Q1 Recap on Proposed Legislation Affecting Healthcare Consolidation

As predicted in Holland & Knight’s year-end 2025 report, the first quarter of 2026 has seen a wave of newly proposed legislation by states that seek to broaden their review of healthcare consolidation. The focus has shifted from private equity to all stakeholders, including real estate investment trusts (REITs), management services organizations (MSOs) and health insurers. States have also revisited the corporate practice of medicine (CPOM) doctrine and, in a new turn of events, considered private rights of action for violations. However, despite the momentum earlier in the year, as of publication of this Holland & Knight alert, more state bills have failed to progress than have successfully been enacted.

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Source: https://www.hklaw.com/en/insights/publications/2026/03/q1-recap-on-proposed-legislation-affecting-healthcare-consolidation

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