On June 9, 2025, Oregon Governor Tina Kotek signed into law Senate Bill 951 (the “2025 Act”).  Unlike California’s AB 3129, which was vetoed by California Governor Gavin Newsom in September 2024, the passage of the 2025 Act is the culmination of the state’s efforts to strengthen controls on health care transactions involving management services organizations (“MSOs”) and private equity investors.  The 2025 Act implements significant changes to Oregon’s existing corporate practice of medicine (“CPOM”) doctrine and materially affects existing arrangements between MSOs and the professional medical entities that they manage.  Significantly, the 2025 Act prohibits several material aspects of health care transactions that are standard in states that restrict CPOM. Continue Reading New Oregon Law Imposes Significant Corporate Practice of Medicine Restrictions

On September 28, 2024, California governor Gavin Newsom vetoed AB 3129, a bill that, among other things, would have required private equity firms and hedge funds to provide 90 days’ prior written notice to, and for some transactions, obtain consent from, the state attorney general prior to proceeding with certain health care transactions.

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Private equity investments in health care to be subject to increased oversight from federal and state regulators, including antitrust officials

Federal and state governmental regulation of health care transactions continues to increase rapidly.  At the federal level, there is increased focus on the role of private equity in health care and the perceived impact on access to care, quality of care and pricing.  At the same time, a growing number of states have passed and continue to propose legislation that increases state oversight of health care transactions.  As a result of this increase in regulatory scrutiny from federal and state regulators, parties interested in conducting health care transactions must consider various regulatory requirements and the factors regulators take into account when analyzing proposed health care transactions. Continue Reading Health Care Transactions Facing Increased Federal and State Regulatory Scrutiny