STATE LEGISLATIVE UPDATE

TABLE OF CONTENTS

SECTION 1: ANTITRUST AND MERGER REVIEW
Merger Review and Approval
Merger Notification
Certificate of Need
Other

SECTION 2: RATE REGULATION AND COST CONTROL
Benchmarks and Caps
Facility Fees and Site Neutrality
Transparency

SECTION 3: PROVIDER CONTRACTING AND NONCOMPETE CLAUSES
Insurer Imposed Conditions
Health System Imposed Conditions

SECTION 4: HEALTHCARE SYSTEM REFORM

SECTION 5: MISCELLANEOUS
Private Equity/Corporate Practice of Medicine
Fiduciary Duties/Third Party Administrators
Artificial Intelligence
Other

Downloadable PDF

Key Enacted Legislation 2025

Connecticut – HB05398 expands the types of healthcare transactions that require review by the Attorney General, and allows the Attorney General broader equitable relief options, including restitution, disgorgement, and voluntary compliance agreements. The bill also requires hospitals to include the actual cost of goods and services alongside their charges in their publicly available price lists.

Hawaii – SB3175 requires healthcare entities to provide 180 days’ notice before mergers, acquisitions, or other consolidation, including information on market share, pricing, and impacts on access to care. The state would then review to see if the transaction is in the public interest. For vertical transactions, where entities at different levels of the healthcare supply chain merge, legislative approval would be required if the combined entity would control at least 25% of a market and would be expected to significantly increase prices or premiums.

Illinois – SB1998 would require healthcare facilities or provider organizations to notify the AG at least 30 days before any mergers or new affiliations. The bill adds that the AG must provide written consent if a private equity group is providing financing for the transaction. The AG would be given power to investigate the transaction.

Massachusetts – H1355 would expand the Health Policy Commission’s authority to review and potentially block mergers, acquisitions, and expansions by healthcare organizations. Entities that have exceeded cost growth benchmarks would be required to file performance improvement plans. Previously approved material changes would be reviewed annually to determine if lower costs and improved quality have been achieved.

Massachusetts – H3947 creates a requirement that before the state insurance commissioner can approve mergers of health-related insurance and service organizations, (1) the merger agreement must be on file with the division for at least 60 days, (2) copies of the agreement must be provided to several state agencies, and (3) a public hearing must be held if requested by any of the named state agencies or at least 10 Massachusetts taxpayers.

North Carolina – S532 would establish the Preserving Competition in Healthcare Act. The bill would require notice to the State Auditor, AG, and State Treasurer before hospital entities could engage in any sale, transfer, or change of control of assets worth more than $5 million. Proposed transactions would be jointly reviewed, which would include public hearings, and would be evaluated on patient access, community benefits, potential conflicts of interest, and potential effects on healthcare providers. Reviewing officials can file a legal action to block or modify any deals found to be objectionable. Additional scrutiny would be imposed on deals involving nonprofit or publicly owned hospital to ensure community benefits are protected.

New York – A06056 would require healthcare providers looking to engage in mergers and acquisitions to be evaluated by the Public Health and Health Planning Council to determine if the transaction would improve access to medical care for underserved individuals, lower costs, and advance public health goals. For five years after the transaction, approved providers would be prevented from raising charges beyond the medical care consumer price index, and would have to submit annual reports showing how the merger has improved prices, outcomes, or efficiencies.

Pennsylvania – HB1460/SB322 requires healthcare entities to obtain state approval before engaging in sales, transfers, leases, or changes in control of healthcare facilities. Proposed transactions would be evaluated to see if they reduce competition, increase costs, diminish care, or limit access. The AG would be allowed to block or impose conditions on transactions deemed against public interest, and can establish a monitoring period of up to five years to ensure compliance.

Pennsylvania – SB708 would require healthcare facilities to notify the AG before entering into mergers, acquisitions or substantial asset transfers. The AG would be empowered to conduct public hearings, request additional information, and potentially enjoin transactions deemed against the public interest.

Pennsylvania – HB1266 would require potential hospital acquirers to provide detailed information to the Department of Health, who would approve or deny acquisitions based on whether they will maintain accessible and affordable healthcare for local communities. The bill also requires monitoring of acquisitions for at least 10 years to ensure any commitments made during the approval process were upheld.

