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California Enacts AB 1415, Expanding OHCA Review to Private Equity, Hedge Funds and MSOs

Starting in 2026, covered investors must give 90 days’ notice, with MSOs subject to new data reporting.

Overview

  • Governor Gavin Newsom signed AB 1415 on October 11, 2025, with the law taking effect January 1, 2026.
  • AB 1415 creates a new category of “noticing entities,” covering private equity groups, hedge funds, MSOs, newly formed deal vehicles, and entities that own or operate providers.
  • Transactions within scope require pre‑closing notice to the Office of Health Care Affordability, which may conduct Cost and Market Impact Reviews that can delay closings.
  • The statute does not grant OHCA authority to block transactions, but it broadens the universe of deals subject to review and information requests.
  • Implementing rules are pending, including clarity on thresholds and filing formats, and the move follows SB 351’s recent codification of corporate practice restrictions with Attorney General enforcement.