About the Course
Introduction
This CLE webinar will examine two recently enacted California laws, AB 1415 and SB 351, both effective Jan. 1, 2026, that will increase the state's oversight of private equity (PE) and hedge fund investments in the healthcare industry. The panel will examine new filing requirements for PE groups, hedge funds, and management services organizations (MSOs) involved in healthcare transactions, and the codification of existing corporate practice of medicine and dentistry restrictions. The panel will also offer best practices for evaluating current and proposed transactions and MSO arrangements for compliance.
Description
California recently enacted two significant laws, AB 1415 and SB 351, that will increase the state's oversight of PE and hedge fund investments in the healthcare industry. Both laws, effective Jan. 1, 2026, signal California's enhanced scrutiny of the influence of nonclinical entities such as PE, hedge funds, and MSOs in healthcare. Counsel should be aware of how these laws may impact current or proposed healthcare deals and MSO arrangements.
AB 1415 expands the types of entities subject to the Office of Health Care Affordability's (OHCA's) transaction filing requirements to include PE groups, hedge funds, and MSOs. These new "noticing entities" must provide notice to OHCA before closing healthcare deals involving material changes. AB 1415 also grants OHCA with authority to establish a new data reporting framework for MSOs in the state.
SB 351, which applies to PE groups and hedge funds involved in physician and dental practices in the state, codifies certain aspects of California's corporate practice of medicine and dentistry doctrines. While the restrictions set forth in SB 351 are largely consistent with existing corporate practice doctrine, SB 351 enhances oversight for PE groups and hedge funds by granting the state Attorney General enforcement authority over these doctrines. Additionally, SB 351 sets forth certain prohibitions with respect to the use of noncompete and non-disparagement clauses in management contracts.
Listen as our expert panel examines AB 1415 and SB 351, and discusses how these laws will impact MSO arrangements and PE groups and hedge funds' investments in the California healthcare industry. The panel will address new requirements and restrictions and offer best practices for compliance.
Presented By
Mr. Friedman advises clients at the forefront of the healthcare industry in areas such as government insurance programs, digital health, accountable care and value-based payments, and regulatory compliance. A former leader of one of the largest Medicaid programs in the country, he provides valuable insight and solutions to healthcare companies and investors navigating complex transactional, regulatory, enforcement and policy matters. Over the course of his career, Mr. Friedman has held top positions at the New York State Department of Health (NYSDOH), including Director of Strategic Initiatives and Special Medicaid Counsel, and most recently, Deputy Commissioner and State Medicaid Director. Prior to joining NYSDOH, he was co-head of the firm’s digital health initiative. At the firm, Mr. Friedman advises payers and providers on the transition to accountable care and value-based payment and assists investors with a range of transactional needs. Additionally, he counsels clients facing government investigations, audits and self-disclosures, as well as violations of healthcare fraud and abuse laws.
Ms. Romig has significant experience in advising clients on a variety of complex transactional, enforcement and regulatory matters within the healthcare and digital health industries. She advises healthcare industry clients, private equity firms and other investors on structuring and negotiating mergers and acquisitions, joint ventures, affiliations and a variety of contractual arrangements and general business transactions. Ms. Romig has particular experience counseling clients on an array of data privacy, security and cybersecurity matters under HIPAA as well as state privacy and security laws. She regularly represents clients involved in security incidents and breaches involving protected health and other sensitive personal information, including in matters involving the U.S. Department of Health and Human Services, Office for Civil Rights and state authorities. Ms. Romig has also provided guidance to clients with respect to negotiation, implementation and adherence to Corporate Integrity Agreements.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Wednesday, January 28, 2026
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. Introduction
II. AB 1415
A. Overview
1. New "noticing entities"
2. MSO data reporting requirements
B. Practical implications
C. Forthcoming regulations
III. SB 351
A. Overview
1. Scope
2. Corporate practice restrictions
3. Restrictive covenants
B. Practical implications
C. Best practices for compliance
IV. Takeaways
The panel will review these and other key issues:
- How does AB 1415's expansion of "noticing entities" impact the types of healthcare transactions subject to review?
- When will OHCA issue regulations clarifying filing requirements for "noticing entities" and data reporting requirements for MSOs?
- How will SB 351's prohibitions impact hedge funds' and PE groups' investments in California healthcare entities?
- What should counsel be doing to review current and proposed MSO arrangements for compliance?
