Trinity Health of New England is closing two mental health outpatient facilities in Hartford, a move that doesn’t require state approval.

The Office of Health Strategy said that’s because a license for the services was held by a third-party medical group, not a Trinity Health-operated hospital.

Acting Commissioner Amy Porter wrote in a ruling earlier this month that because “[s]ervice delivery, administrative processing, and billing for the services do not take place through a hospital’s facility license…no CON is required for the proposal.”

The proposal focuses on facilities at Saint Francis Hospital’s Asylum Avenue location and a second Trinity Health-owned facility on Tower Avenue.

The health network cited hiring issues, noting a rise in demand for mental health services has created a shortage of workers.

It expects the problem to get worse, forecasting a 27% rise in demand over the next 10 years.

But Trinity Health expressed confidence that patients can find care, noting nonprofit service providers also operate in Hartford and promising to offer telehealth services.

“We recognize the critical importance of mental health and are proud to continue providing services that reflect the changing preferences and needs of those we serve,” the health network said in a statement. “This transformation demonstrates our commitment to patient-centered care.

Lawmakers said that’s not enough, especially given the rise in demand for mental health services.

“This is going to harm the citizens of the state of Connecticut and also specifically Hartford,” Sen. Saud Anwar (D-South Windsor) said.

Anwar acknowledged OHS made the correct decision, a view Sen. Jeff Gordon (R-Woodstock) didn’t share.

“They may have found a technical loophole, but it does not all mean it’s consistent with what they’re overall responsible is,” he said.

The Office of Health Strategy declined to comment, pointing to Porter’s ruling.

Both lawmakers said this highlights a need to address the state’s certificate of need process, which is how hospitals get approval for changes.

Hospitals must prove to OHS that there is a need for new equipment, additions or mergers, as well as detail how any program cuts will not harm the surrounding community.

OHS can also require conditions as part of a certificate of need, but that was not possible in this case because Trinity Health did not need approval.