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State Healthcare Transaction Notification Laws Resource

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The state healthcare transaction regulatory landscape is rapidly evolving as an increasing number of states adopt laws requiring notice to, or approval from, state agencies before certain healthcare transactions may close. These laws vary significantly in scope and application. Depending on the jurisdiction, they may apply based on the types of parties involved (such as healthcare entities, provider organizations, management services organizations, or private equity investors), transaction size or revenue thresholds, changes in ownership or control, or other transaction characteristics. Filing requirements, review periods, agency authority, confidentiality protections, and potential penalties for noncompliance likewise differ substantially from state to state, creating a complex and expanding regulatory framework for healthcare transactions.

Our Healthcare and FDA Regulatory and Antitrust and Competition practices work together to help clients navigate these evolving state requirements across mergers and acquisitions, investments, affiliations, restructurings, and other strategic transactions. We work closely with clients to assess whether state notice or approval obligations are triggered, develop filing strategies and transaction timelines, coordinate multistate compliance, and advise on agency engagement throughout the review process. By integrating the firm’s healthcare regulatory, antitrust, corporate, and transactional capabilities, we help clients identify regulatory risks early, minimize execution uncertainty, and efficiently manage the growing patchwork of state healthcare transaction laws.

Overview

The state healthcare transaction regulatory landscape is rapidly evolving as an increasing number of states adopt laws requiring notice to, or approval from, state agencies before certain healthcare transactions may close. These laws vary significantly in scope and application. Depending on the jurisdiction, they may apply based on the types of parties involved (such as healthcare entities, provider organizations, management services organizations, or private equity investors), transaction size or revenue thresholds, changes in ownership or control, or other transaction characteristics. Filing requirements, review periods, agency authority, confidentiality protections, and potential penalties for noncompliance likewise differ substantially from state to state, creating a complex and expanding regulatory framework for healthcare transactions.

Our Healthcare and FDA Regulatory and Antitrust and Competition practices work together to help clients navigate these evolving state requirements across mergers and acquisitions, investments, affiliations, restructurings, and other strategic transactions. We work closely with clients to assess whether state notice or approval obligations are triggered, develop filing strategies and transaction timelines, coordinate multistate compliance, and advise on agency engagement throughout the review process. By integrating the firm’s healthcare regulatory, antitrust, corporate, and transactional capabilities, we help clients identify regulatory risks early, minimize execution uncertainty, and efficiently manage the growing patchwork of state healthcare transaction laws.

