State Healthcare Transaction Laws
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This interactive map tracks state healthcare transaction laws across the country, including broad-scope pre-merger notification requirements – commonly known as mini HSRs – and healthcare-specific transaction review regimes. States are coded to reflect where legislation has been enacted (broad-scope mini HSR, healthcare transaction law, or both), where legislation is pending, or where no current or pending applicable law exists. Our team updates this map regularly as the legislative landscape continues to evolve. Click each state for more information, and contact our healthcare and antitrust teams with questions about your transaction.
Enacted healthcare-specific transaction law
Enacted broad-scope mini HSR regime
Both enacted
Pending or proposed legislation only
No current, pending, or proposed transaction law
Status
Enacted
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Healthcare Transaction Notice and Review
Type
Parties to mergers, acquisitions, or contracting affiliations between hospitals, hospital systems, and provider organizations (physician organizations, physician-hospital organizations, independent practice associations, provider networks, and accountable care organizations representing seven or more providers).
Applies only if the parties lacked prior common ownership or contracting affiliation.
H.B. 2548 expands coverage to any change of ownership or control of a hospital, hospital system, or provider organization, and significant asset transactions, including real property sale-leasebacks. Expanding the scope of transactions covered will subject new entities, such as private equity firms and individual investors, to filing requirements.
Who is Covered
Out-of-state entities: notice required only if generating $10 million or more in Washington patient revenue. No revenue or asset threshold for in-state entities; the obligation turns on transaction type.
Washington added a filing fee to its healthcare material change transaction filing requirements. The fee varies based on the value of the transaction.
The filing fee is $2,500-$25,000 depending on the value of the transaction.
Thresholds
Where to File
Wash. Rev. Code Ch. 19.390
SB 5122.SL (HSR copy requirement)
H.B. 2548 (expanded transaction types)
Sources
Written notice to the Attorney General (“AG”) at least 60 days pre-closing. AG must request additional information within 30 days. The statute does not preclude later AG investigation or antitrust enforcement.
Providers and provider organizations must also file a copy of any federal HSR filing with the AG contemporaneously, which satisfies the notice requirement under RCW 19.390.040.
Timing
Enacted
Status
Healthcare Transaction Notice and Review
Type
Health care entities in material change transactions meeting revenue/asset thresholds below (includes providers, payers, integrated health systems).
AB-1415 extends coverage to private equity groups, hedge funds, and management services organizations.
Who is Covered
Filing required if any party has:
Annual California revenue or assets of at least $25 million; or
Annual California revenue or assets of at least $10 million, where the counterparty meets the $25 million threshold; or
A location in a designated primary care health professional shortage area in California.
A material change transaction includes one involving:
Fair market value of $25 million or more;
A likely increase in annual California revenue of $10 million or more, or 20% or more; or
A transfer of 25% or more of total California assets, or a transfer of control.
Thresholds
90-day pre-closing notice required.
Following notice, California’s Office of Health Care Affordability (“OHCA”) either:
Waives a Cost and Market Impact Review (“CMIR”) within 45 days; or
Notifies parties of its decision to conduct a CMIR within 60 days.
CMIR must be completed within 90 days of that decision, extendable by 30 days.
Total review may exceed eight months.
Timing
https://ohca-mcn.hcai.ca.gov/
Where to File
Cal. Health & Saf. Code Section 127500 et seq.
22 CCR 97431 et seq.
AB-1415; Cal. Health & Saf. Code Sections 127500.2, 127501, 127501.5, 127507
Sources
California
Premerger Notification Law
Material Healthcare Transactions
CLOSE
Enacted
Status
Healthcare Transaction Notice and Review
Type
Attorney General (“AG”) Notice (Nev. Rev. Stat. Section 598A.290 et seq.):
Any person doing business in Nevada party to a transaction resulting in a material change to a group practice or health carrier that would cause it to provide 50% or more of any health care or health carrier service in a geographic market. Excludes transactions between commonly owned entities or those with a pre-existing contracting relationship established before October 1, 2021.
DHHS Notice (Nev. Rev. Stat. Section 439A.126):
Changes of ownership of a hospital or physician group practice.
Who is Covered
AG Notice: Reportable if the transaction would cause a group practice or health carrier to provide 50% or more of any service in a geographic market. Material changes include mergers, consolidations, affiliations, acquisitions of all or substantially all assets or equity, employment of all or substantially all practitioners, and acquisitions of insolvent group practices.
Department of Health and Human Services (“DHHS”) Notice: Triggered by a change of ownership of a hospital or physician group practice.
Thresholds
AG Notice: At least 30 days pre-closing. If a Hart-Scott-Rodino (“HSR”) filing involves Nevada group practice or health carrier assets, simultaneous AG submission satisfies this requirement.
