MCN & CMIR FAQs

AB 1415 Frequently Asked Questions (FAQ)

1. When does Assembly Bill (AB) 1415 become effective?

AB 1415 becomes effective January 1, 2026.

2. Where can I find a copy of the new law?

You can find a copy of the text of the new law at https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB1415.

3. What new entities are required to provide OCHA with notice of transactions under the new law?

In addition to health care entities under existing law, AB 1415 will require the following additional entities to file notices of material change transactions with OHCA:

  • Private equity groups.
  • Hedge funds.
  • Newly created business entities created for the purpose of entering into agreements or transactions with a health care entity.
  • Management services organizations.
  • Entities that own, operate, or control a provider, regardless of whether the provider is currently operating, providing health care services, or has a pending or suspended license.

4. Do these new entities have to file notice of material change transactions with OHCA before OHCA issues amended regulations? 

Yes. Until regulations are enacted to specify the information required in notices to OHCA, noticing entities must provide, at a minimum, “written notice” of the transaction under Health and Safety Code section 127507(c)(2)(A). (Health & Saf. Code, § 127507, subd. (h)(1)-(h)(4) [defining noticing entities].) If any of the parties to or subjects of the transaction are health care entities, notice to the Office is presently and will continue to be required after January 1, 2026. 

5. How far in advance of a transaction’s closing will these new entities have to provide notice of the transaction to OHCA?

Existing statute and regulations require health care entities that are a party to or the subject of a transaction to file with OHCA at least 90 days before the closing date of the transaction.  (Health & Saf. Code, § 127507, subd. (c)(2); Cal. Code Regs., tit. 22, § 97435, subd. (a).) OHCA intends to enact regulations that establish the same filing timelines for noticing entities to provide notice to OHCA.

6. When does the Office of Health Care Affordability (OHCA) intend to enact regulations to implement the new law?

OHCA plans to enact regulations to implement the new law by Spring, 2026.

7. How can I comment on any regulatory amendments before these regulations are enacted?

Please sign up for notifications for OHCA Health Care Market Oversight updates on text and hearings on our website (https://hcai.ca.gov/mailing-list/).

8. Who can I contact if I have any questions about AB 1415 and my transaction?

Please contact OHCA at CMIR@hcai.ca.gov.