Pennsylvania – HB2115 requires healthcare entities involved in material changes (including mergers, acquisitions, or affiliations) to notify the Attorney General at least 120 days in advance. The Attorney General will investigate transactions for potential anticompetitive conduct and consumer harm. The AG can potentially seek injunctions, divestiture of assets, and civil penalties.

Rhode Island – H7720/S2492 requires healthcare entities that meet minimum requirements to provide 180 day notice to the state before any material change transactions, including mergers, acquisitions, changes in control, significant real estate deals, or the closure of facilities or essential services. The Attorney General and Department of Health will then conduct a review, which may include public hearings and a “cost and market impact review” to assess the transaction’s effects on competition, prices, quality, access, workforce, and health equity in Rhode Island, and will have the authority to approve, approve with conditions, or deny the transaction, and can impose conditions such as pricing controls or maintaining essential services.

Washington – SB5704 would require parties to a healthcare material change transaction to submit detailed notices that assess potential impacts on community health services. Public hearings would be required, and the AG would have the ability to approve, modify, or disapprove transactions and to impose penalties for non-compliance. The bill would require ongoing monitoring for five years after the transaction.

Washington – HB1881 requires parties to a healthcare marketplace material change transaction to provide detailed notice to the state at least 90 days before the transaction. The state will engage in a review process that includes public hearings and an in-depth assessment of potential impacts on healthcare services, and establishing ongoing monitoring of transactions for five years after completion. If it is determined that the transaction could harm accessibility or quality, conditions can be imposed, including modifications, or outright disapproving the transaction entirely.

Colorado – SB041 allows the Attorney General to review mergers and acquisitions of healthcare entities (including hospitals, urgent care facilities, ambulance services, pharmacies, and other licensed medical providers). These material change transactions require 60 days’ notice to the AG, and prohibits transactions that could substantially reduce competition, create a monopoly, or harm consumer welfare. It also allows the AG to challenge transactions involving nonprofit hospitals if they would would materially alter these missions or lead to the transfer of charitable assets out of state.

California – SB25 would require any business already required to submit a Hart-Scott-Rodino premerger notification with the federal government to also file a copy with the California AG, if the business has their principal place in business in the state, or annual net sales in California at 20% or more of the federal filing threshold.

Hawaii – SB348 establishes a Uniform Antitrust Pre-Merger Notification Act, requiring businesses to file copies of their Hart-Scott-Rodino (HSR) pre-merger notification forms with the AG, if their principal place of business is in the state, or if they meet minimum in state sales requirements.

Indiana – SB0219 enacts the Uniform Antitrust Pre-Merger Notification Act. This requires entities to file an electronic copy of their federal Hart-Scott-Rodino Act pre-merger notification forms with the Indiana Attorney General.

Maine – LD2202 requires notification to the state Attorney General before healthcare entities can merge or be acquired if minimum thresholds are met.

Massachusetts – H3947 would create new requirements for healthcare insurance and service organization mergers. The bill would require specific conditions to be met before the state insurance commissioner can approve the merger, including that the merger agreement must filed with the state 60 days prior, and a public hearing will be held if requested by various state agencies or at least 10 state taxpayers.

Vermont – H0071 prevents corporations from interfering with the clinical judgement of medical professionals, and prevents non-medical entities from controlling medical practices. It also requires healthcare entities to inform the state before any material change transaction (mergers, acquisitions or partnerships) of over $1 million or more. The bill would also require physicians to have majority ownership and control of medical practices, and would void any non-competition and non-disclosure agreements that could restrict rights.

West Virginia – SB147 enacts the Uniform Antitrust Pre-Merger Notification Act, requiring entities to file an electronic copy of their federal Hart-Scott-Rodino Act pre-merger notification forms with the West Virginia Attorney General.

Alabama – SB82 would remove the certificate of need requirement for new or expanded healthcare facilities and services located in rural areas.

Connecticut – HB05045 creates a three-person panel (the Commissioner of Public Health, the Secretary of the Office of Policy and Management, and the Commissioner of Social Services) to make final certificate of need application decisions.

Florida – H0693 is a comprehensive health services bill, which, among other things, would repeal the state’s Certificate of Need program.

Hawaii – HB11 would eliminate the certificate of need requirement for most health facilities and services, with the exceptions of nursing homes, hospices, intermediate care facilities, and ambulance services.

Iowa – HF224 would eliminate certificate of need requirements.