DHHS Notice: Within 60 days post-closing.
Timing
AG Notice: Nevada Attorney General.
DHHS Notice: Nevada DHHS.
Where to File
Nev. Rev. Stat. Section 598A.290 et seq. (AG notice; definitions at Sections 598A.300–598A.380; penalty at Section 598A.430)
Nev. Rev. Stat. Section 439A.126 (DHHS notice)
Sources
Nevada
Premerger Notification Law
Material Healthcare Transactions
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Enacted
Status
Healthcare Transaction Notice and Review
Type
Health care entities in material change transactions, including: licensed or certified health professionals; hospitals and hospital systems; carriers offering Oregon health benefit plans; Medicare Advantage plans; coordinated care organizations; prepaid managed care organizations; and any entity primarily providing health care items or services, or a parent or closely related entity. Long-term care facilities and those licensed under ORS 443.400-443.455 are excluded.
Who is Covered
Material change transaction: at least one party averaged $25 million or more in revenue over the prior three fiscal years, and another averaged at least $10 million (or, for a new entity, is projected to reach $10 million in its first full year).
For out-of-state entities, also met if the transaction may increase Oregon health care prices or limit access to services.
Excluded: clinical affiliations for trials or graduate medical education; medical services contracts or extensions; affiliations necessary for value-based payment that do not affect corporate leadership, governance, or control; and transactions involving federally qualified health centers unless the entity would lose that status.
Thresholds
Notice to the Oregon Health Authority (“OHA”) at least 180 days pre-closing. Upon receipt of a complete notice, OHA conducts a 30-day preliminary review for potential negative impact on affordable health care access. Then:
OHA (or the Department of Consumer and Business Services (“DCBS”) for domestic health insurer transactions) approves, or approves with conditions, if the transaction is urgently necessary for solvency and in consumers’ interest, or lacks potential to negatively impact affordable health care access; or
OHA conducts a comprehensive review, completed within 180 days of notice receipt (extendable by agreement).
OHA monitors condition compliance and analyzes cost and market impact at one, two, and five years post-closing.
Timing
Where to File
Or. Rev. Stat. Section 415.500 et seq.
Or. Admin. R. 409-070-0000 through -0085
Or. Rev. Stat. Section 415.900 (civil penalties)
Or. Rev. Stat. Section 415.512 (fees)
Sources
Oregon
https://ag.nv.gov/Hot_Topics/HSR_and_30-Day_Advanced_Notice_for_Health_Care_and_Health_Carrier_Transactions/
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https://www.oregon.gov/oha/HPA/HP/Pages/HCMO-How-To-Submit.aspx
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https://www.atg.wa.gov/premerger-notifications
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Healthcare Transaction Law
Mini HSR Law
Enacted; applies to covered premerger notifications filed on or after January 1, 2027
Status
Antitrust Premerger Notice (Mini HSR)
Type
Any person filing a Hart-Scott-Rodino (“HSR”) notification with the FTC and DOJ that:
has its principal place of business in the state; or
directly or indirectly has annual net sales in/from/into the state of the goods or services involved in the transaction equal to at least 20% of the federal HSR filing threshold.
Who is Covered
Triggered only if an HSR filing is required at the federal level AND
The party’s principal place of business is in the state; OR
The party has annual sales in/from/into the state of the goods or services involved in the transaction equal to at least 20% of the HSR size-of-transaction threshold.
Thresholds
Filing must be made contemporaneously with the federal HSR filing—no later than 1 business day after the HSR filing.
No separate waiting period is imposed at the state level. Parties remain subject only to applicable federal HSR waiting period.
Timing
California Attorney General (portal TBD)
1.
Where to File
SB 25 (signed February 10, 2026; effective January 1, 2027)
Cal. Bus. & Prof. Code Section 16900 et seq. (as enacted by SB 25)
Sources
Healthcare Transaction Law
Mini HSR Law
Healthcare Transaction Law
Healthcare Transaction Law
Mini HSR Law
Mini HSR Law
Enacted
Status
Antitrust Premerger Notice (Mini HSR)
Type
Any person filing a Hart-Scott-Rodino (“HSR”) notification with the FTC and DOJ that:
has its principal place of business in the state; or
directly or indirectly has annual net sales in/from/into the state of the goods or services involved in the transaction equal to at least 20% of the federal HSR filing threshold; or
is a provider or provider organization, as defined in RCW 19.390.020, conducting business in Washington (broadly defined to include many healthcare professionals and organizations).
Who is Covered
Triggered only if an HSR filing is required at the federal level AND
The party’s principal place of business is in the state; OR
The party has annual sales in/from/into the state of the goods or services involved in the transaction equal to at least 20% of the HSR size-of-transaction threshold; OR
The party is a provider or provider organization, as defined in RCW 19.390.020, conducting business in Washington.
