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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

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

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

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

Update to Texas v. United States

In our December blog post, we discussed Texas v. United States, No. 19-10011 (5th Cir.), a Texas federal district court decision which struck down the entirety of the Affordable Care Act (“ACA”). The case is being appealed to...more

New California Law re HMO M&A

On September 7, 2018, Governor Jerry Brown signed into law Assembly Bill No. 595, A.B. 595, which amends the California Health and Safety Code to increase oversight by the California Department of Managed Health Care (“DMHC”)...more

Part I: How We Got Here: President Obama to Obamacare to President-elect Trump

One thing that has become clear since the election of Donald Trump last week is that efforts to repeal or amend the Affordable Care Act (ACA) will be a high priority legislative item for next year’s Congress and the incoming...more

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