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In with the New: Trump Freezes Pending and Non-Issued Obama-Era Regulations

Client Alert | 1 min read | 01.23.17

On January 20, 2017, President Trump's Chief of Staff Reince Priebus issued a memorandum to the heads of the executive departments and agencies calling for a regulatory freeze pending review – a practice that is relatively routine for new incoming presidential administrations. Specifically, the memorandum prohibits agencies from sending any regulation to the Office of Federal Register (OFR) prior to review and approval; requires agencies to immediately withdraw unpublished regulations for review and approval; and mandates that agencies temporarily postpone the implementation of published, but not yet effective, regulations for 60 days. Regulations subject to statutory or judicial deadlines are excluded from the aforementioned actions, but agencies must timely identify them to the OMB Director. Agencies also may identify regulations they believe should not be subject to the aforementioned procedures, namely those affecting "critical health, safety, financial, or national security matters, or for some other reason."

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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....