Thresholds
Filing must be made contemporaneously with the federal HSR filing.
No separate waiting period is imposed at the state level. Parties remain subject only to applicable federal HSR waiting period.
Timing
https://www.atg.wa.gov/premerger-notifications
1.
Where to File
Sources
Wash. Rev. Code Ch. 19.420
S.B. 5122
Premerger Notification Law
Material Healthcare Transactions
CLOSE
Enacted
Status
Healthcare Transaction Notice and Review
Type
Parties: Health care providers and provider organizations with at least $25 million in revenue involved in a material change transaction (as defined in 958 CMR 7.00 and the enabling statute).
Regulators: Massachusetts Health Policy Commission (HPC)/Office of the Massachusetts Attorney General (MAAG).
Who is Covered
Trigger: Submission is required when a transaction or event meets the definition of a “material change” under 958 CMR 7.00.
Revenue: A filing is only required if a $25 million revenue threshold is met.
Thresholds
Advance notice required: A Notice of Material Change must be provided at least 60 days pre-closing, consistent with the regulation’s timing requirements.
Review: HPC has 30 days to review the Notice. It can then either start a cost and market impact review (CMIR) or decline to issue a CMIR. If HPC initiates a CMIR, it could delay closing up to 215 days from the date of the Notice.
Timing
HPC: https://masshpc.gov/moat/mcn-cmir
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Where to File
958 CMR 7.00, Notices of Material Change and Cost and Market Impact Reviews (Massachusetts Health Policy Commission), available at: https://www.mass.gov/doc/958-cmr-7-notices-of-material-change-and-cost-and-market-impact-reviews/download
Material Change Notices and Cost and Market Impact Reviews, Massachusetts Health Policy Commission, available at https://masshpc.gov/moat/mcn-cmir
Sources
Massachusetts
Premerger Notification Law
Material Healthcare Transactions
CLOSE
Enacted
Status
Healthcare Transaction Notice and Review
Type
Who is Covered
Medical Groups Trigger: Notice is required when a transaction constitutes a material change as defined in 110-RICR-30-00-5.
Hospitals Trigger: Must seek approval for any transaction concerning the sale or transfer of 20% or more of any ownership interests or assets of a hospital.
Thresholds
Medical Groups – advance notice required: Notice must be provided at least 60 days pre-closing to the RIAG.
Medical Groups – review: The Rhode Island rule does not empower the RIAG to delay the proposed transaction beyond the means already available to the office—namely its ability to bring actions to stop an anticompetitive behavior. The rule itself is a notice requirement only.
Hospitals – notice and review: Notice must be provided to both the RIAG and RIDOH before closing a transaction and the transaction cannot close until the state has approved the transaction. Review and approval can take several months.
Timing
Medical Groups Method: See the filing instructions in the Notice form available at https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8&ved=2ahUKEwi4ppm68sqUAxVx3skDHbrnFBoQFnoECBEQAQ&url=https%3A%2F%2Friag.ri.gov%2Fmedia%2F8211%2Fdownload&usg=AOvVaw2XnPuRzQq3q1n-xZX0wAO0&opi=89978449
Hospitals Method: See information available at https://health.ri.gov/hospitals/hospital-conversions-mergers-program
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Where to File
958 CMR 7.00, Notices of Material Change and Cost and Market Impact Reviews (Massachusetts Health Policy Commission), available at: https://www.mass.gov/doc/958-cmr-7-notices-of-material-change-and-cost-and-market-impact-reviews/download
Material Change Notices and Cost and Market Impact Reviews, Massachusetts Health Policy Commission, available at https://masshpc.gov/moat/mcn-cmir
Sources
Rhode Island
Rhode Island has two distinct healthcare transaction notification regimes—one that applies to medical groups and another that applies to hospitals.
Medical Groups: A recently enacted rule applies to Rhode Island based medical-practice groups undertaking any merger, consolidation, or acquisition that would result in (1) ownership or control by a significant equity investor (defined to include private equity companies), (2) a group of eight (8) or more physicians, physician assistants, and/or nurse practitioners, or (3) any formation of a management services organization or similar entity created to administer contracts with health insurance carriers or third-party administrators on behalf of a medical-practice group. See 110-RICR-30-00-5.
Hospitals: Certain transfers in ownership, assets, membership interests, authority or control of a hospital in Rhode Island require approval by both the Department of Health (RIDOH) and the Rhode Island Department of the Attorney General (RIAG) under the authority of the Hospital Conversions Act (Chapter 23-17.14).
Regulators: RIAG; RIDOH
Premerger Notification Law
Material Healthcare Transactions
CLOSE
Enacted
Status
Healthcare Transaction Notice and Review
Type
Parties: Vermont’s healthcare transaction notice law applies to hospitals and medical practices with one or more physicians that are acquiring medical practices. See 18 V.S.A. § 9405(c).
