also shifts to DPH, including written notices after certain transactions and health care entity annual reporting.
Health care facility oversight and reporting – DPH will now oversee all facility fee requirements, including hospital, health system, and hospital-based facility reporting requirements, and will hold enforcement authority arising from such reporting requirements.
Patient billing and financial assistance provisions – Hospitals must now report charity care and reduced-cost service policies to the Health Systems Planning Unit of DPH, and hospitals must provide detailed patient bills upon request of DPH or a patient.
Health data functions – Short-term acute care general and children’s hospitals will need to submit patient-identifiable inpatient discharge data and emergency department data to DPH, and outpatient surgical facilities and certain hospital outpatient surgery departments must submit such data to DPH.
Community Health Worker Advisory Body – DPH now has jurisdiction over the Community Health Worker Advisory Body.

Functions Moving to OPM

The Act transfers key health care data reporting authorities to OPM, including:

Core health information technology responsibilities – OPM will now oversee implementation and revision of the statewide health information technology plan, adoption of electronic data standards, oversight of the Statewide Health Information Exchange (discussed further below), and associated legislative committee reporting.
Statewide Health Information Exchange – The Act gives OPM administrative authority over the Statewide Health Information Exchange, known as Connie. The Secretary of OPM is responsible for designating and posting the systems, technologies, entities, and programs that constitute the exchange. OPM also receives authority to adopt regulations and implement interim policies and procedures for Connie, including public hearing and notice requirements.
State Health Information Technology Advisory Council – This council, tasked with policy recommendations for health information technology and exchange efforts, is reoriented to advise the Secretary of OPM and the health information technology officer.
All-payer claims database – OPM becomes the successor agency for the all-payer claims database program, now overseeing the planning, implementation, and administration of the all-payer claims database program, securing data collection and storage, auditing reporting entity data, and maintaining written administrative procedures in consultation with the Health Information Technology Advisory Council.
Consumer health information website – The Secretary of OPM receives responsibility for posting consumer-facing health cost and quality information, making specified lists of frequent services and procedures publicly available, and issuing reports on billed and allowed amounts and out-of-pocket costs.
Health care cost growth and quality benchmark authority – The Act redesignates the agency responsible for establishing the health care cost growth and health care quality benchmarks every five years to OPM. The Act also confers authority in OPM for monitoring and identifying entities exceeding benchmarks or failing targets and informing the public as such.

Functions Moving to DSS

The authorities reallocated to DSS include:

Hospital financial health reporting – Hospitals must submit semiannual financial health reports to the Commissioner of Social Services, rather than the Commissioner of Health Strategy. DSS may require additional information if a hospital reports two consecutive quarters of 60 days or less of cash on hand, and DSS must contact a hospital to offer assistance if a report reflects two consecutive quarters of 45 days or less of cash on hand.
Covered Connecticut and waiver-related provisions – The Commissioner of Social Services remains responsible for seeking Section 1115 waivers, but the Act removes the requirement for prior consultation with the Insurance Commissioner and OHS from that provision. The Act also permits DSS, rather than OHS, to seek Section 1332 waivers from the federal government.

Community Benefit Program Reporting Moves to OHA

The Act reassigns hospital community benefit program reporting, which includes hospitals’ community health needs assessments, implementation strategies, and annual reports, from OHS to OHA. Hospitals must submit community benefit reporting to OHA or to a designee selected by the Healthcare Advocate.

The annual summary and analysis of community benefit program reporting is assigned to the Healthcare Advocate, who must post the summary and analysis on the OHA website and solicit stakeholder input through a public comment period. OHA uses that reporting and stakeholder input to identify additional stakeholders, determine how those stakeholders could assist in addressing community health needs, determine whether to make recommendations to DPH in developing the state health plan, and inform the statewide health care facilities and services plan.

Key Takeaways

Broadly, the above-discussed sections of the Act eliminate OHS as a statutory office and distribute its principal functions among multiple agencies. DPH becomes the key successor for the Health Systems Planning Unit, CON authority, nonprofit hospital transaction authority, and multiple health facility oversight functions. OPM becomes the key successor for statewide health information technology, the Statewide Health Information Exchange, the all-payer claims database, consumer health information tools, and benchmark programs. DSS becomes the successor for hospital financial health reporting and receives Covered Connecticut waiver authority. OHA becomes the successor for community benefit program reporting.

Despite administrative authority being distributed across multiple state agencies, the substantive reporting and administrative requirements for health care entities remain largely unchanged. Health care entities should be aware of the different agencies to which they must make reports and disclosures. We will continue to monitor implementation of these administrative changes.