California OHCA Finalizes CMIR Notice Rules for PE, Hedge Funds, MSOs
Amended cost and market impact review regulations effective Nov. 2, 2026 replace interim guidance on which private equity, hedge fund and MSO transactions must file notice with OHCA, and when.
California's Office of Health Care Affordability (OHCA) issued amended cost and market impact review (CMIR) regulations that take effect Nov. 2, 2026, according to a McGuireWoods client alert. The rules replace OHCA's interim guidance on who must file notice, when notice must be filed, and what must be submitted, with the alert noting particular attention to private equity funds, hedge funds and management services organizations (MSOs).
Why sophisticated counsel and clients care: for sponsors, health systems and their advisers, the filing trigger and timing under the prior interim guidance fed directly into deal structuring — whether an acquisition required notice, how long pre-signing preparation of notice content took, and how the review obligation was allocated among parties. These amendments are now operative regulation rather than non-binding guidance, and they affect conditionality, timetable and sequencing for healthcare transactions in the state's largest healthcare market.
What to watch next: the precise notice content and timing requirements in the amended text, how the filing trigger interacts with notice provisions in pending California healthcare deals, and whether other states' review programs move in a comparable direction. Affected clients should re-map live and contemplated California healthcare transactions against the new filing tests and revisit regulatory-out and timing assumptions.