Regulators: Vermont Attorney General (VTAG).
Who is Covered
Trigger: Notice is required when there is to be any purchase or transfer through which a Vermont hospital or medical practice will take over ownership or control of a medical practice.
Thresholds
Advance notice required: A notice of the proposed acquisition must be provided at least 90 days pre-closing to the VTAG. The Vermont regime does not impose any waiting period—it only requires notice.
Timing
Contact and submit a notice to the VTAG.
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Where to File
18 V.S.A. § 9405(c), available at: https://legislature.vermont.gov/statutes/section/18/221/09405c
Sources
Vermont
Enacted
Status
Antitrust Premerger Notice (Mini HSR)
Type
Any person filing a Hart-Scott-Rodino (“HSR”) notification with the FTC and DOJ that:
has its principal place of business in the state; or
directly or indirectly has annual net sales in/from/into the state of the goods or services involved in the transaction equal to at least 20% of the federal HSR filing threshold.
Who is Covered
Triggered only if an HSR filing is required at the federal level AND
The party’s principal place of business is in the state; OR
The party has annual sales in/from/into the state of the goods or services involved in the transaction equal to at least 20% of the HSR size-of-transaction threshold.
Thresholds
Filing must be made contemporaneously with the federal HSR filing.
No separate waiting period is imposed at the state level. Parties remain subject only to applicable federal HSR waiting period.
Timing
Uniform Antitrust Pre-Merger Notification Act - Colorado Attorney General | Colorado Attorney General
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Where to File
SB25-126, Uniform Antitrust Pre-Merger Notification Act
Uniform Antitrust Pre-Merger Notification Act - Colorado Attorney General | Colorado Attorney General
Sources
Enacted; Hospital-focused. Broader healthcare transaction review legislation has been proposed
Status
Hospital/Healthcare Entity Transaction Notice and Review
Type
Colorado “health care entities” under the Colorado Hospital Transfer Act, generally licensed/certified hospitals and similar facilities, excluding entities wholly owned/operated by a governmental unit or agency. This can include hospitals, freestanding emergency departments, ambulatory surgical centers, psychiatric hospitals, nursing care facilities, hospice, assisted living residences, dialysis clinics, community clinics, rehabilitation hospitals, home care agencies, and similar facilities.
Who is Covered
There is no annual revenue, transaction value, or market share threshold.
Notice applies to covered transactions including: sale, transfer, lease, exchange, or disposition of 50% or more of the fair market value of the assets of a health care entity; a series of transactions over five years resulting in transfer of 50% or more of assets; or sale, transfer, or disposition of control of a parent/holding/company controlling a health care entity.
Thresholds
60 days pre-closing notice to the Colorado Attorney General.
For nonprofit-to-for-profit transactions, the AG may extend review by 90 days for good cause.
Timing
Colorado Attorney General
1.
Where to File
Colo. Rev. Stat. § 6-19-101 et seq
SB25-198 was introduced to broaden notice/review for “medical care entities” but failed.
Sources
CLOSE
Colorado
Healthcare Transaction Law
Healthcare Transaction Law
Mini HSR Law
Mini HSR Law
The statute gives the AG review time but does not create a separate transaction-blocking approval regime beyond existing Colorado antitrust authority.
AG may seek TRO/injunction for noncompliance.
Review / Enforcement
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2.
Civil penalties of up to $10,000 per day for failure to comply.
Filings are confidential and exempt from public disclosure, subject to statutory exceptions.
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Enforcement
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Enacted
Status
Healthcare Transaction Notice and Review
Type
Hospitals licensed by the New Mexico Health Care Authority, excluding state university teaching hospitals and state-owned special hospitals.
Certain health care provider organizations, including organizations delivering or managing health care services, physician organizations, PHOs, IPAs, provider networks, ACOs, DSOs, and similar organizations that contract with insurers.
Who is Covered
Thresholds
Timing
HCA may approve, approve with conditions, or disapprove.
HCA considers access, quality, cost, market share, barriers to entry, patient costs, networks, health outcomes, and workforce effects.
Covered transactions cannot be effectuated without written determination that no review is needed or written approval. Fines may be up to $5,000 per violation, or $10,000 for willful/intentional violations.
Review / Enforcement
HCA, which shares materials with the Office of Superintendent of Insurance and the Attorney General.
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Where to File
NMSA 1978 §§ 24A-9-1 through 24A-9-13
HB 586 / Health Care Consolidation Oversight Act amendments
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Sources
CLOSE
New Mexico
No revenue threshold.
