Updates

Washington: notice of health care deals (RCW 19.390)

What it does. Parties must give the attorney general written notice at least 60 days before a "material change": a merger, acquisition or contracting affiliation between hospitals, hospital systems or provider organizations; any deal that changes majority ownership or control of one; a sale of most of its assets, including sale-leasebacks; or a nonprofit-to-for-profit conversion. If the attorney general asks for more information within 30 days, the deal cannot close until 30 days after the parties substantially comply. Parties must report within 30 days after the deal is completed, abandoned or blocked (RCW 19.390).

Key dates. Enacted in 2019. The legislature amended the chapter in 2026 (statute).

Who it covers. Hospitals, hospital systems and "provider organizations," meaning groups that contract with insurers on behalf of seven or more health care providers. Some deals with out-of-state entities with $10 million or more in Washington revenue are also covered (statute; Washington Attorney General).

What it means for physicians and patients. The attorney general posts a quarterly public list of pending and completed deals, so physicians and patients can see changes in ownership. The law is a notice requirement, not an approval process. Penalties are up to $200 a day, and the law creates no private right to sue (statute).

Compared with TPIPPA. Washington tells the state about deals before they close. TPIPPA would also set rules on who may own and control a practice and require every management agreement to be filed with the Texas Medical Board (how TPIPPA works).

California SB 351: limits on private equity and hedge funds

What it does. A private equity group or hedge fund involved with a physician or dental practice in California may not interfere with clinical judgment, such as choosing tests, referrals, treatment, or how many patients a doctor sees or how many hours a doctor works. It also may not control medical records, hire or fire clinicians based on clinical competence, set payer-contracting terms, make coding and billing decisions, or approve equipment and supplies. Contract terms that allow this are void. Management and asset-sale contracts with these investors may not bar clinicians from competing after they leave or from speaking about quality of care. The attorney general can seek an injunction and recover fees (bill text).

Key dates. Signed by the governor on October 6, 2025 (Chapter 409, Statutes of 2025) (bill text).

Who it covers. Private equity groups and hedge funds and the entities they control. Hospitals and hospital systems, and public agencies are excluded. Unlicensed parties may still assist or consult if the physician keeps final approval (bill text).

What it means for physicians and patients. The law states that clinical decisions are to stay "exclusively in the hands of licensed health care providers," and it protects clinicians who speak up about quality of care (bill text).

Compared with TPIPPA. SB 351 covers private equity and hedge funds. TPIPPA would protect the same kinds of decisions from anyone without a license, void most physician noncompetes regardless of who owns the practice, and add private lawsuits and attorney general fines (how TPIPPA works).

Rhode Island: pre-merger notice for medical-practice groups

What it does. At least 60 days before a "material change," the parties must notify the attorney general. Material changes include a medical-practice group merging with or being bought by a hospital or hospital system; a combination that creates a group of eight or more physicians, physician assistants or nurse practitioners; forming an MSO or similar entity to contract with insurers for one or more groups; and deals in which a "significant equity investor" gains ownership or control (rule text). The notice form asks about expected effects on reimbursement rates, referral patterns, access and quality of care (Attorney General).

Key dates. Rulemaking began May 28, 2025; effective January 28, 2026 (Attorney General).

Who it covers. Rhode Island medical-practice groups in any legal form, and the investors, hospitals and MSOs that deal with them. A "significant equity investor" includes private equity investors with a financial interest and any investor holding more than 10% (McDermott Will & Schulte).

What it means for physicians and patients. The attorney general, the state's primary antitrust regulator, learns about practice deals before they close. Penalties can reach $200 a day for late notice and up to $100,000 if no notice is given by closing, and the attorney general may ask a court to delay a deal until notice is given (McDermott Will & Schulte).

Compared with TPIPPA. Rhode Island's rule requires notice but does not limit who may own or control a practice. TPIPPA would do both: set those limits and make management agreements and ownership public through the Texas Medical Board (how TPIPPA works).

