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OGE Amends Executive Branch Ethics Program

Client Alert | 1 min read | 11.07.16

On November 2, 2016, the Office of Government Ethics issued a final rule amending the regulations setting forth the elements and procedures of the executive branch ethics program by defining and describing the executive branch ethics program, delineating the responsibilities of various government stakeholders, and enumerating key executive branch ethics procedures. Among the various amendments, which are detailed in our blog post, the final rule centralizes the procedures of the executive branch ethics program and modifies the procedures for the correction of agency noncompliance by outlining several remedial actions that may be taken.

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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....