New healthcare private equity reporting requirements set to go into effect

There are those who doubt P.E. can save health care.

1. It removes physicians from most control, who they hire, what insurance plans to accept,

P.E. gained a lot of ground in the past five years. However pushback is growing.  Here are some of the specifics.

New healthcare private equity reporting requirements set to go into effect

With the new year comes a host of new regulations at the both the federal and state level that will impact the way healthcare is delivered in America. 

In 2025, seven states passed some sort of new reporting requirement, or other restrictions, on private equity investments in healthcare. For context, only one state passed a bill to add oversight to private equity activity in 2024—that being Indiana. 

There were also 14 proposed bills that failed to pass in 2025, though many could find traction in the future.

Below, HealthExec takes a look at three of the new state laws that we think will be especially significant to business operations moving forward. Each could be a sign of what’s to come nationwide.

Massachusetts pioneers reporting

Early in January 2025, Massachusetts Gov. Maura Healey signed H 5159 into law, officially referred to as “An Act enhancing the market review process”—in this case, meaning private equity activity. In a statement, the governor said the law would “increase oversight of the healthcare industry to protect patients and providers.”

As Saran noted in a publication on his firm’s website, used to guide clients in compliance efforts, Massachusetts was the first state to take such a leap. While other states have their own regulations on healthcare transactions that involve investment firms, Massachusetts was the first to specifically mandate comprehensive reporting, with the stated goal of improving public and regulatory oversight of private equity involvement in healthcare, be it provider clinics or hospitals. 

In speaking to HealthExec, Saran said the state has had some transaction review process for “more than a decade,” but this new bill brings substantially more oversight, as it requires healthcare entities to report detailed information about all private equity investments, including the involved parties, financial details, and projections on what impact the new ownership stake or influx of cash is expected to have on the price of services, patient care capacity and staffing. 

Ideally, this additional insight into what’s happening would make it easier for regulators to intervene if there’s any potential risk to the public. The new law is a direct reaction to the bankruptcy of Steward Health Care, which many associate with high debt and financial mismanagement, worsened by private equity ownership. 

When signing H 5159, Gov. Healey mentioned Steward by name:

“As Attorney General, I spent years in court trying to hold Steward to this standard, and I’m glad that our laws will no longer be exploited in this way,” she said. “I’m grateful for the strong leadership of Speaker Ron Mariano, Senate President Karen Spilka, and the Legislature for advancing these bills that will strengthen our healthcare system, lower costs, and protect patients and providers.”

However, in pre-filed written testimony, the Massachusetts Massachusetts Health Policy Commission received warnings not to conflate all investments in healthcare with what happened at Steward, as many hospitals and practices need funds for upgrades and expansion plans that will ultimately benefit patients.

“Significant private equity investors shared their belief that investments in the Massachusetts healthcare system increase technological innovation, reduce administrative workloads to boost efficiency and provide access to much-needed capital funds,” Sara noted in his post. 

He told HealthExec that the Massachusetts Health Policy Commission could use the new reporting data to study the impacts of healthcare consolidation, without the state necessarily halting private equity activity in healthcare.

As for what measurable impact the law will have and how regulator behavior will shift, that remains to be seen. 

Oregon targets MSOs

Of new state laws passed last year, Oregon took the most specific steps toward restricting how corporate entities—as opposed to licensed clinicians—may invest in and control healthcare entities in the state. 

Passed in June 2025, SB 951 and HB 3410A regulate how management services organizations (MSOs) interact with physician practices and impose specific rules on payer contracting, billing, and governance models. In short, the laws limit how much control these third-parties can have over physicians, with the stated aim of protecting the independence of medical practices.

Private equity firms often use the MSO companies to invest in healthcare practices, including physician-owned clinics and medical groups. So, in a sense, the new law is targeting them directly. These operations support groups now face tighter regulations, limiting how they can interact with practices under their umbrella, for which they provide services such as patient billing and payer claims submissions. 

A shakeup could make it harder for private equity firms to structure profitable deals in Oregon. And indeed, Saran noted that the state is now “one of the highest-risk states in the country for [a potential violation of this new corporate practice of medicine law] and likely an outlier for national platforms.”

However, he told HealthExec, private equity activity in the state is likely to continue—it’s just that firms and investors will have to be careful to stay within the bounds of the law. The state already has the authority to block transactions, but has so far been allowing most to go through, albeit with some additional review from the Oregon Health Authority.

“If they start denying transactions and they start snagging up national transactions, I think that could change,” he said. “I think what private equity has looked at recently is the change in the corporate practice bill that was passed this year, after a few years of bouncing around in the state.”

Saran said that SB 951 and HB 3410A—which go into effect on January 1, 2026—will require a change in plans from some firms, as well as shifting of assets to ensure compliance. And in some respects, this will mean national agreements that involve practices in Oregon may have to make specific carve-outs to appease the state. 

“It's not as simple as saying, ‘ok, we’ll maybe update some agreements and nothing really changes in practice,’” he stated. “You have to look at everything and see what divestments are necessary—not full divestment, but compliance might require moving around some ownerships and directorships, and [changing] certain contracts, and all that.”

“The standard model that is used across the country needs to be now tweaked for Oregon specifically,” Saran clarified. 

California treats firms like stakeholders 

In October 2025, Gov. Gavin Newsom signed AB 1415 and SB 351 into law, both of which will impact how private equity companies, hedge funds and other investors operate in the state when making healthcare deals. 

AB 1415 expands the Office of Health Care Affordability’s (OHCA) authority to oversee financial deals that affect healthcare delivery, with special emphasis on MSOs. Such groups will be required to submit reports on their activity aimed at improving transparency into their business practices. 

In particular, the state is taking an interest in how investments flowing through MSOs will impact the price of patient care. 

“The law imposes broader reporting requirements for MSOs and directs the OHCA to adopt future regulations and guidelines to eliminate duplicative reporting,” Saran wrote. “The rulemaking process is underway, and the regulations are expected to become final in spring 2026.”

Building off this, SB 351 expands California’s corporate practice of medicine limitations, with emphasis on keeping healthcare decisions in the hands of doctors. Specifically, it requires that only licensed physicians make certain patient care-related decisions and limits how much influence investors can have on day-to-day operations. 

Saran said that much of this is consistent with what California regulators were already doing—SB 351 merely codifies a lot of corporate practice of medicine doctrine into law. He said a lot of this may be redundant, as investors were already complying with the status quo.

“Before this was signed into law, California had one of the strictest corporate practice of medicine regimes and there was active enforcement of it,” he told HealthExec. “So it's not like California was a Wild West where there's no law, there's no enforcement. They had all that.”

He noted a series of lawsuits filed against the state by investors and physicians alike, who think regulators were overstepping their constitutional bounds, long before SB 351 passed. 

What has changed is that laws governing stakeholders now include private equity investors. Meaning, if health systems are making acquisitions or merging, it matters to the state who their investors are. Firms could potentially run afoul of antitrust laws if they’re not careful. 

“One thing I tell private equity sponsors is, this is one of the first times that you have this direct line from regulator to the private equity sponsor. They are now focused directly on you all and what you do,” Saran said. 

“What do your relationships and level of control look like with physicians and dental practices?” he added, referencing how these new laws will make it easier for OHCA to develop future regulations as the report details roll in. 

For more, including details on what Maine, New York, Rhode Island and Texas are doing, read Saran’s full article by clicking here. 

New healthcare private equity reporting requirements set to go into effect