On May 15, 2026, the California Office of Health Care Affordability (OHCA) released proposed regulations implementing Assembly Bill (AB) 1415 which took effect on January 1, 2026 (see our prior posts here and here). The new legislation expands the state’s health care material change transaction notice (MCN) process and requires private equity groups, hedge funds, management services organizations (MSOs), and certain newly created entities to give OHCA direct notice of proposed material change transactions involving a health care entity. Before formal rulemaking, OHCA issued Frequently Asked Questions providing high-level guidance for AB 1415 implementation, leaving many operational details for the proposed and final regulations. The proposed regulations were presented at OHCA’s Health Care Affordability Board meeting on May 27, 2026, and will remain open for informal public comment at [email protected] through June 11, 2026. In July 2026, the proposed regulations will be submitted for emergency rulemaking with a formal five day public comment period prior to an August 2026 effective date. Below is a summary of the key changes.

On April 13, 2026, Maine enacted two significant pieces of legislation affecting health care transactions. Chapter 661 (H.P. 1481), effective July 14, 2026, requires health care entities with a threshold presence in Maine to file copies of any premerger notifications required under the Hart-Scott-Rodino (HSR) Act with the Maine Attorney General (Premerger Notification Law). Chapter 690 (H.P. 1480), effective January 1, 2027, establishes a framework for reviewing “material change transactions” involving the acquisition of health care entities by private equity companies, hedge funds, or certain management services organizations (Material Transactions Review Law). 

While federal and state legislators contemplate the next wave of PBM and drug pricing reform, legislatures in Virginia and Ohio have already sent significant legislation addressing prescription drug pricing and pharmacy benefit manager oversight to their respective governors in early 2026. 

Washington’s Governor signed House Bill 2548 (Chapter 222, Laws of 2026) into law on March 25, 2026, to take effect June 11, 2026, to amend the state’s health care transaction review law at Chapter 19.390. The current law requires pre-transaction notice for certain material transactions involving hospitals, hospital systems, or provider organizations.