Connecticut Health Law

Connecticut’s 2026 legislative session brought significant changes for health care organizations, individual providers, and human resources (HR) professionals across the state. Despite being a “short session” in an even-numbered year, lawmakers passed several bills with meaningful compliance implications.

Below is an overview of the most noteworthy changes taking effect on October 1, 2026, along with key compliance deadlines health care employers should note.

Certificate of Need Law Changes (PA 26-68, §152 and §§ 226-237)

Connecticut has enacted major changes to the certificate of need (CON) law. Although the effective date is October 1, 2026, most changes will not apply until July 1, 2027. For a detailed analysis, see our prior blog addressing the significant changes to the CON law.                           

Hospital Financial Assistance Policy Requirements (PA 26-68, §355 and PA 26-76, §28)

A new law requires hospitals to maintain a financial assistance policy consistent with federal law. Each hospital must include on or with every billing statement information specified in the statute. This includes a clear, conspicuous notice that financial assistance may be available and that any patient may apply without a fee. The notice must be provided in specified languages and made available in other languages upon request. Hospitals must also post the required information prominently on their websites.

Patient Medical Records Notification Requirements (PA 26-13, §4)

By January 1, 2027, each health care provider (not defined in the statute) must notify patients in writing at the time of initial intake of the following:

• The laws concerning how long the provider must maintain patient medical records; and
• How patients may request copies of their medical records from the provider.

New Civil and Criminal Penalties for Unlicensed Health Care Institutions (PA 26-68, §§183-184 and PA 26-76, §§77-78)

The budget implementer (as amended by PA 26-76) increases criminal penalties and adds new civil penalties for unlicensed health care institutions. Key provisions include:

• Operating an institution without a license is a class C misdemeanor, punishable by a fine of up to $2,000 for each day of a continuing violation.
• DPH may hold a contested case hearing and impose a civil penalty on any person operating an institution without the required license. The civil penalty may not exceed $5,000 per day of violation.

The same penalties apply to anyone providing nursing facility management services without the certificate required under CGS §19a-561.

An institution that applied for license renewal within 60 days of the lapse date is exempt from criminal penalties, even if the renewal application was incomplete at the time. As under current law, an exception also exists for state or federally regulated financial institutions that have succeeded to title of the premises by mortgage foreclosure, provided the operator continues to occupy the property. The fine for owners of real property on which an unlicensed institution operates remains unchanged: up to $100 per offense, with each day of a continuing violation after conviction treated as a separate offense.

Emergency Treatment of Opioid Use Disorder in Hospitals (PA 26-13, §12)

Effective January 1, 2027, hospitals may, to the extent permitted under federal law:

• Administer methadone or buprenorphine to an emergency department patient with symptoms of opioid use disorder without requiring hospital admission, if clinically indicated and the patient consents.
• Offer the patient a prescription or supply of an opioid antagonist upon discharge from the emergency department, and, if the patient accepts, provide the prescription or dispense the medication.
• Refer the patient to one or more community providers or opioid treatment programs.

If clinically indicated, hospitals may dispense a supply of methadone in accordance with federal law. When a hospital administers or dispenses methadone, it must provide the patient with a “last-dose letter,” a formal, sealed document confirming the exact date, time, and amount of the last dose administered, to present to the local opioid treatment program.

When a hospital administers buprenorphine, it must provide the patient, to the extent permitted by federal law, with a “bridging prescription,” a temporary, short-term prescription to ensure continuity of medication while the patient awaits specialized care from the community provider to which the hospital refers the patient.

This new law does not require medication when clinically contraindicated, limit clinician professional judgment, or preclude the use of medications other than buprenorphine or methadone for opioid use disorder when clinically indicated and the patient consents.

Medicaid Audit Extrapolation Rules (PA 26-14, §7)

The amended law establishes new extrapolation limits for Medicaid audits. Beginning with audit review periods commencing January 1, 2027, the Department of Social Services (DSS) must provide up-to-date education materials and technical assistance documents to help providers with proper Medicaid billing before extrapolation occurs.

The new extrapolation limits do not apply to providers whose rates are set under CGS §17b-340 (e.g., nursing homes, chronic disease hospitals associated with chronic and convalescent homes, rest homes with nursing supervision, residential care homes and residential facilities for persons with intellectual disability).

Restrictions on Arrests in Health Care “Protected Areas” (PA 26-14, §7)

A new law restricts peace officers, including federal law enforcement officers, from detaining, arresting, or otherwise taking an individual into custody in a “protected area” based on a civil offense unless two conditions are met. Protected areas include hospitals and urgent care centers, their grounds, and parking lots and garages used in their operations, as well as state and municipal facilities.

• The officer is acting in his or her official capacity; and
• The individual is the subject of a judicial warrant.

An aggrieved individual may bring a civil action for equitable relief or damages in Superior Court; a damages action may be triable by jury. The court may grant appropriate legal and equitable relief, including temporary or permanent injunctive relief, punitive damages, attorney's fees, and court costs.