H.R. 10444: Stop Corporate Takeovers of Physicians Act of 2026

What it does. The bill would make it unlawful for an entity that is not majority-owned and controlled by licensed clinicians to own or control a medical practice, employ or contract for a licensee's professional services, or practice medicine. It would void noncompete clauses (with a narrow exception for owners of 25% or more) and nondisclosure and non-disparagement agreements. It would bar management services organizations from owning practices, controlling their sale, or making decisions on hiring, schedules, revenue, staffing, visit length, coding, billing, prices or payer contracts. Management fees would have to be negotiated at arm's length and reflect fair market value. Licensee owners would have to be licensed in the state, present there and substantially engaged in patient care (bill text).

Key dates. Introduced September 16, 2026 and referred to the House Energy and Commerce and Ways and Means committees; no further action (congress.gov). If enacted, the rules would take effect one year later (bill text).

Who it covers. Medical practices nationwide and the entities that own or manage them. "Licensee" includes physicians and advanced practice providers such as physician assistants and nurse practitioners. Nonprofit and public providers, hospitals, hospital-affiliated clinics, critical access hospitals and rural emergency hospitals are exempt from the ownership ban (bill text).

What it means for physicians and patients. The FTC would enforce it. Injured people could sue for triple damages and attorney's fees, state attorneys general could sue, and courts would order divestment and the return of revenue. It would not preempt state laws that are equal or stricter (bill text). Sidley describes it as modeled on Oregon's law and says it is unlikely to pass (Sidley).

Compared with TPIPPA. The two share core ideas: licensee ownership, limits on management companies, fair market fees and void noncompetes. TPIPPA is a Texas bill. It adds filing with the Texas Medical Board, emergency department staffing and medical director rules, and criminal penalties for executives who knowingly control medical decisions (how TPIPPA works).

The FTC and health care roll-ups

What happened. In January 2025 the FTC settled with private equity firm Welsh, Carson, Anderson & Stowe over a series of anesthesia practice acquisitions in Houston and Dallas-Fort Worth. The complaint alleged those deals created monopoly power used to raise prices. Andrew Ferguson, then a commissioner, wrote that the case was a standard antitrust merger case and that the firm being private equity was "irrelevant" (Ferguson statement). In March 2026, Ferguson, now chairman, issued a memo creating a health care task force (Healthcare Dive). On October 22, 2026, he said the agency is investigating "serial acquisitions" in health care (RealClearHealth).

Who it covers. Any acquirer, whatever its corporate form, whose deals may substantially lessen competition (Ferguson statement).

What it means for physicians and patients. Federal antitrust law can reach roll-ups that raise prices, but each case must show that the acquisitions harm competition (Ferguson statement).

Compared with TPIPPA. Antitrust enforcement looks at market power one case at a time, usually after deals are done. TPIPPA would set ownership and control rules in advance, whatever a company's market share (how TPIPPA works).

Deal flow: physician practice deals slow

What the data show. PitchBook's Q3 2026 healthcare services report says private equity deal count in healthcare services fell 28.5% year over year. Physician practice management deals fell 27.3%, and generalist and multispecialty provider deals fell 53.9%. PitchBook cites regulatory scrutiny of private equity ownership as a challenge for investors (PitchBook).

Key dates. Report published October 29, 2026 (PitchBook).

What it means for physicians and patients. Fewer practices changed hands in the quarter. The report does not attribute the drop to any single law (PitchBook).

Compared with TPIPPA. This is market data, not a law. TPIPPA's rules would apply regardless of deal volume.

California AB 1415 and the OHCA regulations

What it does. AB 1415 expanded the transaction notices filed with California's Office of Health Care Affordability (OHCA). It added private equity groups, hedge funds, management services organizations, newly created deal entities, and entities that own or control providers as "noticing entities." Notice is due at least 90 days before the deal (bill text). The final regulations say a private equity or hedge fund deal is a material change if the investor ends up with 10% or more of a covered entity, or less with certain control rights. They also set filing thresholds for MSOs and require more disclosure. OHCA may follow up with a cost and market impact review (Wilson Sonsini).

