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Connecticut Governor Signs Public Health Bill: What Health Care Organizations Need to Know

By Victoria Larson & Conor Duffy on June 4, 2026
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On May 14, 2026, Connecticut Governor Ned Lamont signed Public Act No. 26-13, “An Act Concerning Various Revisions to the Public Health Statutes” (the “Act”) into law. The Act contains numerous revisions to State public health and health care laws, and several provisions deserve close attention from health care organizations, including hospitals and health systems, campus clinics, behavioral health providers, EMS providers, nurse’s aides, dentists, and other licensed professionals. We summarize key changes under the Act below.

New Flexibility for Campus Clinics (§1)

Effective October 1, 2026, an infirmary operated by an educational institution may provide care not only to enrolled students, faculty, and employees, but also to dependent family members of those groups when the family members are enrolled in the institution’s health plan.

This change may be significant for colleges, universities, and other educational institutions that operate infirmaries and sponsor health plans covering dependents. Under prior law, these infirmaries were generally limited to evaluating and treating routine health problems, and in some cases providing short-term overnight accommodations, only for students, faculty, and employees.

Increased Regulatory Focus on Managed Residential Communities (§2)

Effective July 1, 2026, the Act requires the Commissioner of Public Health to establish a working group to advise DPH on managed residential communities where assisted living services agencies provide assisted living services to residents. The working group must also evaluate whether DPH licensure of those managed residential communities would help DPH and the communities improve residents’ health, safety, and overall well-being. The working group must include representatives from managed residential communities, assisted living services agencies, residents receiving assisted living services in managed residential communities, relatives of those residents, and an association of aging services organizations in Connecticut. Organizations that operate managed residential communities or contract with assisted living services agencies should monitor the working group’s recommendations because they may influence future licensure or regulatory oversight of these communities, which are already subject to a number of regulatory regimes in Connecticut depending upon the specific services each community provides.

New Patient Notice Requirements for Medical Records Retention and Access (§4)

As of January 1, 2027, health care providers in Connecticut must notify each patient in writing, at initial intake, about the laws governing how long the provider must maintain patient medical records and how the patient may request copies of those records.

Providers should therefore review intake packets, electronic registration workflows, patient portal messaging, and medical records request policies to confirm that they give patients the required written notice at initial intake. As a reminder, under Connecticut law, providers are generally required to maintain medical records for not less than seven years (for individual providers) and not less than 10 years (for hospitals), but in certain circumstances and for certain types of records shorter or longer retention periods may apply (and longer retention may nonetheless be advisable in light of certain statutes of limitations extending to 10+ years).

Additional Data for Community Health Needs Assessments (§11)

Effective October 1, 2026, when conducting a community health needs assessment, the Act requires hospitals to consider including the nutritional needs of community members with diabetes and congestive heart failure. To the extent federal law permits, hospitals must include those nutritional needs in the hospital’s community health needs assessment.

Before starting the next community health needs assessment, hospitals should evaluate whether existing community health data, population health analytics, community benefit materials, or care management information identify nutrition-related needs among community members with diabetes or congestive heart failure.

Hospitals Get New Opioid Treatment Bridge Tools (§12)

Beginning January 1, 2027, the Act permits hospitals to administer buprenorphine or methadone to a patient who presents to the emergency department with symptoms of opioid use disorder without admitting the patient solely for that purpose. The hospital may do so only when (i) such administration is clinically indicated, and (ii) the patient consents.

At discharge, the Act also permits hospitals to offer the patient a prescription for, or supply of, an opioid antagonist, such as naloxone hydrochloride or another similarly acting and equally safe FDA-approved drug for overdose treatment. If the patient accepts, the hospital may provide the prescription or dispense the opioid antagonist. Hospitals may also refer the patient to one or more community providers or opioid treatment programs that can provide continuity in buprenorphine prescribing or methadone administration. If a hospital administers buprenorphine, the hospital must provide a bridging prescription for buprenorphine for the anticipated period while the patient awaits treatment from the referred community provider, if permitted by federal law (e.g., the Controlled Substances Act). Finally, the Act directs that if a hospital administers or dispenses methadone to a patient as permitted by the Act, the hospital must provide a last-dose letter for the patient to give to the local opioid treatment program to which the hospital refers the patient. A “last-dose letter” is a formal, sealed document confirming the exact date, time, and amount of the last methadone dose administered to the patient.

