The California Department of Health Care Access and Information (HCAI) recently announced, through newly posted HCAI AB 1415 FAQs, that regulations implementing AB 1415 should be expected in Spring 2026. AB 1415 takes effect on January 1, 2026, and expands the entities required to notify the Office of Health Care Affordability (OHCA) of “material change” health care transactions. Private equity groups, hedge funds, management services organizations (MSOs), and newly created entities will fall within the law’s scope.
HCAI indicated that OHCA intends to maintain the existing 90-day advance filing deadlines in its forthcoming regulations. Under current statute and regulations, health care entities that are a party to or the subject of a transaction must file with OHCA “at least 90 days prior to entering into the agreement or transaction.” OHCA expects to adopt the same timelines for newly covered noticing entities.
Until implementing regulations are issued, however, newly covered noticing entities are still required to provide OHCA with written notice of a material change transaction. The FAQs state that noticing entities must “at a minimum, provide written notice” during the interim period. The categories of “noticing entities” are defined in statute, and if any party to the transaction is a health care entity, notice to OHCA is already required and will remain so after January 1, 2026.
Affected entities should begin reviewing any anticipated 2026 transactions to determine whether they could qualify as material change transactions and require notice. Newly covered entities, such as private equity groups, hedge funds, MSOs, and newly created entities, should be prepared to provide written notice and assume the existing 90-day timeline will apply until OHCA issues its regulations.
Alston & Bird is closely monitoring these developments. Please contact us with any questions about AB 1415 or other state-level transaction review requirements.
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