Simpson Thacher Secures COPA Approval for HCA Healthcare's Sale of Terre Haute Regional Hospital
The Firm represented HCA Healthcare in connection with the regulatory review and approval of its sale of Terre Haute Regional Hospital to Union Health, pursuant to a Certificate of Public Advantage ("COPA"). The transaction involved a merger of the only two hospitals in Terre Haute, Indiana and faced significant antitrust scrutiny from the Federal Trade Commission during both the Biden and Trump Administrations, and by the Indiana Office of the Attorney General and Indiana Department of Health (“IDOH”). Following a multi-year regulatory review process, the IDOH approved the COPA, finding that the benefits of the transaction outweigh any potential disadvantages attributable to a reduction in competition. The COPA from the IDOH grants the newly combined hospital system immunity from federal and state antitrust laws, pursuant to Indiana’s COPA statute. The transaction successfully closed on December 13, 2025.
The Simpson Thacher team included Partners Sara Razi and Lindsey Bohl, and Associates Avia Gridi and Jordan Krieger.