I cannot say how much I hate Michigan's CoN rule. It is entirely corrupt and it ends up being self-dealing between the big players, until of course, protons come up.
U of M wants them bad. Of course Beaumont (Corewell) and Flint are going to fight this. But, this has nothing to do with medical necessity or numbers of patients. It's all a turf war. In my opinion, if the institution is funding it, let em open one and see who ends up winning.
But good luck on starting a center on your own. The big boys will literally line up against you even if you want to put one of up in an underserved area. They will fight you, take the CoN for that area and then put it in a suburb that has 3 linacs already.
It is the worst thing. PET-CT trucks come a half a day a week in same areas, when there is plenty volume to have a unit at a hospital or outpatient center. Instead, we have delays.
But, once you have your CoN, it's game on. The numbers needed to support an additional CoN to add on are quite low and so big systems get bigger, small systems will never obtain a CoN.
I hate CoNs so much. Even though my group is large enough to benefit. We can get 4 more CoN based on our volume