On April 16, 2026, the Massachusetts Health Policy Commission (HPC) approved amendments to its Material Change Notice (MCN) regulations at 958 CMR 7.00 (the Amended Regulations), which went into effect on May 8, 2026. As background, following the 2025 passage of health care legislation that expanded the HPC’s health care market oversight responsibilities, the HPC
Healthcare Transactions
Connecticut Disbands Office of Health Strategy and Reassigns Health Care Oversight and Policymaking Authority Across State Agencies
By Conor Duffy, Michael Lisitano & Ivy Miller on
Posted in Academic Medical Centers, Ambulatory Surgical Centers (ASC), Health Information Exchanges and Electronic Medical Records (EMRs), Health Information Technology, Health Policy, Healthcare Transactions, Hospitals and Health Systems, Legislation, Medicare and Medicaid, Physicians and Allied Health Professionals
Connecticut Governor Ned Lamont recently signed Public Act No. 26-68 (“the Act”), which includes the elimination of the Office of Health Strategy (OHS) and reassignment of its statutory authority over the health care delivery system in Connecticut. The Act’s repeal of OHS’s enabling statute and the transfer of its authority to other state agencies are scheduled…
Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority
By Conor Duffy, Ivy Miller & Robinson+Cole's Health Law Group on
On February 5, 2026, the Massachusetts Health Policy Commission (HPC) published proposed amendments to its Material Change regulations at 958 CMR 7.00 (the Proposed Amendments). Among other things, the Proposed Amendments broaden the HPC’s market review authority by subjecting more transactions to the HPC’s Material Change Notice (MCN) process and provide the HPC greater latitude…
OIG Green Lights MSO Model Arrangement for Telehealth Platforms in New Advisory Opinion
On June 11, 2025, the Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 25-03 (the Advisory Opinion), in which OIG approved of a proposed arrangement under which a management support organization and a physician-owned professional corporation (the Requestors) would enter into an arrangement involving the leasing of clinical employees…
Connecticut Establishes Emergency Certificate of Need Process for Hospitals in Bankruptcy
By Conor Duffy, Michael Lisitano & Guest Contributor on
*This post was authored with Paul Palma, law intern at Robinson+Cole. Paul is not admitted to practice law.
On March 3, 2025, Connecticut Governor Ned Lamont signed a law establishing a new process for hospitals in bankruptcy to apply for an “emergency certificate of need” (CON) to approve a transfer of ownership. The law, titled …
Massachusetts Enhances Regulatory Oversight of Health Care Transactions on For-Profit and Private Equity Investments
By Danielle Tangorre, Conor Duffy, Leslie Levinson, Guest Contributor & Robinson+Cole's Health Law Group on
This post is co-authored by Seth Orkand, co-chair of Robinson+Cole’s Government Enforcement and White-Collar Defense Team.
Massachusetts has expanded regulatory oversight of health care transactions by imposing False Claims Act liability on health care owners and investors for changes including failure to disclose violations. On January 8, 2025, Governor Maura Healey signed…
Massachusetts Expands FCA Liability To Owners and Private Equity Investors
By Danielle Tangorre, Conor Duffy, Leslie Levinson & Guest Contributor on
This post is co-authored by Seth Orkand, co-chair of Robinson+Cole’s Government Enforcement and White-Collar Defense Team.
Under a new 2025 law, Massachusetts is one of the first in the nation to broaden its state False Claims Act (FCA) to require disclosures by investors and owners of health care entities. On January 8…
California Governor Vetoes Bill Imposing New Requirements for Private Equity in Healthcare Transactions
By Robinson+Cole's Health Law Group, Leslie Levinson & Danielle Tangorre on
On September 28, 2024, California Governor Gavin Newsom vetoed California Assembly Bill 3129 (the Bill). The Bill, if enacted, would have imposed new notice and consent requirements for private equity investors involved in healthcare transactions. Governor Newsom’s veto statement clarifies the Bill’s vetoing, stating that the Office of Health Care Affordability (OHCA) “was created as…
Health Care Transactions and Civil Investigative Demands: What Third Parties Need to Know
By Conor Duffy on
Below is an excerpt of an article, co-authored with Antitrust and Trade Regulation Team lawyer Jen Driscoll and Internal Investigations and Corporate Compliance chair Ed Heath, published in the American Health Law Association’s Health Law Weekly newsletter on January 19, 2024.
Mergers and acquisitions in health care markets are viewed with heightened scrutiny by…
Two Pathways for Medicaid Self-Disclosures Announced by OMIG
By Danielle Tangorre on
The New York Office of the Medicaid Inspector General (OMIG) recently announced updates to its Self-Disclosure Program in response to feedback from Medicaid stakeholders after its revised posting in January 2023. OMIG revised its disclosure process to have two pathways for healthcare providers to report, explain, and return overpayments by creating an “Abbreviated Self-Disclosure Process” in addition to the existing full disclosure process.
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