Simpson Thacher Attorneys Author Article on California’s Expanded Review of Private Equity Healthcare Transactions
Partners Vanessa Burrows and Lindsey Bohl and Associate Evan Miller authored an article titled, “Preparing For Broader Calif. Rules On PE Healthcare Deals,” published by Law360. The article examines emergency regulations proposed by California’s Office of Health Care Affordability (OHCA) that would significantly expand the agency’s oversight of healthcare transactions involving noticing entities including private equity groups, hedge funds and management services organizations. The authors discuss how the regulations clarify key definitions that determine the scope of OHCA’s review authority, broaden the transaction circumstances that trigger filing obligations and impose significant new disclosure requirements on transaction parties. The article also highlights practical considerations, including the need to account for the 90-day preclosing notice requirement, potential cost and market impact reviews and enhanced reporting obligations, as California continues to increase scrutiny of private capital investments in the healthcare sector.
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