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State Antitrust Enforcement Roundup: New Laws; New Potential Legislation; and New (and Broader) Areas of Focus

The number of U.S. states implementing or considering new antitrust laws (or supplementing existing laws) targeting proposed transactions continues to grow. As detailed in our healthcare merger matrix, many states have...more

Major Regulatory Updates from the West Coast: New California and Washington Approaches to Healthcare Private Equity and MSO...

State legislatures on the West Coast are intensifying their focus on private equity and management service organizations (MSOs) in healthcare, introducing new regulatory measures that could significantly reshape investment...more

Navigating the Matrix of State Healthcare Approvals

The outlook for federal antitrust enforcement remains murky, at best, with uncertainty about whether the new federal HSR rules, merger guidelines, and existing enforcement actions. The forecast for state antitrust...more

Massachusetts Expands Oversight of Private Equity Investment in Healthcare: Key Takeaways from House Bill 5159 Signed into Law by...

On January 8, 2025, Massachusetts Governor Maura Healey signed House Bill 5159 (“H.5159”) into law, marking a notable expansion of the regulation of private equity investments within the Massachusetts healthcare sector. The...more

Update: Governor Newsom Vetoes California’s AB 3129 Targeting Healthcare Private Equity Deals

On September 28, 2024, Governor Newsom vetoed Assembly Bill No. 3129 (AB 3129), which would have required private equity groups and hedge funds to obtain the Attorney General’s written consent at least 90 days prior to...more

Update: AB 3129 Passes in California Senate and Nears Finish Line

After its passage in the California Senate on August 31, 2024, Assembly Bill No. 3129 (AB 3129) is now headed to Governor Newsom’s desk. As discussed in depth in our previous blog series on AB 3129, the legislation would...more

Update: OHCA Approves Amendments to Cost and Market Impact Review (CMIR) Regulations

California’s Office of Health Care Affordability (OHCA) has officially approved amendments (“Amendments”) to the cost and market impact review (CMIR) regulations, effective August 22, 2024. Most significantly, these...more

Massachusetts Senate Passes Bill to Increase Oversight of Private Equity Healthcare Transactions

On July 18, 2024, the Massachusetts Senate passed S. 2871, An Act Enhancing the Health Care Market Review Process (the Bill), to increase oversight of healthcare transactions involving private equity firms, real estate...more

OHCA Proposes Amendments to its Cost and Market Impact Review Program

Only two months after California’s cost and market impact review (CMIR) regime began to require notice of certain healthcare-related transactions, the Office of Health Care Affordability (OHCA) has already proposed several...more

California Attorney General Advocates for Greater Antitrust Enforcement in Private Equity in Healthcare

On June 6, 2024, California Attorney General Rob Bonta announced that he led a multistate coalition of eleven (11) state attorneys general in in submitting a comment letter (the “Comment Letter”) in response to the Federal...more

Update: California State Assembly Passes AB 3219 Requiring State Approval of Private Equity Healthcare Deals

California’s AB 3219, which would require private equity firms and hedge funds to obtain prior approval to consummate certain healthcare-related transactions, is now one step closer to becoming law following the State...more

U.S. Department of Labor Rescinds Trump-Era Rule on Association Health Plans (AHPs)

On April 29, 2024, the U.S. Department of Labor (the “DOL”) issued a final rule (the “Final Rule”) rescinding the 2018 Association Health Plan rule (“2018 AHP Rule”), thereby marking a return to the more rigid pre-2018...more

California is Capping Health Care Cost Increases – Starting at 3.5% in 2025

As we previewed last year regarding SB 184 and the establishment of the California Office of Health Care Affordability (OHCA), California now has taken a significant regulatory step aimed at restraining growth in health care...more

California’s AB 3129: A New Hurdle for Private Equity Health Care Transactions on the Horizon?

Parties involved in or considering health care transactions in California have been focused on navigating the new rules set by California’s Office of Health Care Affordability (OHCA), and newly proposed legislation could...more

The Corporate Transparency Act: A Reporting Guide for Medical Groups and MSOs

Congress passed the Corporate Transparency Act (the “CTA”) in 2021 with the aim of enhancing transparency in entity structures and ownership as well as combating terrorism, money laundering, and other forms of corporate...more

The Stage is Set: California Finalizes OHCA Regulations Requiring Notice and Review of Material Healthcare Transactions in 2024

At long last, the cost and market impact review (CMIR) regulations promulgated by the California Office of Health Care Affordability (OHCA) have been approved by the California Office of Administrative Law (OAL). The final...more

OHCA Published Near-Final Draft of Regulations Requiring Notice and Review of Material Healthcare Transactions in 2024

In the final days of November, the Office of Health Care Affordability (OHCA) published three updates related to its proposed regulations regarding the review of certain healthcare transactions in California: 1. the...more

OHCA’s Revised Regulations Following Comments from Industry Stakeholders

As we anticipated in our previous blog article, the Office of Health Care Affordability (OHCA) made revisions to its proposed regulations following the public workshop hosted by the California Department of Health Care Access...more

Public Workshop for OHCA’s Proposed Regulations Sparks Lively Discussion Among Industry Stakeholders

As we previewed in our previous blog article, the California Department of Health Care Access and Information (“HCAI”) hosted a public workshop on August 15, 2023 for in-person and virtual attendees to make comments and pose...more

Update from California’s Office of Health Care Affordability (OHCA): Proposed Regulations re Material Change Transactions and...

As we previewed in our blog article in March on the establishment of California’s new Office of Health Care Affordability (OHCA), OHCA has issued proposed regulations available on the OHCA website, that provide...more

California Office of Health Care Affordability: Another Regulatory Hurdle for California Healthcare M&A Transactions?

California has a new regulatory review process that could have implications for healthcare mergers and acquisitions and similar transactions in the state. By way of background, after nearly two years of negotiations with...more

COVID-19 Impacts and Outcomes on Hospital Margins in 2021: Increased Activity in Hospital Transactions in 2022?

In its December Hospital Flash Report, Kaufman Hall identified and reviewed the continued, negative impact of COVID-19 on hospital operating margins. After a dramatic drop in hospital margins during the height of the pandemic...more

The American Rescue Plan Act of 2021: A New Lease on Life for the Affordable Care Act?

On March 10, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (the “Act”). This $1.9 trillion COVID-19 relief package not only includes a whole host of healthcare-related provisions, but, along with...more

Secret Rules and Hidden Penalties: Biden Executive Order Takes Aim at the Trump Administration’s Efforts to Limit HHS’s Use of...

Executive Orders and the Biden Administration’s promises to postpone or withdraw certain last-minute, so-called “midnight rules” promulgated by the Trump Administration are currently grabbing everyone’s attention, especially...more

Texas v. California: SCOTUS Hears Oral Arguments About the Constitutionality of the ACA

On November 10, 2020, the U.S. Supreme Court heard oral arguments for California v. Texas, a case that will potentially decide the fate of the Patient Protection and Affordable Care Act (“ACA”). As discussed in prior...more

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