Lexology December 28, 2023
California’s new Office of Health Care Affordability (OHCA) is set to start pre-closing regulatory review of certain health care transactions on January 1, 2024. As further explained in our previous post, subject to certain exceptions, a broad range of health care entities (collectively, Health Care Entities) soon will be subject to potential pre-closing transaction review. On December 8, 2023, OHCA submitted its cost and market impact review (CMIR) notice and review process regulations to the California Office of Administrative Law (OAL) for approval. The regulations submitted by OHCA are available here. On December 18, 2023, the OAL published the final emergency regulations, containing several notable changes to the regulations submitted by OHCA for approval. The final regulations (CMIR Regulations), which...