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OCA reports first year of cost and market impact review notices: 16 transactions, all waived so far
Summary
OCA summarized the first year of notices under its cost and market impact review (CMIR) program. Since the statutory 90‑day notice requirement began on April 1, 2024, staff received 16 transactions (26 prefiling meetings) and have waived the reviews to date; no comprehensive CMIR has been ordered.
Assistant Deputy Director Sheila Pattayan reported an operational update on OCA’s cost and market impact review (CMIR) program and described the first year of activity under the April 1, 2024 statutory notice requirement.
Key statistics and findings
Pattayan said that between April 1, 2024 and the end of December 2024 the office received notices for 10 transactions (16 submitters) and, since January, has received six additional transactions (10 submitters), for a total of 16 transactions to date. Staff conducted 26 prefiling meetings during the first year to help submitters prepare complete filings. Pattayan said, “April 2025 marks a year since we began our program of accepting notices of material change transactions.”
Types of transactions and outcomes
The transactions have been varied; staff reported a plurality of skilled nursing facility (SNF) acquisitions, plus lab transactions, physician organization transactions, combined plan‑and‑physician transactions, and at least one federally qualified health center (FQHC) transaction. For each complete filing, staff applied nine statutory factors to decide whether a full CMIR was required.
To date, OCA has issued waivers for every transaction reviewed and has not ordered a comprehensive CMIR. Pattayan explained staff’s process: filings are posted once deemed complete; during the 45‑day review window staff may request additional information and stop the clock; staff works with other state agencies (for example CDPH, DHCS, DMHC and the Attorney General) and uses public monitoring and tips to identify potentially reportable transactions.
Engagement and enforcement practice
Pattayan noted that some transactions are complex and involve multiple corporate layers, single‑purpose acquisition entities and foreign investors; staff is identifying submitters and ownership chains to ensure full reporting. Staff also said it follows up when it learns of a transaction that appears within jurisdiction but has not been filed; that outreach has produced additional submissions or referrals to other regulators.
Next steps
OCA will continue its intake and review process, post complete notices to the website, and continue coordination with other agencies when jurisdictional questions arise. Staff will publish additional notices and continue to use prefiling engagement to improve filings' completeness.
Ending
Pattayan framed the first year as a period of operational startup and problem solving: staff has focused on outreach, filing completeness and interagency coordination while applying statutory criteria to determine when a full CMIR is needed.