Maryland – SB494/HB944 repeals an existing Certificate of Need exemption for certain mergers. Material change transactions would now require advance notice to the state, who would conduct a review to determine the impact on cost, quality, access, and equity of healthcare services.

Missouri – HB1637 would repeal the existing Certificate of Need law.

North Carolina – H455 would repeal the state’s certificate of need laws.

North Carolina – S370 would repeal the state’s certificate of need laws.

Nebraska – LB437 would repeal the Nebraska Health Care Certificate of Need Act.

Rhode Island – H7143 repeals the states certificate of need process, meaning that providers won’t need state approval to acquire new major medical equipment or offer new services.

Rhode Island – S2865 repeals the “Certificate of Need” process, meaning that healthcare providers would no longer need this prior approval from the state to acquire new equipment or offer new services.

Virginia – SB239 will direct a Task Force to identify areas medical deserts in the state, and to propose criteria for when projects in these areas should get an expedited CON review.

West Virginia – HB4917 would terminate the West Virginia Health Care Authority and its certificate of need program, meaning that after January 1, 2027, healthcare facilities would no longer need a certificate of need to operate. The Authority would also no longer review and approve collaborative agreements between healthcare providers.

Mississippi — SB2560 repeals the state’s Health Care Certificate of Need Law.

Alabama — HB605/SB350 the Rural Health Antitrust Immunity Act would allow rural healthcare entities and individuals to collaborate and share services, even if these activities might otherwise be considered anti-competitive under state and federal antitrust laws, including joint purchasing, shared staffing, and coordinated service development.

California — AB1776 amends California’s antitrust law (the Cartwright Act) by changing the definition of a “trust” from acts by “two or more persons” to “one or more persons”, explicitly recognizing single-firm anticompetitive actions in state law.

Florida — H1047/S1122 allows two or more special hospital districts to jointly create, participate in, and manage various ventures, partnerships, or collaborations, including business entities or service networks, protected from both state and federal antitrust laws. In Florida, special hospital districts are tax-payer funded entities authorized by the state government to provide healthcare services. The bill also states that providing quality and cost-efficient medical care is a public necessity.

Massachusetts — S873 requires hospitals to provide 180-day advance notice before closing or discontinuing essential health services.

Minnesota — SF2025 establishes the Fair Competition Act to address anti-competitive business practices by prohibiting the establishment or maintenance of monopoly or monopsony power that affects competition or controls prices. The bill broadens the scope of existing antitrust law by creating new legal standards for price fixing, market allocation, and collusive practices. The bill also creates a prohibition on unconscionably excessive prices (defined as prices 10% above recent market rates) and a ban on price discrimination that could potentially lessen competition or create monopolistic conditions.

Missouri — SB1602 allows the Board of Curators of the University of Missouri to own or operate healthcare facilities and to acquire entities or assets involved in providing health care services with immunity from federal and state antitrust laws for the University in 25 enumerated counties.

New York — A02015/S00335 would significantly expand existing New York anti-trust laws. The definition of monopolistic and anti-competitive practices would be amended to include unilateral actions by dominant firms that harm market competition. The bill also would make it easier to establish a company’s dominant market position, including presumptions based on market share and allowing direct evidence of market dominance. The bill would also require notification to the AG when companies are involved in significant mergers.

New York — A09225 prevents any entity from simultaneously owning or controlling both a health insurance company and a health care provider in the state.

Oklahoma — HB1415 would expand who can bring an antitrust lawsuit by allowing for claims for injuries that are direct or indirect. The Attorney General would be empowered to bring civil actions on behalf of the state, governmental entities, or residents.

Pennsylvania — HB1371 prohibits anticompetitive practices, creating antitrust regulations that allow the Attorney General to take action against entities engaged in activities that restrain trade, monopolize markets, or create anti-competitive mergers. Health care facilities, health care systems, and provider organizations would have to provide premerger notifications to the Attorney General. Others that suffer damages from anticompetitive practices can bring civil actions, and the law allows for class action lawsuits.

Pennsylvania — SB754 establishes comprehensive requirements for hospitals planning to close all or a significant portion of their operations. Hospital authorities would be required to obtain approval from the Attorney General and either the state or local health department before closure, to ensure that patient care continuity and community health needs are adequately addressed.

