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.
• Connecticut:
  • GB 6873 would require parties to give 60 days notification to the Connecticut Attorney General for transactions involving health care entities, including providers, provider practices, MSOs, PBMs, health care facilities, and insurers with total revenues / assets of more than $10 million. Certain transactions involving private equity firms are also reportable.
  • S.B. 261 would impose restrictions on private equity firms buying, operating, or holding a controlling interest in hospitals, including by limiting the ability of such firms to lease property back to the hospital for a fee after purchasing the land rights.
  • S.B. 567 would expand the authority of the Attorney General and Commissioner of Health Strategy to regulate private equity ownership of hospitals, radiology groups, and drug rehabilitation facilities. Further, the law would restrict “self-dealing property transactions.”
  • S.B. 469 would restrict private equity firms from acquiring hospitals, prohibit hospitals from entering real estate investment trust (“REIT”) transactions, and establish physician-led ownership requirements for certain medical groups and centers.
  • S.B. 837 would require group practices to submit information about intended acquisitions or mergers to the Commissioner of Health Strategy, repeal the presumption in favor of approving certificate-of-need applications for large group practice ownership transfers, and mandate the Health Care Cabinet to develop legislative recommendations to increase oversight of group practice mergers and acquisitions.
  • H.B. 6570 would prohibit private equity firms from acquiring ownership or control of healthcare provider practices or facilities and would require healthcare administrators to disclose ownership structures and significant changes in such structures to the Health Systems Planning Unit. The Attorney General would be authorized to enforce these provisions.
  • S.B. 1507 would prohibit any transaction effecting new or increased private equity or REIT ownership of hospitals, health systems, or group practices. It would also prohibit healthcare facilities and MSOs from engaging in certain activities that interfere with or control the professional judgment or clinical decisions of Licensed Clinicians.
• Illinois: S.B. 1998 would update the state’s current Mini-HSR Law to require private equity firms and hedge funds to obtain consent from the Attorney General if they provide financing for certain covered healthcare transactions.
• Indiana: H.B. 1666 would require private equity firms acquiring a healthcare facility, regardless of the total assets at issue, to submit a 90-day pre-closing notice. Under a new consent requirement, the Attorney General would have 45 days to approve or deny the transaction. Further, healthcare entities, including hospitals, insurers, and pharmacy benefits managers, would be required to file annual ownership structure reports.
• 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.
• Minnesota: SF 3354 would prohibit PE firms or REITs from acquiring or increasing ownership interest in providers.
• New Mexico: S.B. 14 would require private equity transactions involving certain healthcare entities to provide a pre-closing notice to the Office of Superintendent of Insurance (“OSI”) no later than 60 days prior to the proposed date. The OSI would be authorized to require a cost and market impact review, in which case parties would need to obtain OSI approval with or without conditions.
• Texas:
  • HB2747 / SB1595 would require 90 days notice be given to the Texas Attorney General for material change transactions involving a health care entity, which includes healthcare providers, facilities, provider organizations, PBMs and health carriers.
  • H.B. 985 would require a hospital that acquires an outpatient healthcare facility to provide written notice to the Attorney General and to the Health and Human Services Commission.
• Vermont: H.B. 71 would require healthcare entities to notify the Green Mountain Care Board at least 180 days prior to entering into Material Change Transactions. The Board, in consultation with the Attorney General, would have 30 days to review the transaction and approve, approve with conditions, or disapprove. A comprehensive review could also be initiated, which would extend the review process by 90 days.
• Washington:
  • S.B. 5561 would require healthcare entities to annually disclose information on entities with a controlling interest or ownership stake in healthcare providers, including financial and organizational information. The information would form a public interactive tool displaying changes in ownership or control, organization structures, and trends in consolidation.
  • H.B. 1072 would require healthcare entities that provide protected healthcare services, such as reproductive services, death with dignity services, and gender-affirming care, to notify the Department of Health at least 60 days prior to entering into a transaction. The Department would have 60 days to review and issue a final determination; otherwise, the transaction would be considered approved.
• Wisconsin: AB-50 would require health care entities (to be defined by the Wisconsin Department of Health Services (DHS)) to report material change transaction and allows DHS to approve or disapprove transactions. Limited details are included in the bill proposal.

^[1] List current as of 5/12/25. 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.