Health Law Advisor

On October 11, California Governor Gavin Newsom signed AB 1415, which regulates private equity and hedge fund activity by expanding the Office of Health Care Affordability’s (OHCA) jurisdiction and notice requirements. Though the law is a compromise from last session’s AB 3129—which the Governor vetoed on September 28, 2024—it nevertheless represents a significant change for private equity groups, hedge funds, and management services organizations (MSOs) in the state.

On October 6, 2025, California Governor Gavin Newsom signed SB 351, aimed at limiting the involvement of private equity groups and hedge funds in health care practices. While the new law does create new statutory requirements governing hedge fund and private equity group involvement in the management of physician and dental practices, those requirements largely reflect existing California case law and Medical Board of California guidance. Specifically, the new law:

• prohibits a private equity group or hedge fund that is involved—including as an investor or owner—with a physician or dental practice doing business in the state, from interfering with the professional judgment of physicians and dentists in making health care decisions;
• prohibits these entities from exercising power over specified actions, including hiring practices and coding and billing procedures for patient services, and
• prohibits contracts between a private equity group or hedge fund or an entity controlled by a private equity group or a hedge fund and a physician or dental practice, if the contract would allow the conduct described above or impose a noncompete or nondisparagement clause.

The law will take effect on January 1, 2026. The state attorney general is empowered to enforce the new law through injunctive relief and other equitable remedies. It is the latest in a national trend among states to strengthen corporate practice of medicine (CPOM) doctrines by limiting the influence of non-licensed entities in clinical decision-making. The bill, introduced by California State Senator Christopher Cabaldon, passed the state legislature in September with bipartisan support.

Recently, the California Legislature made a series of major revisions to Assembly Bill 3129 (“AB 3129” or “the Bill”), a highly anticipated piece of legislation expected to have a substantial impact on transactions in California’s healthcare space.  Although Epstein Becker Green has previously discussed the Bill (see original post here, as well as a first update here), this blog post will discuss the legislature’s most recent revisions on June 19 and June 27.

Why Assembly Bill 3129 Was Introduced

The Bill was introduced by Assembly Member Wood and is supported by Attorney General Bonta in response to growing concerns about the increasing involvement of private equity and hedge funds in California’s healthcare sector. As private equity firms have increasingly acquired healthcare facilities and provider groups, California’s legislature wants to strengthen oversight to ensure that these transactions are conducted in a transparent manner that protects patients, ensures access, and preserves affordability.

What the Bill Will Do

AB 3129 seeks to address these concerns by requiring private equity groups and hedge funds to provide written notice to, and obtain the written consent of, the Attorney General before engaging in any change of control or acquisition involving healthcare facilities, provider groups, or nonphysician providers. This includes changes of control, acquisitions, or agreements that may impact healthcare services or access.