Pennsylvania — SB785 creates the “Pennsylvania Open Markets” comprehensive antitrust law. The law would prohibit contracts that restrain trade and require premerger notification for certain healthcare transactions. Both the AG and private parties could bring actions for antitrust violations, with remedied including damages and injunctions.

Tennessee — SB2496 prohibits hospitals from entering into anti-competitive agreements or engaging in anti-competitive conduct with other hospitals in the state, and declares the Certificate of Public Advantage program was a failed economic experiment, and that healthy competition among hospitals is now considered to be in the best interest of the public and aligns with the Tennessee Constitution.

Vermont — H0719/S0249 allows health systems to collaborate on cost containment, improving access to care, enhancing quality, or preserving rural hospitals, with immunity from antitrust lawsuits if the collaborations follow specific state oversight procedures. Sharing cost, utilization, workforce, and quality data among collaborating parties would not be considered a violation of antitrust law.

Washington — HB2548/SB6208 requires hospital systems or provider organizations engaging in mergers, acquisitions, or contracting affiliations to notify the Attorney General at least sixty days prior. Additionally, the law would require the Secretary of State revoke the nonprofit status of a healthcare entity if it converts to a for-profit or unincorporated entity through a material change transaction.

California — AB1345 expands the definition of anticompetitive practices under the Cartwright Act, making it unlawful for one or more persons to take actions that restrain trade, impede free competition, or attempt to monopolize or monopsonize trade or commerce.

Delaware – SB213 amends the state’s Hospital Budget Review Act to allow hospitals with global budget agreements covering at least 50% of their patient volumes to be exempt from certain benchmark compliance processes. Hospitals exceeding the state’s healthcare spending benchmark may be required to submit a compliance plan.

Illinois – HB5301/SB3770 creates the Global Hospital Budget Authority within the Department of Public Health, responsible for implementing a global budget model for hospitals, where participating hospitals receive a prospectively set annual budget for eligible services. The bill also creates stricter oversight for changes in hospital ownership, especially those involving private equity, requiring disclosures, community health impact assessments, and potentially imposing conditions on transactions.

Illinois – SB3900 creates the Illinois Health Care Cost and Payment Board, charged with setting standardized reimbursement rates for hospitals across all payers, and to establish prospective annual global hospital budgets.

Maine – LD2196 creates limits on hospital prices, capping annual growth in hospital facility prices to match the Medicare inpatient prospective payment system market basket, and limits the maximum a hospital can charge for inpatient or outpatient services to 200% of the Medicare rate for that service, with exceptions for financially distressed hospitals or those not complying with utilization review and prior authorization requirements. The bill also streamlines prior authorization for chronic conditions, and mandates that health insurance carriers provide detailed financial information, including utilization and payment trends by category and hospital, in their rate filings, and requires that the minimum negotiated rate for in-network primary care and behavioral health services be at least 110% of the Medicare rate for similar services.

Illinois – SB3900 creates the Illinois Health Care Cost and Payment Board, charged with setting standardized reimbursement rates for hospitals across all payers, and to establish prospective annual global hospital budgets.

Maryland – HB616/SB515 requires the Health Services Cost Review Commission to include costs associated with employing or contracting with physicians and other professional providers, in addition to hospital services, when reviewing costs and rates for hospital services.

Massachusetts – H1376 would create a cost growth benchmark, setting a target for annual increases in healthcare spending. The total assessed amount for a variety of healthcare entities could not increase at a rate higher than the benchmark approved by the Health Policy Commission.

Massachusetts – H1361 would allow the Health Policy Commission to implement performance improvement plans from healthcare entities that exceed spending benchmarks. The state would also perform an analysis of healthcare spending, referring entities with excessive spending to the Commission. The commissioner would also get authority to review rates, and have authority to approve, modify, or disapprove rates that appear excessive, inadequate, or unfairly discriminatory.

Massachusetts – H1372/S905 creates the Weighted Average Payer Rate – a calculation that determines inpatient and outpatient revenue per discharge/visit for different types of payers. Requiring reporting on the index is intended to increase transparency, and the state’s healthcare commission would be required to hold annual public hearings on healthcare expenditure growth, costs, payment systems, and delivery systems.

Massachusetts – S2047 reforms the state’s healthcare cost benchmark in Massachusetts by creating a new definition of “historical growth rate in gross state product” as the average annual growth rate of the gross state product measured over a ten-year period.