This restriction does not apply to infractions, motor vehicle violations, or arrests for criminal offenses punishable by imprisonment, contempt of court, a judge-issued capias, a parole or probation violation warrant, or an emergency commitment.

Expanded Definition of Anti-Steering Clause in Health Care Contracts (PA 26-68, §218)

A new amendment to anti-steering clause prohibitions clarifies that an “anti-steering clause” includes any utilization management provision in a health care contract. In effect, hospitals and health systems may not use contract terms to limit a health carrier's or health plan administrator's use of utilization management tools, such as prior authorization, to encourage enrollees to seek care from competing providers.

Enhanced Workers’ Compensation Benefits for Health Care Providers and Facility Employees (PA 26-12, §1)

Under general workers’ compensation law in Connecticut, workers who are totally incapacitated due to a job-related injury are entitled to 75% of their average weekly earnings, subject to a cap. The new law enhances these benefits for health care providers (including certain volunteers) and other employees of health care facilities. When these workers are victims of physical or negligent assault while discharging their duties and the assault results in total or partial incapacity to work, they must be paid 100% of their average weekly earnings without regard to any statutory cap.

The weekly compensation must also include payment for: (1) expenses reasonably incurred for medical or other necessary services due to the assault; and (2) lost wages due to a court appearance in connection with the assault. An employee absent due to an injury from the assault or for a court appearance must continue to receive full salary. The employer may not charge these absences against sick, vacation, or personal leave days, though the employer may deduct the amount of any workers' compensation award from salary payments.

Penalties for Unlicensed Health Care Practitioners (PA 26-68, §185)

The statute authorizing Department of Public Health (DPH) licensing boards and commissions to act against persons violating applicable statutes or regulations has been amended. DPH or the appropriate board or commission may now, after a hearing, impose a civil penalty of up to $25,000 on a person who provides professional services under DPH’s jurisdiction without an appropriate license or certificate. Each day of providing services in violation of the law is grounds for the penalty.

New Social Worker Programs at DCF (PA 26-26, §5)

By January 1, 2027, the Department of Children and Families (DCF) must establish:

• A prospective social worker internship program for eligible participants lasting at least one academic semester; and
• A first-year social worker mentorship program for newly hired DCF social workers.

DCF must pay a stipend to each intern and mentor who successfully completes the program and may pay a stipend to newly hired social workers who successfully complete the mentorship program. DCF must also submit annual reports regarding the programs to the newly established Child Welfare Policy and Oversight Committee and to the Committee on Children of the General Assembly.

PPE Requirements for Home Health Aide Agencies (PA 26-74, §4)

Home health aide agencies must provide their employees and contractors who provide home health aide services with personal protective equipment (PPE) at no cost. Required PPE includes disposable gloves, hand sanitizers, aprons, gowns, foot covers, face shields, N95 (or higher) face masks, and surgical masks – whatever is necessary to safely provide home health aide services to clients.

Additional Laws Affecting Health Care and Other Employers

The following two pieces of legislation are not specific to the health care industry but have significant implications for all Connecticut employers.

Automated Employment Decision Technology: New HR Compliance Requirements (PA 26-15, §§ 7-14)

A new law regulates the use of “automated employment-related decision technology” in making employment decisions, effective October 1, 2027. This term generally refers to technology that processes personal data and uses computation to generate predictions, recommendations, classifications, rankings, or scores that substantially factor into or materially influence employment-related decisions.

Beginning with technology deployed on or after October 1, 2027, employers using this technology must provide certain notices to employees and applicants. Before any decision is made, employers must provide written notice disclosing the technology’s purpose, the categories of personal data it will analyze, and how the data will be assessed in reaching a decision. Although employers need not disclose trade secrets or other legally protected information, they must notify the employee or applicant that information is being withheld and explain the basis for that decision. A violation of these requirements is an unfair or deceptive trade practice, but no private right of action is available, i.e. only the Connecticut Attorney General may enforce it.

Additionally, effective October 1, 2026, an employer's use of this technology is not a defense to an employment discrimination complaint.

Employee Monitoring: Updated Notice Requirements for Connecticut Employers (PA 26-73)

Connecticut’s law governing employee monitoring has been amended. Under current law, employers must generally give written notice prior to electronically monitoring their employees. The amended law now also requires that the notice include the specific locations where monitoring may occur. There is an exception to this location requirement when the employer has reasonable grounds to conduct monitoring for security and employee safety purposes.

Employers must provide new employees hired on or after October 1, 2026, with a written statement in plain language prior to the commencement of employment. This statement must advise which activities are prohibited and may be monitored without prior written notice—that is, when an employer has reasonable grounds to believe employees are engaged in conduct that violates the law, violates the legal rights of the employer or its employees, or creates a hostile workplace environment, and monitoring may produce evidence of that misconduct.

Pullman & Comley’s Health Care practice has broad experience advising hospitals, physician groups, behavioral health providers, and other health care organizations, health care transactions, and regulatory compliance throughout Connecticut. Should you have any question on how the new laws impact your current operations and future organizational goals, please contact Steve Cowherd, Isabelle Bibet-Kalinyak, Mike Kurs or Margaret Bartiromo.