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Healthcare Notice Requirements

Holland & Knight LLP

New York State Department of Health Publishes Form of Material Transactions Notice

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The New York State Department of Health (DOH) published on May 15, 2025, the long-awaited electronic Material Transaction Notice Form (the Form), which replaces its prior email submission process with a portal filing for...more

Holland & Knight LLP

New York Budget Omits Changes to State's "Disclosure of Material Transactions" Law

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In a prior blog post, we summarized proposed legislation included in New York Gov. Kathy Hochul's state fiscal year (FY) 2025-2026 budget that would have subjected "material transactions" to additional disclosure and...more

Clark Hill PLC

Colorado Court of Appeals rules that claims under the Health Care Worker Protection Act are subject to the Colorado Governmental...

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On May 8, the Colorado Court of Appeals concluded that any claim that might be asserted under the Health Care Worker Protection Act (“HCWPA”), C.R.S § 8-2-123, is subject to the notice requirement in the Colorado Governmental...more

McDermott Will & Emery

Healthcare Regulatory Check-Up Newsletter | March 2025 Recap

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This issue of McDermott’s Healthcare Regulatory Check-Up highlights key regulatory and enforcement activity for March 2025. This month features: - Noteworthy enforcement actions demonstrating that the Anti-Kickback Statute...more

McDermott Will & Emery

Colorado SB 25-198 Would Expand Notice Requirements for Material Change Healthcare Transactions

On March 5, 2025, the Colorado state legislature introduced Senate Bill (SB) 25-198, aiming to expand Colorado’s licensed hospital notice requirements for material healthcare transactions and impose notification and...more

Rivkin Radler LLP

NYS Reinforces Its Scrutiny Over Healthcare Transactions

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We recently discussed increasing state regulation of healthcare mergers and acquisitions in the face of the current Administration’s clear policy of federal deregulation. We noted that 15 states had implemented oversight laws...more

Dorsey & Whitney LLP

Massachusetts Expands Healthcare Material Change Law, Adds Private Equity in Scope

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On January 8, 2025, the governor of Massachusetts signed into law H.5159, An Act enhancing the market review process (the “Act”). Among various other healthcare market oversight enhancements, the Act expands the authority of...more

Foley & Lardner LLP

Massachusetts “Patients First Act” Implementation and Enforcement Re-Extended

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The Massachusetts Senate proposed an amendment on Monday December 2, 2024, that would delay implementation and enforcement of the 2021 Patients First Act addressing health care cost transparency. Section 31 of the amendment...more

Husch Blackwell LLP

California Board of Pharmacy Proposes Amended Regulation Governing Pharmacy Business Discontinuations

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On November 15, 2024, the California Board of Pharmacy issued a public notice of its intent to modify Cal. Code Regs. tit. 16 § 1708.2, which governs the discontinuation of pharmacy businesses in California. The regulation...more

Holland & Hart LLP

Are You Ready for It? Section 1557's Upcoming Deadlines

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The Department of Health and Human Services (“HHS”) Office of Civil Rights (“OCR”) published its final rules implementing the anti-discrimination provisions under Section 1557 of the Affordable Care Act (“Final Rule”) on May...more

Bodman

The Rise of State-Required Health Care Transaction Notices

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Although they are currently still in the minority, a growing number of states are enacting or proposing legislation that requires applicable parties to provide notice of pending health care transactions....more

Arnall Golden Gregory LLP

California Bill Would Increase Scrutiny on Private Equity Healthcare Transactions

The California Legislature recently passed Assembly Bill 3129 (“AB 3129” or the “Bill”), which, if signed by California Governor Gavin Newsom, would increase oversight of healthcare entity transactions involving private...more

Proskauer - Health Care Law Brief

AB 3129 Passes California Legislature, Targeting Private Equity Health Care Transactions and Granting AG Consent Right

On August 31, 2024, the California State Assembly and State Senate passed Assembly Bill 3129 (“AB 3129”). If signed by Governor Newsom, AB 3129 would establish a comprehensive transaction review law that (i) targets private...more

Mintz - Health Care Viewpoints

California’s Health Care Transactions Review Law: Regulatory Revisions Effective Immediately

Effective immediately, on August 22, 2024, the Office of Health Care Affordability (OHCA) adopted revisions to the cost and market impact review (CMIR) regulations (Revised Regulations), which govern California’s pre-closing...more

Bass, Berry & Sims PLC

California Bill on Health Care System Consolidation Scheduled for Vote in Senate Health Committee

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Effective January 1, 2025, if enacted, California Assembly Bill 3129 (Bill) would grant sweeping power to the Attorney General by authorizing the Attorney General to approve, conditionally approve, or disapprove of certain...more

Sheppard Mullin Richter & Hampton LLP

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

ArentFox Schiff

OCR Finalizes HIPAA Privacy Rule to Support Reproductive Health Care Privacy

ArentFox Schiff on

On April 26, the US Department of Health and Human Services Office for Civil Rights (OCR) published a Final Rule that adds protections under the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule...more

Holland & Hart LLP

New ACA 1557 Non-Discrimination Rules: Checklist For Healthcare Providers

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On May 6, 2024, the Department of Health and Human Services (HHS) published its final rule revamping the non-discrimination regulations issued under § 1557 of the Affordable Care Act.  The revised rules apply to all...more

Nelson Mullins Riley & Scarborough LLP

What the FTC’s Rule Banning Non-Competes Means for Healthcare

The FTC unveiled its long-awaited final rule banning most non-compete agreements during a live broadcast of a Commission meeting on April 23, 2024. The proposed rule, which was first announced in January 2023, underwent an...more

Proskauer - Health Care Law Brief

California Considers New Restrictions as Health Care Notice Requirements Go Live for Transactions Closing on or After April 1

In August 2023, we published a blog post about the California Office of Health Care Access and Information’s (“OHCA”) proposed cost and market impact review (“CMIR”) regulations under the California Health Care Quality and...more

Mintz - Health Care Viewpoints

A Mintz Health Care Roundtable: Current Trends in State Health Care Transaction Review and What to Expect in 2024

States are increasingly exercising regulatory oversight of health care transactions by enacting laws requiring prior notice or approval of certain health care transactions. Currently, 15 states have enacted health care...more

Epstein Becker & Green

Indiana Senate Enrolled Act 9 Requires Written Notice of Health Care Entities’ Mergers or Acquisitions

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On March 13, 2024, Indiana Governor Eric J. Holcomb signed Senate Enrolled Act No. 9 (“SEA 9”) which will amend the Indiana Code with respect to notice of health care entity mergers and acquisitions....more

Mintz - Health Care Viewpoints

Indiana Joins States Focusing on Consolidation of Health Care

On March 13, 2024, Indiana joined the ranks of states exercising greater oversight and regulation of health care transactions.  Senate Enrolled Act No. 9 (S.B. 9), which takes effect on July 1, 2024, requires written notice...more

Epstein Becker & Green

Proposed CA Assembly Bill 3129: Notice & Consent for Private Equity, Hedge Funds Acquiring/Changing Control of Health Care...

Epstein Becker & Green on

As our December 2023 Insight noted, California’s SB 184 (enacted in June 2022) and accompanying regulations contain pre-transaction notice requirements by “specified health care entities” for certain “material change...more

Quarles & Brady LLP

Indiana Lawmakers Continue to Take Aim at Health Care Organization Mergers

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On February 27, 2024, the Indiana House of Representatives (“House”) voted to pass legislation that would call for increased scrutiny regarding mergers between health care organizations. More specifically, the implementation...more

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