Massachusetts – S904 modifying how the state’s Health Policy Commission is able to address excessive healthcare spending. Entities that have been identified as exceeding the cost growth benchmark may be required to develop a performance improvement plan to reduce spending. If the entity fails to implement the plan in good faith, civil penalties can be imposed.

Massachusetts – H1384 creates a three-year benchmark cycle to monitor healthcare expenditure growth. Entities that exceed the benchmark would be required to develop performance improvement plans, with civil penalties for repeated violations.

Massachusetts – H3196 changes the calculation of the healthcare cost growth benchmark, using a new standard that ties the benchmark to the historical growth rate of the gross state product.

Minnesota – SF622 allows insurance carriers to offer reference-based pricing health plans, where the carrier sets a predetermined rate for services based on a percentage of Medicare rates, rather than negotiating separately with providers. Providers would decide if they wanted to accept the specified rate, and would not be required to participate in a reference-based plan.

New Jersey – S3012 creates a new state entity to collect and analyze data on healthcare expenditures and prices and make the information publicly available. The bill would create a Health Care Cost Containment and Price Transparency Commission to set benchmarks for overall healthcare cost growth and hospital price growth. The Commission would identify entities that exceed these benchmarks, and could issue civil penalties.

New York – A01915/S01634 requires health insurance plans to spend at least 12.5% of their total healthcare expenditures on primary care services, but spending shifts cannot result in higher premiums or increased cost-sharing. The legislation also contains guidelines for increasing primary care investments, including improving reimbursement rates, building provider capacity, upgrading technology, and implementing value-based payment arrangements.

Oklahoma – SB787 limits payments for hospital services to either 200% of Medicare/Medicaid rates or the median amount paid by health benefit plans, whichever is less. Providers could not charge patients more than authorized cost-sharing amounts. Insurance rate filings would be reviewed for affordability, and the ability of lower-income individuals to pay for health insurance.

Rhode Island – S3091 requires uncompensated care to be included when setting rate caps or affordability standards for hospital contracts, ensuring that the uncompensated care burden is converted into a percentage applied above the established rate cap.

South Carolina – H3302 prevents insurers from charging higher out-of-pocket rates for emergency services from out-of-network providers compared to in-network services and would require reimbursement of out-of-network providers at either the in-network rate, the usual and customary rate, or the Medicare reimbursement rate, whichever is greatest. The legislation would define surprise billing as an unfair trade practice.

Tennessee – SB2036 requires health insurance entities to annually increase their in-network provider reimbursement rates and annual benefit maximums by at least the rate of inflation, capped at 4% annually unless the commissioner of commerce and insurance approves otherwise.

Vermont – H0245 expands the Green Mountain Care Board’s existing hospital budget review powers to include optional review of budgets for health networks – systems comprising two or more affiliated hospitals with integrated financial and governance structures. The bill also requires budget reviews to consider factors like administrative costs, workforce development, and executive compensation.

Vermont – S0055 directs the Green Mountain Care Board to develop a plan for implementing reference-based pricing for hospital services – where prices for medical services are based on a percentage of Medicare rates.

Vermont – S0190 requires hospital and insurer contracts to express rates as a percentage of Medicare or some other approved benchmark. Additionally, hospitals would be required to use unique National Provider Identifiers for off-campus departments to improve billing accuracy. The bill would also bring outsourced clinical services under the Green Mountain Care Board’s purview.

Vermont – H0553 requires hospitals to hold public hearings at least 30 days before submitting their proposed budgets to the Green Mountain Care Board, which is the state agency responsible for overseeing healthcare costs and access. The Green Mountain Care Board would also be given the authority to direct hospitals to coordinate or align their administrative functions with other hospitals to improve efficiency and reduce administrative expenses.

Washington – HB2283/SB5953 requires health insurance plans to spend at least 90 percent of their premium revenues on direct medical care and quality improvement activities.

West Virginia – HB5022 expands the the capitation rate review program to include the Aged and Disabled Waiver program, the Personal Care Services program, and the Traumatic Brain Injury Waiver program, studying the reimbursement rates for these programs.

Illinois — SB2182 creates the Facility Fee Transparency and Prevention Act. The Act would prohibit facility fees for preventive services and preventive care. For other services, patients would need to be informed in advance about specific facility fees.

Illinois — HB4701 prohibits providers from charging facility fees for outpatient services, except for those provided on a hospital’s campus, at a facility with a licensed hospital emergency department, or for emergency services at a freestanding emergency center.