Key dates. Signed October 11, 2025 (bill text); expanded notice effective January 1, 2026; final regulations effective November 2, 2026 (Wilson Sonsini).

Who it covers. Health care entities that meet revenue or asset thresholds (generally $25 million, or $10 million in some deals), along with the investors and MSOs that deal with them. Physician organizations with fewer than 25 physicians are generally excluded unless they are high-cost outliers (Wilson Sonsini).

What it means for physicians and patients. Filings are generally public records unless OHCA accepts a confidentiality request, so more deals involving outside investors will be visible before they close (Wilson Sonsini). The law states that it does not change California's ban on the corporate practice of medicine (bill text).

Compared with TPIPPA. AB 1415 requires notice and review but does not ban any deal. TPIPPA would set ownership and control limits and require management agreements to be filed with the Texas Medical Board (how TPIPPA works).

November 3, 2026

Oregon's law, put to the test

Oregon passed the nation's toughest law against corporate control of medicine in 2025 (SB 951). Its ownership and control limits took effect January 1, 2026 for new arrangements; arrangements that already existed have until January 1, 2029 (SB 951, Sec. 9). This year, a single emergency department fight showed what such a law can do.

What happened

1. February 2026. PeaceHealth told Eugene Emergency Physicians (EEP), the local group of 41 clinicians that had staffed its Lane County ERs for about 35 years, that it would be replaced by Georgia-based staffing company ApolloMD, working through a newly formed physician group, Lane Emergency Physicians, owned by an Illinois-based physician (OPB, KLCC).
2. February 11. All 41 EEP clinicians signed a pact refusing to work for ApolloMD (KLCC).
3. February 24. Of 367 ballots cast by PeaceHealth Oregon medical staff, 93% voted no confidence in the chief hospital executive and chief medical officer (OPB).
4. March. Two EEP physician leaders testified before an Oregon Senate committee. Lawmakers asked ApolloMD to show it complied with SB 951; the bill's author, House Majority Leader Ben Bowman, said its response "only raised further concerns" (KLCC).
5. April 9. The chief hospital executive was placed on leave after allegations, based on more than 300 pages of emails, that he tried to influence patient care while holding only an administrative license (OPB).
6. April 22. Nurses delivered a petition signed by more than 6,800 people asking PeaceHealth to keep EEP (Oregon Nurses Association).
7. April 27 – May 6. EEP's lawsuit under SB 951 went to a hearing in federal court. The judge said the idea that the new group's leaders had "no idea how this is set up" "defies logic and credibility," and called the arrangement as presented no clearer than "a shell game" (KLCC). On day four he said ApolloMD's CEO and the new group's owner were "being dishonest with the court" under oath (KLCC).
8. May 6. Before final arguments, the parties reached a settlement. EEP keeps staffing the RiverBend and Cottage Grove emergency departments for at least three years, and ApolloMD and its new group are out of the arrangement entirely. The deal includes joint tracking of patient experience, length of stay and staffing data (The Oregonian, OPB). The case was dismissed by agreement on May 20 (court filing).
9. May 14. PeaceHealth said the chief hospital executive no longer works for the system (OPB).

Closing the hearing, the judge called SB 951 "a wise, far-reaching decision ... to protect patients and the medical profession from exactly what's happened in this case" (The Oregonian).

The honest caveat

Because the case settled, no court has ruled on what SB 951 means. Oregon's law now has a deterrent record, not a precedent. Most existing arrangements also don't have to comply until 2029, so the larger effects are still ahead. Law firms advising the industry are telling clients to review and restructure their management arrangements so physicians keep control of clinical decisions, and to plan for both deadlines (Holland & Knight, Ropes & Gray, Wilson Sonsini).

What it means for Texas

In Oregon it took a lawsuit, a medical staff revolt, a petition and five days in federal court to keep a local ER group in place. Oregon showed this can be stopped case by case. TPIPPA would stop it by statute, with clear rules on who may hold a hospital physician-coverage contract and who may direct patient care. Read the bill.