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Heads Up! CFATS Requirements Reinstated

Client Alert | less than 1 min read | 11.09.16

DHS reinstated the requirement that facilities that manufacture, use, store, or distribute certain amounts of designated high-risk chemicals submit reports (called “top screens”) to DHS within 60 days and is also requiring facilities that previously submitted top screens to submit new ones using the recently released Chemical Facility Anti-Terrorism Standard (CFATS) Top Screen tool. Earlier this year, DHS had suspended the regulatory requirement imposed on covered facilities to submit top screens while it developed a new CFATS tiering methodology for assessing risk.

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Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....