Student Safety Plans Get a Secure Pathway to Schools (§19)

Beginning April 1, 2027, health care providers that prepare a safety plan for a minor following receipt of inpatient behavior health care treatment for at least 12 consecutive days are required to review the safety plan with the minor patient, if the provider believes review is medically appropriate. The provider must also ask whether the minor patient or minor patient’s parent or legally authorized representative consents to sharing the safety plan with the minor patient’s school, and must obtain written consent before transmitting the safety plan to the school (from the patient’s parent or legal representative, or from the minor patient if the patient is 16 years or older). If the required consent is given, the health care provider must transmit the safety plan to the minor’s school district or school using a secure messaging system or another HIPAA-compliant form and manner.

The Act defines a safety plan as a written document created collaboratively between a health care provider and patient that outlines coping strategies, activities, and support networks the patient can access to prevent or manage a potential mental health crisis.

The Act also connects this safety-plan framework to Connecticut’s statewide health information exchange, known as Connie, by making it a goal of the exchange to provide secure messaging organizational accounts to school districts or schools for receiving minor patient safety plans, and to provide access to those organizational accounts for designated employees at no cost.

Notably, the Act also expressly provides that it does not require health care providers to release information to parents or legal representatives of a minor patient “if, pursuant to state or federal law, a minor patient may withhold such information” from a parent or legal representative.  The Act gives, as examples of such information that may be subject to heightened protections, “information regarding pregnancy, abortion, contraceptives, human immunodeficiency virus or other sexually transmitted disease testing or treatment, mental health treatment or any other area of care that a health care provider has promised a minor patient that the health care provider will keep confidential…”  This last cited criterion is particularly notable because it potentially raises the question of whether the Act could be construed as a state law giving heightened protection to any types of health information related to a minor patient if the provider “promise[s]” to keep it confidential.

Nurse’s Aide Oversight Expands (§23)

The Act makes several changes related to the oversight of the practice of a nurse’s aide that take effect October 1, 2027.

The Act revises the definition of “nurse’s aide” to include a registered nurse’s aide who provides nursing or nursing-related services through employment or contract with an “institution.” This change expands DPH’s nurse’s aide registry to cover nurse’s aides working with any DPH-licensed health care institution, not only nursing homes. Individuals who are otherwise licensed or certified by DPH as health professionals and individuals who volunteer to provide those services without monetary compensation remain excluded from the definition of “nurse’s aide.”

The Act expands DPH’s authority to receive, investigate, and prosecute complaints against individuals who provide services as nurse’s aides in any DPH-licensed institution. The grounds for complaint include illegal, incompetent, or negligent conduct in the provision of nursing or nursing-related services; abuse of a resident, patient or client; neglect of a resident, patient, or client; misappropriation of resident, patient, or client property; and fraud or deceit in obtaining or attempting to obtain registration as a nurse’s aide. The Act defines “abuse” and “neglect” by reference to 42 CFR § 483.5, which sets out the Centers for Medicare & Medicaid Services definitions for long-term care facilities.

DPH may now summarily suspend a nurse’s aide’s ability to practice before final adjudication of a complaint or during the appeals process if DPH finds that the nurse’s aide would pose a clear and immediate danger to public health and safety if allowed to continue practicing. DPH may also discipline a nurse’s aide by revoking or suspending a credential; censuring the violator; issuing a letter of reprimand; placing the nurse’s aide on probationary status; or imposing a civil penalty of up to $25,000.

Finally, the Act updates terminology under the nurse’s aide training requirements by replacing references to “residents” and “residents’ rights” with “patients” and “patients’ rights.”

Connecticut Moves Toward EMS Licensure Portability (§28)

Effective October 1, 2026, Connecticut adopts the Recognition of Emergency Medical Services Personnel Licensure Interstate Compact, but the state will not actually enter the compact earlier than one year after Massachusetts, New York, or Rhode Island enacts it. The compact is designed to enhance access to EMS services by facilitating day-to-day movement of EMS personnel across state lines and allowing state EMS offices to provide immediate legal recognition to EMS personnel licensed in another member state.

At a high level, the compact applies to EMS personnel such as EMTs, advanced EMTs, and paramedics. The compact may be relevant for EMS organizations and health systems with multistate emergency services operations because it creates a framework for qualifying EMS personnel licensed in one member state to practice in another member state under the compact’s privilege to practice model. Because Connecticut’s participation cannot begin until at least one year after Massachusetts, New York, or Rhode Island enacts the compact, EMS organizations should monitor neighboring-state adoption before treating the compact as operational in Connecticut.

Dentists Enter the Cosmetic Injection Space (§34)

Effective October 1, 2026, the Act allows Connecticut-licensed dentists to administer cosmetic injections to a patient’s face if the dentist satisfies specified training and insurance requirements. A “cosmetic injection” is defined under the Act as a nonsurgical procedure involving the injection of a substance, including botulinum toxin or dermal filler, to alter or enhance a person’s physical appearance.

