About

Jacquelyn R. Daniel is an associate in the Corporate Department and a member of the Heath Care Group. Jacquelyn earned her B.A. in political science…

Jacquelyn R. Daniel is an associate in the Corporate Department and a member of the Heath Care Group. Jacquelyn earned her B.A. in political science from the University of California Berkeley in 2015, and her J.D. from Boston College Law School in 2022. Before law school, Jacquelyn spent several years working in biomedical research administration at a premier Harvard teaching hospital in Boston, MA. During law school, Jacquelyn focused her studies and clinical practice on corporate law and health law. She also interned in-house for two large health care providers headquartered in the Boston area.

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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 Affordability Act (“Proposed Regulations”). The final CMIR regulations implementing the notice requirements for large health care transactions in California (“Final Regulations”) were approved on December 18, 2023. As enacted, all health care entities that meet certain threshold requirements and are a party to a “material change transaction” expected to close on or after April 1, 2024, must provide at least 90 days’ advance notice to OHCA. OHCA began accepting notices as of January 1.

Continuing the trend towards greater scrutiny of health care transactions, on February 16, the California Assembly introduced a new bill, AB-3129, which would subject private equity groups and hedge funds to a 90-day notice and consent requirement for change of control transactions or acquisitions of health care facilities or provider groups that are expected to close on or after January 1, 2025. While the Final Regulations are intended to promote competition in the health care sector, the stated purpose of AB‑3129 is to improve the quality and lower the cost of health care.

This blog discusses the scope of the Final Regulations and what to look out for as AB-3129 makes its way through the California legislative process. 

About

Jacquelyn R. Daniel is an associate in the Corporate Department and a member of the Heath Care Group. Jacquelyn earned her B.A. in political science…

Jacquelyn R. Daniel is an associate in the Corporate Department and a member of the Heath Care Group. Jacquelyn earned her B.A. in political science from the University of California Berkeley in 2015, and her J.D. from Boston College Law School in 2022. Before law school, Jacquelyn spent several years working in biomedical research administration at a premier Harvard teaching hospital in Boston, MA. During law school, Jacquelyn focused her studies and clinical practice on corporate law and health law. She also interned in-house for two large health care providers headquartered in the Boston area.

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