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.

• New York: Governor Hochul’s proposed legislation package (A10007 / S09007) would significantly expand New York state authorities’ ability to review healthcare transactions, increasing the length and cost of review for transacting parties. The bill would transform’s New York’s notice-only regime and grant the Department of Health power to conduct Cost and Market Impact Reviews (CMIRs), which could delay transaction closings by up to 180 days. As in other states, the DOH would conduct a preliminary review of all proposed transactions and determine whether a CMIR is warranted. The bill would also impose new reporting requirements on parties to material transactions to provide information on the impact of the transaction on cost, quality, access, equity, and competition on the five-year anniversary of closing.
• Washington: H.B. 2548 expands the scope of Washington’s current notification regime to include additional types of healthcare transactions. Previously, only transactions between two provider organizations, hospitals, or hospital systems were reportable. Under the new bill, any change of control of these entities or a majority of their assets (e.g., through a real estate leaseback), regardless of buyer’s identity, could be subject to a notification. The bill also allows the state attorney general to request additional information from the parties, tolling the 60-day waiting period. Together, these changes will mean that more parties, including private equity firms, will be subject to filings, which will now take longer to review. HB2548 passed the Washington House and is under consideration in the state Senate.

^[1] List current as of 2/26/26. Note that this page may not include all regulatory developments.

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