Covered “transactions” include:
merger of a New Mexico hospital with another hospital or person controlling a hospital;
acquisition of one or more hospitals or a person controlling a New Mexico hospital;
affiliation, contract, or agreement resulting in change of hospital control, including with an MSO or insurer;
formation of a new entity/MSO resulting in change of control of an existing New Mexico hospital;
sale, mortgage, purchase, lease, new affiliation, or other agreement changing control of a hospital or hospital real estate; and
acquisition of one or more independent health care practices by a provider organization owned or affiliated with a health insurer.
Control is presumed at 15% or more voting power/proxies, rebuttable.
Notice must be submitted before the transaction can close. There is no set number of days before closing that a filing must be made.
New Mexico’s Health Care Authority (“HCA”) has 30 days to determine completeness or request missing information.
HCA review must be completed within 120 days of complete notice, unless parties agree to extend.
Enacted
Status
Healthcare Transaction Notice, Reporting, Review, and Antitrust/Public-interest Oversight
Type
Health care entities including hospitals, hospital systems, captive professional entities, medical foundations, health care provider group practices, entities organized or controlled by those entities, and entities that own or control them.
Who is Covered
Large transactions: Minn. Stat. § 145D.01 applies where a health care entity has average annual revenue of at least $80 million, or the resulting entity is projected to have at least $80 million in average annual revenue.
Smaller reportable transactions: Minn. Stat. § 145D.02 applies where the relevant entity has average annual revenue between $10 million and $80 million, or the resulting entity is projected to fall in that range.
Thresholds
Large transactions: 60 days pre-closing notice to the Minnesota Attorney General (“AG”) and the Commissioner of Health (“Commissioner”). AG may extend the waiting period by up to 90 additional days.
$10M–$80M transactions: report to Minnesota Department of Health (“MDH”) 30 days pre-closing, or within 10 business days after parties first reasonably anticipate entering into the transaction if closing is less than 30 days away.
Timing
Minnesota prohibits transactions that substantially lessen competition or tend to create a monopoly or monopsony.
AG or Commissioner may hold public forums and may bring an action to compel compliance.
Review / Enforcement
Large transactions: AG and MDH.
$10M–$80M transactions: MDH, which may share data with the AG.
New Requirements for Certain Health Care Entity Transactions
MDH Transaction Notices - MN Dept. of Health
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Where to File
Minn. Stat. §§ 145D.01, 145D.02
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Sources
CLOSE
Minnesota
A transaction is a single action or series within five years involving Minnesota or a Minnesota-formed/licensed health care entity, including: mergers/exchanges; transfer/lease/sale of 40% or more assets; security interest in 40% or more assets; transfer of 40% or more ownership; governance changes transferring control; creation of a new health care entity; revenue-sharing of 40% or more; 40%+ membership changes in nonprofit entities; or other transfer/acquisition of control.
Exclusions include common-control transactions, certain secured loans, clinical affiliations solely for trials/GME, mere hiring, clinical-service contracts, and certain transactions solely involving nursing homes/assisted living/home care and similar entities.
Covered Transactions
CLOSE
Proposed (2026). Introduced June 18, 2026; referred to House Government Operations Committee.
Status
Healthcare Transaction Notice, Review and Pre-closing Approval
Type
Any person entering a “health facility consolidation,” meaning a transaction or a series of transactions that results in a health facility acquisition or a health facility merger.
Covered acquisitions include:
an acquisition by a health facility owner of another health facility;
an acquisition by a person of 2 or more health facilities that are not currently owned by the same health facility owner;
an acquisition by a health facility owner of a controlling interest in another health facility owner; and
an acquisition by a person of a controlling interest in 2 or more health facility owners that are not currently controlled by the same health facility owner.
Covered mergers include: any merger between 2 or more health facility owners.
“Health facility” includes: any facility or agency licensed under Article 17 of the Public Health Code (including hospitals), plus any other facility where a health professional’s services are a primary function.
Who is Covered
Consolidation approval standard: Subject to hardship and small-deal exemptions (described below), the board shall not approve a covered transaction unless certain market-share conditions are met (described below), the applicant commits to reduce prices at each target facility by at least 2% on closing, and the applicant commits to limit future price increases at each target facility to the annual change in the Consumer Price Index.
Market-share conditions: the board shall not approve a consolidation that would result in a combined bed count above 8% of all beds statewide or above 15% of beds in a prosperity region, or a combined market share above 3% statewide or above 15% in a prosperity region, in any category of health services. These caps can be waived only through the hardship exemption below.
A hardship exemption waives the market-share conditions and the 2% cut, but not the CPI cap, where: (i) a target facility is financially struggling and at risk of closing; (ii) the consolidation is the only feasible way to prevent its closure, and (iii) the target facility’s owner supports the exemption.
