New Mini-HSR Laws Take Effect This Summer

Primary Transaction Notification Laws

Last Updated July 11, 2025

State

Law/Code

Thresholds

Notification

Timing

California

Cal. Health & Safety Code §§ 127500 et seq. (OHCA)

At least one party has annual healthcare revenues/assets ≥ $25 million for the past three fiscal years (or ≥ $10 million with a partner generating ≥ $25 million) or involves a health professional shortage area.

Must notify California’s Office of Health Care Affordability of any transaction resulting in a “material change” in control/ownership of healthcare entities.

90 days before closing. Parties can expect a 90-180 day delay until closing.

California Corporate Code § 14700 et seq. (CA AG Office)

Acquiring party must trigger HSR or acquire > 20 retail drug/grocery firms.

Must notify California AG of a retail grocery firm or retail drug firm acquisition.

180 days before closing.

Colorado

Colo. Rev. Stat. § 6-19-101 et seq.

Hospitals meeting the 50% threshold.

Must notify Colorado AG of a transfer of ≥ 50% of a hospital's assets.

60 days before closing.

Senate Bill 25-126

Copy required if:
a) The party has its principal place of business in Colorado; or

b) The party has annual net sales in Colorado of ≥ 20% of HSR threshold (currently $124.6 million).

Must send the Colorado AG a copy of the HSR form contemporaneously with filing HSR.

No waiting period.

Connecticut

Conn. Gen. Stat. § 19a-486i et seq.

Applies to healthcare entities, including transactions where one party is a hospital, hospital system, or other healthcare provider triggering HSR.

Must notify Connecticut AG of any material change in control involving hospitals or group practices.

Separate post-closing notice to the state Office of Health Strategy also required.

30 days before closing.

Hawaii

Haw. Rev. Stat. § 323D-71 et seq.

≥ 20% of a hospital in Hawaii.

Must notify (and get approval) from the state Health Planning and Development Agency and AG for 20% ownership or a controlling interest in a hospital.

90 days before closing.

Illinois

Public Act 103-0526, 740 Ill. Comp. Stat. 10/7.2A

If all parties are Illinois-based, required.

If an out-of-state party is involved, notice is required if that party generates ≥ $10 million in annual Illinois patient revenue.

Must notify the Illinois AG for any merger, acquisition or affiliation involving healthcare facilities or provider organizations.

30 days before closing.

Indiana

IC 25-1-8.5

≥ $10 million in total assets and private equity firms acquiring Indiana health providers.

Must notify Indiana AG if a “health care entity” involved in a merger or acquisition.

90 days before closing.

Massachusetts

958 CMR 7.02 (Mass. Gen. Laws ch. 6D, § 13)

One of the providers/provider organizations must have had ≥ $25 million in annual revenue from payor reimbursements for patient care.

Must notify Health Policy Commission of any material transaction involving a hospital or provider organization for a cost and market impact review.

60 days before closing and cannot close until 30 days after the HMC issues its market impact report (if necessary).

Minnesota

Minn. Stat. § 145D.01–.02

≥ $80 million in revenues for large deals; $10 million to $80 million for smaller deals.

Must notify Minnesota AG for certain healthcare transactions (including certain serial minor transactions).

60 days for large deals; 30 days for smaller deals.

Nevada

Nev. Rev. Stat. § 598A.290 et seq.

Market share threshold.

Must notify Nevada AG for certain transactions of healthcare providers or health insurers.

30 days before closing.

New Mexico

Health Care Consolidation Oversight Act

Transactions involving New Mexico hospitals only.

Must notify (and obtain approval) from New Mexico Office of Superintendent of Insurance hospital deals.

120 days before closing.

New York

N.Y. Public Health Law § 4550 et seq.

Deals that increase gross in-state revenues by ≥ $25 million.

Must notify New York Department of Health of “material transactions” by healthcare entities.

30 days before closing.

Oregon

Or. Rev. Stat. §§ 415.500 et seq.

One party has average revenue (nationwide) of ≥ $25 million in the last three fiscal years; other party has an average revenue of ≥ $10 million in the last three fiscal years (or last full year if new).

Must notify (and obtain approval) from the Oregon Health Authority (OHA) for deals involving hospitals, health systems, insurers or large physician groups.

180 days before closing; the OHA can expedite and “stop the clock” for incomplete filings or requests for information.

Rhode Island

R.I. Gen. Laws § 23-17.14-1 et seq.

Any ownership or control transfer of Rhode Island hospitals.

Must notify the Department of Health (DOH) and the AG for any ≥ 20% acquisition of a hospital.

30 days for notice, 180 days for final decision.

Vermont

18 Vt. Stat. Ann. §§ 9405b, 9405c

Vermont-licensed hospitals and medical practices with one or more physicians.

Must notify AG of acquisitions of hospitals and medical practices with one or more physicians.

90 days before closing.

Washington

Wash. Rev. Code §§ 19.390.010 et seq.

For out-of-state entities, ≥ $10 million in revenue from Washington patients.

Must notify Washington AG for hospital deals, including provider organizations with ≥ seven providers.

60 days before closing. Satisfied if need to send a copy under SB 5122 below.

SB 5122

Copy of HSR required if:
a) The party has its principal place of business in Washington;
b) The party or another entity controlled by the party has annual net sales in Washington of ≥ 20% of HSR threshold (currently $124.6 million); or
c) The party meets the definition of “provider” or “provider organization” under RCW 19.390.020.

Must contemporaneously send HSR filing to Washington AG.

No waiting period.