Overview
- Gov. Gavin Newsom signed AB 1415 shortly after SB 351, and both laws take effect on January 1, 2026.
- AB 1415 extends OHCA’s pre-transaction notice to private equity groups, hedge funds, MSOs, newly formed deal entities, and entities that own, operate, or control providers.
- Many material deals must be noticed at least 90 days before closing, including significant asset dispositions and transfers of control over MSO assets or operations.
- SB 351 codifies corporate practice of medicine limits by barring investor control over clinical and core operational decisions and prohibiting non-competes and contract clauses that silence provider commentary on quality or ethics.
- OHCA will conduct rulemaking in the coming months to clarify filing thresholds and procedures, and stakeholders should plan for longer lead times and update governance and contracts to preserve clinical independence.