To qualify, the dentist must successfully complete in-person, hands-on training in the administration of cosmetic injections through a continuing education provider or program approved by the Commissioner of Public Health or accredited by a national professional accrediting body. The dentist must also maintain professional liability insurance that covers cosmetic injection procedures. Additionally, dentists may not delegate cosmetic injections to dental hygienists, dental assistants, or other auxiliary personnel.

The Act still imposes limits on the type of cosmetic procedures dentists are allowed to perform. Dentists cannot administer injections into the tear trough, infraorbital hollow, eyelids, medial canthal region, or other orbit-adjacent soft tissue for periocular volumization or under-eye hollow correction. The Act also does not authorize dentists to administer injections into the forehead, glabella, or eyebrows for improved cosmesis.

The Act, however, does allow dentists to administer a neuromodulator to the lateral canthal region, including for treatment of lateral canthal rhytids (a/k/a, crow’s feet). It also permits injections for management of orofacial pain, temporomandibular disorders, or other oromandibular conditions, or dermal filler to the malar, zygomatic, or midface region when the primary intended treatment site is the cheek or midface and the injection site remains inferior to the infraorbital rim.

Key Takeaways from the Act

  • Health care providers should prepare to give patients written medical records retention and access notices at initial intake by January 1, 2027.
  • Managed residential communities, assisted living services agencies, and senior living campus operators should monitor the DPH working group’s recommendations and the commissioner’s February 1, 2027 report to the Public Health Committee, and consider opportunities for their representatives to participate as part of the working group.
  • Hospitals should review their community health needs assessment processes to determine whether available data warrant including nutritional needs for community members with diabetes and congestive heart failure.
  • Hospitals should review emergency department opioid use disorder protocols before January 1, 2027, including buprenorphine and methadone administration, opioid antagonist offers, referrals, bridging prescriptions, and last-dose letters.
  • Educational institutions that operate infirmaries should evaluate whether their clinical operations and health plan arrangements will extend services to dependent family members enrolled in the institution’s health plan, and consider how that will impact other operations and compliance programs (including records protections and processes under FERPA and/or HIPAA).
  • Hospitals and pediatric behavioral health providers should assess how they will obtain consent, transmit safety plans securely, and coordinate with schools when a minor patient receives at least twelve consecutive days of inpatient behavioral health care treatment.
  • Institutions that employ or contract with nurse’s aides should prepare for the October 1, 2027 expansion of DPH’s registry, complaint, discipline, and training framework.
  • EMS providers and organizations with cross-border operations should monitor whether Massachusetts, New York, or Rhode Island enacts the EMS compact because Connecticut’s participation cannot begin earlier than one year after one of those states does so.
  • Dentists that want to administer cosmetic injections should assess training, professional liability insurance, site-of-service limits, nondelegation requirements, and any future DPH regulations.
Photo of Victoria Larson Victoria Larson

Victoria C. Larson assists a variety of health care providers and health-related businesses, such as health systems, hospitals, physician groups, clinically integrated networks, and long-term care facilities, with a range of health care regulatory matters, including licensure, corporate practice of medicine requirements, privacy…

Victoria C. Larson assists a variety of health care providers and health-related businesses, such as health systems, hospitals, physician groups, clinically integrated networks, and long-term care facilities, with a range of health care regulatory matters, including licensure, corporate practice of medicine requirements, privacy issues, and federal and state health care fraud and abuse compliance. Read her full rc.com bio here.

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Photo of Conor Duffy Conor Duffy

Conor Duffy is co-chair of Robinson+Cole’s Health Law Group and a member of the firm’s Data Privacy + Security Team. Mr. Duffy advises hospitals, physician groups, accountable care organizations, community providers, post-acute care providers, and other health care entities on general corporate matters…

Conor Duffy is co-chair of Robinson+Cole’s Health Law Group and a member of the firm’s Data Privacy + Security Team. Mr. Duffy advises hospitals, physician groups, accountable care organizations, community providers, post-acute care providers, and other health care entities on general corporate matters and health care issues. He provides legal counsel on a full range of transactional and regulatory health law issues, including contracting, licensure, mergers and acquisitions, the False Claims Act, the Stark Law, Medicare and Medicaid fraud and abuse laws and regulations, HIPAA compliance, state breach notification requirements, and other health care regulatory matters. Read his full rc.com bio here.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    Health Law Diagnosis
  • Organization:
    Robinson & Cole LLP
  • Article: View Original Source

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