Small-deal exemption: A transaction is not covered if the following conditions are met:
a party is a health professional, or a facility in the deal is owned by one or more health professionals;
each facility-owner’s combined annual facility revenue across all owned/operated/governed facilities is not more than $5 million; and
combined annual revenue of all facilities in the proposed deal is not more than $10 million.
Thresholds
File a consolidation application with the Hospital Cost Review Board before closing; the parties cannot close without board approval and payment of a 12% assessment tax.
A $10,000 application fee is due at filing, and the board may separately require the applicant to reimburse the board’s review costs within 30 days of request.
No fixed statutory decision deadline. The board may request additional information, with a 30-day response requirement, and may hold public hearings.
Timing
Consolidation applications delivered to a new Hospital Cost Review Board (Department of Licensing and Regulatory Affairs).
The 12% assessment tax is paid to the Department of Treasury.
Where to File
HB 6118, health facility consolidation prevention act (introduced text): https://legislature.mi.gov/documents/2025-2026/billintroduced/House/htm/2026-HIB-6118.htm
HB 6116, hospital cost review board act, which creates the reviewing board (introduced text): https://legislature.mi.gov/documents/2025-2026/billintroduced/House/htm/2026-HIB-6116.htm
Sources
Michigan
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CLOSE
Enacted
Status
Healthcare Transaction Notice and Review
Type
Any organization or business that provides diagnostic, medical, surgical, dental treatment, or rehabilitative care;
An insurer that issues a policy of accident and sickness insurance;
A health maintenance organization;
A pharmacy benefit manager;
An administrator;
A private equity partnership, regardless of where the private equity partnership is located, seeking to enter into a merger or acquisition with one of the aforementioned entities.
Who is Covered
Mergers or acquisitions with a value of at least $10,000,000
Thresholds
90 days' pre-closing; The Indiana Attorney General is required to review the parties’ submission within 45 days from receiving the notice and may analyze in writing any antitrust concerns regarding the transaction, which must be provided to the parties. The Indiana Attorney General may issue a civil investigate demand to the submitting parties for additional information.
Timing
Office of the Indiana Attorney General: https://inoag.my.site.com/oagHCEM/s/
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Where to File
IC 25-1-8.5
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Sources
Indiana
Premerger Notification Law
Material Healthcare Transactions
CLOSE
Enacted
Status
Healthcare Transaction Notice and Review
Type
Physician practice, group, or management services organization or similar entity providing all or substantially all of the administrative or management services under contract with one or more physician practices;
Provider-sponsored organization;
Health insurance plan;
Or any other kind of health care facility, organization or plan providing health care services in New York, including dental practices, clinical laboratories, pharmacies, wholesale pharmacies (including secondary wholesalers), independent practice associations, and accountable care organization.
Who is Covered
A single transaction or series of transactions (during rolling 12-month period) that will result in a health care entity increasing its total gross in-state revenue by $25 million or more.
Thresholds
30-day pre-closing notice required.
Timing
NYS Department of Health; Notices of material transactions must be reported electronically using the Material Transaction Reporting Form.
1.
Where to File
Article 45-A; Public Health Law Article 45-A, Material Transactions Frequently Asked Questions
Sources
New York
CLOSE
Enacted
Status
Type
Hospitals;
Hospital systems;
Group practices with two or more physicians licensed in Connecticut;
Other health care providers licensed by Connecticut.
Who is Covered
Thresholds
Concurrent with HSR filing or 30 days pre-closing notice.
Timing
Notices of Material Change and Healthcare Filings
1.
Where to File
Conn. Gen. Stat. § 19a-486(i)
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Sources
Connecticut
Healthcare Transaction Notice and Review
Transactions, including mergers, consolidations, affiliations, acquisitions, employment of all or substantially all physicians, of a group practice including at least two Connecticut licensed physicians with one of the following entities:
Another group practice, resulting in a group practice with 8 or more physicians; or
A hospital, hospital system, captive professional entity, medical foundation or other entity organized by, controlled by or otherwise affiliated with such hospital or hospital system.
Transactions in which one party conducting business in Connecticut is a hospital, hospital system, or other health care provider and for which the parties are required to make a filing under the Hart-Scott-Rodino (HSR) Act.
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Premerger Notification Law
Material Healthcare Transactions
CLOSE
Proposed (2026). SB 3175 introduced January 28, 2026; referred to various committees February 2, 2026.
Status
Healthcare Transaction Notice, Review, and — for certain vertical transactions — Legislative Approval
Type
"Health care entity," defined broadly to include any hospital, hospital system, health insurer, health maintenance organization, physician organization, provider group, ambulatory surgical center, or other entity licensed or authorized to provide or finance health care services in the State.
Who is Covered
A covered entity entering a “material health care transaction.” There is no proposed annual revenue, transaction value, or market share threshold.