Andrea Linna
Partner
Andrea Linna is a partner at Wilson Sonsini Goodrich & Rosati, where she is a member of the firm’s digital health industry group and its healthcare practice. With more than 15 years dedicated to healthcare law, Andrea exclusively represents digital health and health tech clients, from emerging companies to established industry players and their venture capital investors. 
  • Regulatory
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Nawa Lodin
Associate
Washington, D.C.
Nawa Lodin is a Chambers USA-ranked associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where she is a member of the firm’s digital health industry group and healthcare practice. She advises healthcare, digital health, life sciences, and technology companies on complex healthcare regulatory and transactional matters, with a particular focus on artificial intelligence and machine learning in healthcare, telehealth, corporate practice of medicine, and federal and state fraud and abuse laws, including the Anti-Kickback Statute and Stark Law.
  • Regulatory
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Jamillia P. Ferris
Partner
Washington, D.C.
Jamillia represents clients in several areas, including merger review, government investigations, and antitrust-related counseling and litigation.
  • Antitrust and Competition
View Profile
Kimberley Biagioli
Senior Counsel
Washington, D.C.
Kim Biagioli is senior counsel in the antitrust practice of Wilson Sonsini Goodrich & Rosati, where her practice focuses on United States antitrust and competition law. She advises clients in a variety of industries on all aspects of the merger review and clearance process, including Hart-Scott-Rodino Act compliance. Kim also provides guidance on antitrust risks of mergers and acquisitions and other transactional issues, including pre-closing conduct.
  • Regulatory
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Maureen Ohlhausen
Partner
Washington, D.C.
Maureen Ohlhausen co-chairs Wilson Sonsini Goodrich & Rosati's antitrust and competition practice. A former acting chairman of the Federal Trade Commission (FTC), and the only FTC commissioner to receive the Robert Pitofsky Lifetime Achievement Award, she advises clients on complex antitrust and consumer protection matters. Sought after for her depth of experience on antitrust and FTC-related issues, Maureen is known for her relationships with officials in the U.S. and abroad.
  • Antitrust and Competition
View Profile
Evan Moore
Associate
Washington, D.C.
Evan Moore is an associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where he is a member of the firm’s antitrust practice group. His work encompasses a variety of antitrust matters, including merger reviews conducted by the Federal Trade Commission and the DOJ’s Antitrust Division.
  • Antitrust and Competition
View Profile
People
Andrea Linna
Partner
Andrea Linna is a partner at Wilson Sonsini Goodrich & Rosati, where she is a member of the firm’s digital health industry group and its healthcare practice. With more than 15 years dedicated to healthcare law, Andrea exclusively represents digital health and health tech clients, from emerging companies to established industry players and their venture capital investors. 
  • Regulatory
View Profile
Nawa Lodin
Associate
Washington, D.C.
Nawa Lodin is a Chambers USA-ranked associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where she is a member of the firm’s digital health industry group and healthcare practice. She advises healthcare, digital health, life sciences, and technology companies on complex healthcare regulatory and transactional matters, with a particular focus on artificial intelligence and machine learning in healthcare, telehealth, corporate practice of medicine, and federal and state fraud and abuse laws, including the Anti-Kickback Statute and Stark Law.
  • Regulatory
View Profile
Jamillia P. Ferris
Partner
Washington, D.C.
Jamillia represents clients in several areas, including merger review, government investigations, and antitrust-related counseling and litigation.
  • Antitrust and Competition
View Profile
Kimberley Biagioli
Senior Counsel
Washington, D.C.
Kim Biagioli is senior counsel in the antitrust practice of Wilson Sonsini Goodrich & Rosati, where her practice focuses on United States antitrust and competition law. She advises clients in a variety of industries on all aspects of the merger review and clearance process, including Hart-Scott-Rodino Act compliance. Kim also provides guidance on antitrust risks of mergers and acquisitions and other transactional issues, including pre-closing conduct.
  • Regulatory
View Profile
Maureen Ohlhausen
Partner
Washington, D.C.
Maureen Ohlhausen co-chairs Wilson Sonsini Goodrich & Rosati's antitrust and competition practice. A former acting chairman of the Federal Trade Commission (FTC), and the only FTC commissioner to receive the Robert Pitofsky Lifetime Achievement Award, she advises clients on complex antitrust and consumer protection matters. Sought after for her depth of experience on antitrust and FTC-related issues, Maureen is known for her relationships with officials in the U.S. and abroad.
  • Antitrust and Competition
View Profile
Evan Moore
Associate
Washington, D.C.
Evan Moore is an associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where he is a member of the firm’s antitrust practice group. His work encompasses a variety of antitrust matters, including merger reviews conducted by the Federal Trade Commission and the DOJ’s Antitrust Division.
  • Antitrust and Competition
View Profile
  • Alert | New Oregon HCMO Rules Bring Higher Fees, New Penalties, and Deal Timing Requirements, August 13, 2026
  • Alert | State Healthcare Transaction Notification Laws: A Growing Risk to Deal Timing and Execution in Healthcare M&A, August 6, 2026
  • Alert | California MSO Transaction Notification Requirements Begin January 1, 2026, November 19, 2025
  • Alert | States Expand Premerger Filings Family by Adopting “Baby-HSR” Laws to Review More Transactions, April 15, 2025

The following states currently have state healthcare transaction notice laws:

 

 

State

State

California

Minnesota

Colorado

Nevada

Connecticut

New York

Hawaii

New Mexico

Illinois

Oregon

Indiana

Rhode Island

Maine (effective January 1, 2027)

Vermont (effective March 1, 2027)

Massachusetts

Washington

 

Insights and Resources
  • Alert | New Oregon HCMO Rules Bring Higher Fees, New Penalties, and Deal Timing Requirements, August 13, 2026
  • Alert | State Healthcare Transaction Notification Laws: A Growing Risk to Deal Timing and Execution in Healthcare M&A, August 6, 2026
  • Alert | California MSO Transaction Notification Requirements Begin January 1, 2026, November 19, 2025
  • Alert | States Expand Premerger Filings Family by Adopting “Baby-HSR” Laws to Review More Transactions, April 15, 2025

The following states currently have state healthcare transaction notice laws:

 

 

State

State

California

Minnesota

Colorado

Nevada

Connecticut

New York

Hawaii

New Mexico

Illinois

Oregon

Indiana

Rhode Island

Maine (effective January 1, 2027)

Vermont (effective March 1, 2027)

Massachusetts

Washington

 

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