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Haynes Boone’s Real Estate Practice Group is excited to introduce the summer edition of HB Real Estate Insights. We hope you enjoy this read....more
In our February 14, 2025 blog post, we detailed a proposed expansion of Article 45-A of New York’s Public Health Law (hereinafter, the Disclosure of Material Transactions Law) included in the proposed Fiscal Year 2026 New...more
On May 15, 2025, the New York State Department of Health (“DOH”) announced the launch of the electronic Material Transaction Reporting Form for health care transactions (“Electronic Form”). To assist reporting entities in...more
Just last week, we reported that the 2025/26 NYS Budget Bill did not include a provision that would have increased the requirements for seeking Department of Health (DOH) approval of a material healthcare transaction (which...more
Under the Material Transactions Law, certain health care entities involved in a transaction that increases gross, in-state revenue to at least $25 million must provide written notice of the transaction to the New York State...more
We recently wrote about proposed legislation that would have substantially increased the existing reporting requirements for material healthcare transactions in NYS that have existed since Public Health Law (PHL) Article 45-A...more
On May 9, 2025, New York State (“NYS”) Governor Kathy Hochul signed legislation enacting the State Fiscal Year 2025-26 budget into law. Notably omitted from the final budget legislation was Part S of the Health and Mental...more
The first quarter of 2025 has been eventful for New York’s Disclosure of Material Transactions Law. As discussed in our recent blog post, the proposed Fiscal Year 2026 New York State Executive Budget (FY 26 Executive Budget)...more
Nearly two years ago, and as previously discussed in a Proskauer alert, New York enacted Public Health Law Article 45-A (the “Material Transactions Law”), which requires reporting of certain material health care transactions....more
On August 1, 2023, the New York State’s Department of Health (the “DOH”) began implementation of Public Health Law Article 45-A, the State’s new statutory requirement for advance notice and public disclosure of certain...more
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
Earlier this month, the New York State Department of Health (DOH) released its first formal guidance under Public Health Law (PHL) Article 45-A, the state’s recently enacted healthcare transaction notice law. Issued in the...more
This month, nearly two years after the passage of New York’s health care transaction law, N.Y. Pub. Health Law § 4550 et seq. (described in our previous Alert), the New York State Department of Health (“DOH”) released...more
On October 31, 2023, the New York State Department of Financial Services (DFS) released a notice withdrawing its proposed market conduct rules for pharmacy benefit managers (PBMs). The proposed rules, announced August 16,...more
Starting January 1, 2024, healthcare facilities and provider organizations engaging in certain transactions in Illinois, such as mergers and acquisitions, will have new reporting requirements. Illinois recently joined a...more
Noncompete agreements are under siege, facing attacks on the state and federal fronts. This is vividly illustrated by what's happening within the Federal Trade Commission and the New York State Legislature. In the...more
The 2023-2024 New York State budget has enacted significant new mandatory disclosure and notice laws for certain transactions involving physician practices and other health care organizations. This new law – Article 45-A of...more
The proposed FY 2024 New York State Executive Budget announced by Governor Kathy Hochul on February 1, 2023, includes a new requirement to seek approval from the New York Department of Health (DOH) for acquisitions and...more
The concept of “control” of insurers received significant attention from state insurance regulators last year and will receive even more in 2023. We wrote a brief report in April 2022 following the New York Department of...more
A recent post on Foley Hoag’s State AG blog about New York’s proposed pre-merger notification legislation details the potential new notification requirement, but we wanted to dive a little deeper into the impact the proposed...more