Illinois — HB4908 creates “site-neutral payment” principles for the State Employees Group Insurance Program, so that payment for covered healthcare services is the same regardless of where it is provided.

Massachusetts — H1144/H4619 limits where providers can charge facility fees to services on hospital campuses or emergency departments. Clear written notice of facility fees would need to be provided to patients. Additionally, the bill would create requirements for notifying patients when services are out-of-network.

Minnesota — HF1312/SF1503 would prevent providers from charging facility fees for specific types of services at provider-based clinics. Providers would not be allowed to charge facility fees for outpatient evaluation and management services.

North Carolina — S316 would require hospitals and ASCs to disclose detailed cost information for common medical procedures and inpatient admissions, and require that patients be informed about potential out-of-network providers. The bill would also place limits on facility fees, and require reporting of facility fee practices.

New Jersey — S3409 prevents hospitals from charging a facility fee when services are provided at an outpatient facility connected to the hospital.

New York — A05342/S08039 would prohibit providers from charging facility fees that aren’t covered by the patient’s insurer by removing existing statutory language that allowed facility fees with advanced notice.

New York — A02140 would create site-neutral payment policies for certain healthcare services. The bill would require providers participating in health benefit plans to accept rates that do not exceed 150% of Medicare rates for enumerated services.

Oklahoma — HB3808 would create the “Oklahoma Hospital Facility Fees Reform Act of 2026″. The current text of the bill lacks detail on what this might mean.

Pennsylvania — HB2268 creates health care site neutrality, prohibiting healthcare providers from charging a facility fee for services provided in off-campus facilities, outpatient evaluation and management services, and certain outpatient, diagnostic, or imaging services. Rates for these services cannot exceed a benchmark based on Medicare rates, and providers would be required to submit annual reports detailing facility fees billed.

Rhode Island — H7937 creates health care site neutrality, prohibiting healthcare providers from charging a facility fee for services provided in off-campus facilities, outpatient evaluation and management services, and certain outpatient, diagnostic, or imaging services. Rates for these services cannot exceed a benchmark based on Medicare rates, and providers would be required to submit annual reports detailing facility fees billed.

Vermont — H0585 would enact health insurance reforms, including a requirement for “site-neutral billing” policies requiring certain healthcare services to be reimbursed at a standardized rate regardless of whether they are performed in a hospital or a non-hospital setting. The bill also restricts the exemption from prior authorization requirements for primary care providers to only those practicing independently.

Vermont — H0848 prohibits facility fees for outpatient hospital services that use standard evaluation and management codes, or for any healthcare services provided through telehealth.

Virginia — HB184 creates site-neutral payment policies for certain outpatient or ambulatory healthcare services, so that providers must accept payment that does not exceed 150% of Medicare. The State Corporation Commission and the Department of Health would be required to produce an annual report detailing payment trends for these services.

Hawaii — SB2277 requires hospitals to comply with federal hospital price transparency requirements, and allows patients to challenge debt collection actions by hospitals.

Kentucky — HB59 would require healthcare providers to provide patients with statements for services that clearly explain each service, its cost, its price classification, and whether a claim has been or will be filed with an insurance company. Providers could not charge for the statements.

Kentucky — SB340 establishes the Kentucky All-Payer Claims Database to collect and analyze health care claims data for purposes that include improving population health, informing healthcare planning, supporting research, and enhancing the accessibility and affordability of healthcare.

Minnesota — SF4062 would prohibiting spread pricing by PBMs where a health plan is changed a different price for a prescription drug than what the PBM pays the pharmacy, and mandates PBMs reimburse pharmacies at least the national average drug acquisition cost.

New Hampshire — SB476 requires hospitals to maintain public pricing files and patient-friendly service estimators. Insurers would be required to allow consumers to obtain free, member-specific price estimates online. The legislation would also create a consumer portal as part of the All-Payer Claims Database that displays de-identified price benchmarks and links to carrier pricing tools.

New Hampshire — HB297 requires insurers and third-party administrators to annually inform employers about the option to submit data to the state’s all-payer claims database.

New Jersey — A1729 creates the Office of Healthcare Affordability and Transparency to support the Health Care Cost Containment and Price Transparency Commission, and will set guidelines for healthcare entities to submit data on their expenditures, pricing, and cost growth. The Commission will use the to set benchmarks for overall healthcare cost growth and hospital price growth.

