As federal antitrust and fraud enforcement recalibrates (withdrawn antitrust safe harbors, weakened merger-reporting tools, and slower federal fraud investigations amid HHS staffing cuts) California is moving in the opposite direction, and the action is concentrated on the transactional side. SB 351 and AB 1415 took effect January 1, 2026, codifying corporate practice of medicine limits on private equity and hedge funds and pulling private equity groups, hedge funds, and management services organizations into the Office of Health Care Affordability’s pre-transaction notice regime. The Attorney General is already enforcing: a May 2026 corporate-practice settlement with private-equity-owned Aspen Dental, a June 2026 corporate-practice settlement with Carbon Health imposing $4.5 million in penalties and requiring restructuring of its “friendly PC” arrangements, and a March 2026 amicus brief in Art Center Holdings pressing a categorical reading of the corporate-practice ban, each layered on top of the office’s longstanding statutory authority to review and condition every nonprofit healthcare facility transaction, including in bankruptcy. This panel connects those threads into a single operating picture: what the enforcement surge means for deal structuring, diligence, OHCA notice triggers and timing, MSO-PC and physician-alignment arrangements, and day-to-day governance. Attendees will leave able to anticipate where state scrutiny will land and an understanding of compliance consideration in a fast-developing area.

This webinar offers 1 hour of MCLE credit and is free for CSHA members. Registration for non-members is $50. Non-members: email csha@csha.info to register.

Speakers

Michael Wood
Senior Attorney | Arnold & Porter Kaye Scholer LLP

Loreli (Lori) Wright
Senior Associate | Arnold & Porter Kaye Scholer LLP