Lexology June 22, 2023
Hogan Lovells

The New York legislature recently enacted new reporting requirements that will affect health care transactions across the state. Effective August 1, 2023, certain “material” mergers, acquisitions, affiliation agreements, and joint ventures involving “health care entities” must be reported to the New York Department of Health (NY DOH) at least thirty days prior to closing. NY DOH will also collect deal documents and other information and solicit public comment on summaries of these transactions. While NY DOH need not approve reported transactions (a notable change from an earlier version of the legislation), these new requirements may invite increased regulatory and public scrutiny, especially for management services organizations (MSOs) that support physician practices.

Transactions subject to the new reporting requirements

The new...

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