OCA reports transaction trends under Cost and Market Impact Review program; skilled‑nursing and lab deals spike

The Office of Health Care Affordability's compliance team told the advisory committee on June 16 that California's Cost and Market Impact Review (CMIR) program has received rising transaction notices since its April 1, 2024 launch and that certain transaction types—especially skilled‑nursing facility and laboratory acquisitions—have become more frequent. Bridal Kearns, assistant chief counsel for OCA's compliance division, summarized activity: the program handled 10 transactions in 2024 with 16 material change notices and 26 pre‑filing meetings, and continued activity into 2025 with at least six transactions and 10 notices already filed. To date the agency said it has issued waivers for all notices reviewed but remains actively monitoring the market. Monitoring approach and public tips: OCA described a market surveillance approach that includes public reporting, interagency coordination and a CMIR inbox for tip‑offs. Staff said they have investigated transactions that appeared not to have been filed and have sent inquiry letters when filings appeared required; at least one inquiry spurred a later filing. Types of deals and examples: The slideshow listed a range of recent filings and transactions—buyers included corporate operators and national chains—and highlighted multiple skilled‑nursing deals, acquisitions of clinical laboratories (Quest Diagnostics, Laboratory Corporation of America / BioReference), and transactions involving provider groups and county health entities. Several filings were under active review at the time of the presentation. Why it matters: The CMIR program is designed to identify transactions that may adversely affect cost, quality, equity or access by increasing market concentration. OCA staff noted that comparable agencies (Massachusetts Health Policy Commission; Oregon Health Authority) have conducted relatively few comprehensive reviews despite many filings, and that CMIR reviews are therefore uncommon but important when market facts warrant deeper analysis. What the committee asked: Members asked about public resources (flowcharts, FAQs) and how OCA evaluates complex ownership chains; staff emphasized that submitters are asked to provide organizational charts and ownership flows and said those charts have been instrumental to their assessment work. What's next: OCA staff said they will continue outreach, refine guidance and use public leads to identify potential non‑filings. The agency encouraged public messages to cmir@hca.ca.gov when community members suspect a transaction should have been filed.