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Health Care & Hospital Law,
Mergers & Acquisitions

Jan. 31, 2024

A new era in California health care M&A

Though it is too early to tell how aggressive the California Office of Health Care Affordability will be in subjecting transactions to a full review, the regulations will consider the anticompetitive impact and potential negative impact on health care costs or availability.

California healthcare transactions closing on or after April 1, 2024 could be subject to a nine month or greater delay under the cost and market impact review (CMIR) regulations recently promulgated by the newly created California Office of Health Care Affordability (OHCA).

1. Applicability

The applicability of CMIR to a given transaction boils down to three questions: Does the transaction involve a health care...

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