"Material health care transaction" includes a merger, acquisition, affiliation, joint venture, consolidation, asset transfer, or other arrangement resulting in a change of control, governance, or material influence over a health care entity.
Additional legislative-approval trigger for "vertical consolidations" where the combined entity would control 25% or more of a relevant health care service market or insurance market in the State or any county, and the transaction is projected to produce specified pricing, premium, or public-expenditure effects.
Thresholds
Written notice to the state agency at least 180 days before the proposed effective date of the transaction.
Timing
State Health Planning and Development Agency (SHPDA), Hawaii Department of Health
https://ag.nv.gov/Hot_Topics/HSR_and_30-Day_Advanced_Notice_for_Health_Care_and_Health_Carrier_Transactions/
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Where to File
S.B. 3175 (Haw. 2026 Reg. Sess.) — Relating to Health Care Market Oversight
https://www.capitol.hawaii.gov/sessions/session2026/bills/SB3175_.HTM
Sources
Hawaii
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Premerger Notification Law
Material Healthcare Transactions
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Proposed (2026). H 853 introduced and referred to the House Health & Welfare Committee on March 10, 2026.
Status
Hospital Control-transfer Healthcare Transaction Notice, Review, and Approval (limited to certain nonprofit hospitals)
Type
"Covered hospital," defined as an Idaho hospital that is organized as a nonprofit corporation and has received public hospital-district assets under Idaho Code section 39-1359.
Who is Covered
A covered hospital entering into a “control transfer.” There is no proposed annual revenue, transaction value, or market share threshold.
"Control transfer" includes any transaction or arrangement resulting in a change in majority voting power of the governing board, substitution of a parent or controlling entity, or the delegation of material governance authority through a management, affiliation, or similar agreement. The last clause is what extends the bill beyond outright sales to governance-shift arrangements.
Thresholds
Written notice to the Attorney General and the Department of Health and Welfare at least 90 days before the control transfer.
At least one public hearing in the county the hospital primarily serves, with no less than 30 days' public notice.
Timing
https://ag.nv.gov/Hot_Topics/HSR_and_30-Day_Advanced_Notice_for_Health_Care_and_Health_Carrier_Transactions/
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Idaho Attorney General and Idaho Department of Health and Welfare
Where to File
H. 853 (Idaho 2026 Reg. Sess.) — Hospitals; transfer of control of certain hospitals.
https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2026/legislation/H0853.pdf
Sources
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Idaho
Premerger Notification Law
Material Healthcare Transactions
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Proposed (2026). SB 978 introduced April 30, 2026; in Senate Rules and Operations Committee as of June 9, 2026.
Status
Healthcare Transaction Notice, Review, and Legislative Approval
Type
“Hospital entities” i.e., hospitals and their affiliated organizations.
Who is Covered
Transactions, including sales of assets, leases, interests, or transfers of control, valued at $5 million or more.
Thresholds
The initial review period is 60 days, with potential extensions to 90 days, during which the transaction is prohibited from being finalized.
Timing
Provide the State Auditor, Attorney General, and State Treasurer with written notice of the proposed transaction.
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Where to File
SB 978 text available at https://www.ncleg.gov/Sessions/2025/Bills/Senate/PDF/S978v1.pdf
Sources
North Carolina
Premerger Notification Law
Material Healthcare Transactions
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Proposed (2026)
Status
Private-equity Healthcare Transaction Notice and Review
Type
Private equity firms acquiring hospitals, healthcare facilities, subacute care facilities, psychiatric institutions, hospice programs, or ambulatory surgery centers
Who is Covered
Acquisition by a private equity firm of specified healthcare facility types.
“Acquisition” means a transaction through which an entity gains the ability to direct or influence the management and policies of a healthcare facility, including through:
Ownership of voting securities;
Real estate leasing arrangements; or
Contracts (other than commercial contracts for goods or nonmanagement services).
Thresholds
60-day pre-closing notice and approval requirement
Timing
Iowa Department of Inspections, Appeals, and Licensing (DIAL)
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Where to File
Iowa SF 414
Sources
Iowa
Enacted
Status
Healthcare (Mini HSR)
Type
Healthcare entities, including healthcare providers, healthcare facilities, or a provider organization. The law expressly excludes: licensed nursing facilities and dental services providers and dental services organizations.
Who is Covered
The healthcare entity’s principal place of business (i.e., the headquarters address of the healthcare entity making the HSR filing) is in Maine; or
The healthcare entity (or a person or entity controlled directly or indirectly by the healthcare entity) had annual revenue in Maine in the most recent calendar year of at least 20% of the HSR filing threshold for the “goods or services involved in the transaction.”
Thresholds
Filing concurrent with HSR filing.
