Proposed State Healthcare Transaction Notification Laws

The following states have proposed, but not passed, additional state healthcare transaction notification laws.^[1] We are continuing to track these bills and will provide updates if any of these bills are enacted into law.

• California:
  • S.B. 25 would require any person making a transaction notification filing pursuant to the Hart-Scott-Rodino Act (including healthcare and private equity firms) to also file a copy of the form with the Attorney General. The additional filing would only be required if the filing person has (1) its principal place of business in California or (2) annual net sales in California for the goods or services involved in the transaction of at least 20 percent of the minimum HSR filing threshold (which is currently $126.4 million).
  • A.B. 1415 would expand the notice regime administered by the state’s Office of Health Care Affordability (“OHCA”) to require filings for transactions involving MSOs. The proposal would also extend the transaction reporting obligation, which currently applies to healthcare entities, to private equity firms and hedge funds.
• Massachusetts: S.D. 1910 (S.868) would prohibit private equity firms from engaging in transactions that are likely to cause financial distress to a healthcare provider due to debt placement. In addition, the legislation would create requirements for how private equity firms direct healthcare providers to pay fees and issue dividends, while also requiring private equity firms to deposit a bond with the Department of Health.
• Pennsylvania: HB1460 would requires parties notify the [] of transactions involving health care facilities, including hospitals, ambulatory surgery centers, and long term nursing facilities, and private equity investors or for-profit entities to the Pennsylvania Attorney General at least 60 days prior to closing. The Attorney General has 30 days after notification to request additional information and may extend the waiting period for an additional 30 days.

^[1] List current as of 9/1/25. Note that this page may not include all regulatory developments.

This informational piece, which may be considered advertising under the ethical rules of certain jurisdictions, is provided on the understanding that it does not constitute the rendering of legal advice or other professional advice by Goodwin or its lawyers. Prior results do not guarantee similar outcomes.