Timing
Maine Attorney General
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Where to File
H.P. 1481 (to be codified at 10 MRSA § 1102-B)
Sources
CLOSE
Enacted; Effective January 1, 2027
Status
Healthcare Transaction Notice and Review
Type
A “material change transaction” occurs when a private equity company, hedge fund, or MSO owned or controlled by either a private equity company or a hedge fund acquires either a majority interest in or operational control of a healthcare entity in Maine. Covered healthcare entities include healthcare providers (i.e., individuals or entities qualified to provide healthcare services, including medical practices), licensed healthcare facilities (including hospitals, ambulatory surgery centers, outpatient clinics, labs, and imaging centers), and provider organizations (including accountable care organizations, physician-hospital organizations, independent practice associations, and MSOs). The law expressly excludes: licensed nursing facilities and dental services providers and dental services organizations.
Who is Covered
Maine will require a yet-to-be-determined filing fee for these filings that will be between $2,000 and $10,000 per transaction.
Thresholds
180-day pre-closing notice. DHHS has 60 days to conduct a preliminary review and approve, conditionally approve, or refer the transaction to comprehensive review, which could extend the review period to over seven months.
Timing
Department of Health and Human Services (DHHS)
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Where to File
H.P. 1480 (to be codified at 22 MRSA ch. 106, §§ 371–373; 22 MRSA § 8710-A)
Sources
Maine
Healthcare Transaction Law
Healthcare Transaction Law
Mini HSR Law
Mini HSR Law
In Effect
Status
Retail Grocery and Pharmacy Transactions
Type
“Retail drug firms,” “retail grocery firms,” and those who acquire, directly or indirectly, any voting securities or assets of a retail grocery firm or retail drug firm in an HSR reportable transaction, and/or those who are acquiring more than 20 retail drug firms or retail grocery firms.
Retail drug and grocery firms are defined via NAICS code.
Who is Covered
HSR reportable transaction or acquiring more than 20 retail drug or grocery firms.
There is a filing fee that varies based on the size of the transaction.
Thresholds
Written notice to the California Attorney General at least 180 days before the proposed effective date of the transaction. This filing can be satisfied by submitting an HSR filing if one is required. If no HSR filing is made, the law requires that specific information be reported.
Timing
California Attorney General
Where to File
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB853
Sources
The acquiring entity is subject to a filing fee based on the size of the transaction and the AG’s costs of reviewing it.
Civil penalties of up to $20,000 for each day of noncompliance.
Fees and Penalties
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Retail Grocery and Pharmacy Transactions
Retail Grocery and Pharmacy Transactions
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Enacted; current statutory text sunsets January 1, 2027 unless amended
Status
Healthcare Transaction Notice and Review
Type
Health care facilities and provider organizations that are parties to covered transactions. All parties must provide notice.
“Provider organization” means an organization in health care delivery or management representing 20 or more providers in contracting with carriers/TPAs, including physician organizations, PHOs, IPAs, provider networks, and ACOs.
Covered Illinois/out-of-state transactions require notice if the out-of-state entity generates $10 million or more in annual revenue from Illinois residents.
Who is Covered
No general revenue threshold for Illinois entities.
A covered transaction is any merger, acquisition, or contracting affiliation between two or more health care facilities or provider organizations not previously under common ownership or contracting affiliation.
“Contracting affiliation” covers arrangements allowing entities to negotiate jointly, or one entity to negotiate for another, with carriers/TPAs over professional medical service rates; common-ownership arrangements are excluded.
Thresholds
Generally 30 days pre-closing/effective date.
If HSR-reportable, provide a copy of the HSR filing to the Illinois AG at the same time it is filed federally.
If a Health Facilities and Services Review Board change-of-ownership application is required, that filing satisfies the notice requirement, and HFSRB notifies the AG.
Timing
AG may request additional information within 30 days of notice; if requested, the transaction may not proceed until 30 days after substantial compliance. Later requests do not further delay closing.
Penalty up to $500 per day; AG may seek TRO/injunction in Sangamon or Cook County. A 10-day cure opportunity exists before enforcement, but not on/after the earlier of proposed or actual closing.
Review / Enforcement
Illinois Attorney General Antitrust Bureau: Antitrust Health Care
For HFSRB-triggering facility transactions, file through the Illinois Health Facilities and Services Review Board process.
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Where to File
740 ILCS 10/7.2a, added by Public Act 103-0526
Illinois Health Facilities Planning Act, where CHOW review applies
Antitrust Health Care
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Sources
Illinois
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Civil penalties of up to $25,000 per day for failure to comply.
Filings are confidential and exempt from public disclosure, subject to statutory exceptions.
Enforcement
Civil penalties of up to $10,000 per day for failure to comply.
Filings are confidential and exempt from public disclosure, subject to statutory exceptions.
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Enforcement
Luke Taeschler
+1.212.653.8464
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