Oklahoma — HB3647 intends to create a comprehensive database of health care information in the state by requiring health insurers and benefit plans with at least 2,000 covered individuals to submit claims data, unique identifiers, and demographic information to a state-designated entity. The data would be used to assess healthcare utilization, expenditures, and performance, and for improving health care quality and costs.

Oklahoma — HB4453 creates an Oklahoma Health Care Cost Transparency Board to oversee an All-Payer Claims Database, which will collect and analyze health care costs, utilization, and spending data from insurers. The Board will publish an annual report on cost trends, primary care spending, and policy recommendations. The bill includes a mandate that commercial health insurers dedicate at least 11% of their total medical spending to primary care.

Pennsylvania — HB1739 creates an All-Payor Claims Database that requires insurers, providers, and facilities to submit detailed claims data. Public reports and interactive tools will be developed using the data to help consumers understand healthcare costs.

Pennsylvania — HB2241 requires hospitals to publish a comprehensive list of all standard charges for every item and service they offer, including gross charges, negotiated rates with insurers, and discounted cash prices, in a machine-readable digital format on their website. Medical offices must also make a list of standard charges for their most frequently provided services available.

Virginia — HB618 requires the state to create and publicly share an inventory of all mandated health benefits and providers. Health insurers would be required to report on providers they terminate from their networks and any they later reinstate, and consolidates reporting related to balance billing.

Virginia — HB1209 requires hospitals to give patients a detailed, itemized statement of charges for any non-emergent medical procedure, test, or service they receive to increase transparency in hospital billing.

Wisconsin — AB353/SB383 requires hospitals to publicly disclose detailed pricing information in both machine-readable and consumer-friendly formats, and make them easily accessible online. The bill also limits debt collection against patients for non-compliant hospitals.

Massachusetts — S851 states that a healthcare provider can’t refuse to negotiate in good faith with payors, then subsequently charge extremely high rates for non-contracted services (defined as more than 200% of the payor’s average contracted reimbursement rate for that same service).

Massachusetts — H4954/H4955 among other things, prevents insurers from restricting provider participation or forcing all members of a provider group into the same cost-sharing tier or requiring their inclusion in a select network plan on an all-or-nothing basis.

Massachusetts — H1298 among other things would remove existing requirements that carriers include entire provider groups in a network on an all-or-nothing basis or mandate that all members of a provider group be placed in the same tier, with the intent of giving insurance carriers more flexibility in designing health plan networks.

Mississippi — SB2752 an any willing provider bill that prevents health insurers from discriminating against any licensed healthcare provider within the plan’s service area who is willing to accept the insurer’s terms and conditions.

Missouri — HB3088 among other things, prevents insurers from restricting provider participation or forcing all members of a provider group into the same cost-sharing tier or requiring their inclusion in a select network plan on an all-or-nothing basis.

Missouri — SB1644 prohibits anti-steering clauses, anti-tiering clauses, gag clauses, and most-favored-nation clauses by declaring any such clauses in provider network contracts void and unenforceable, while the rest of the contract remains valid. The bill also creates a good faith requirement for health benefit plan issuers to act in the best interest of enrollees when encouraging the use of specific providers or implementing tiered networks.

New Jersey — S504 requires that insurance companies must accept any licensed healthcare provider or facility that applies to join their network, and must reimburse these providers at a rate no less than 200% of the Medicare rate for similar services.

New York — A05106/S07577 would prevent insurers from being required to include all members of a provider group in their network, place all group members in the same network tier, or include all group members in all of their insurance products. Contracts couldn’t prohibit insurers from encouraging patients to seek care from higher-value providers using benefit design, and from including most-favored-nation clauses.

New York — S05527 forbids contracts where reimbursement is based on the lowest rate a provider has charged elsewhere, preventing payers from taking advantage of pricing disparities. The bill also prevents insurers from restricting patient referrals based on a provider’s participation in a particular insurance product.

Oklahoma — HB3259 would prohibit certain restrictive clauses between healthcare providers and anyone directly contracting with a provider for healthcare services. This includes a ban on “all-or-nothing clauses”, “anti-steering clauses”, “gag clauses”, and “most favored nation clauses”. Any such clauses in existing or future provider contracts would be void and unenforceable.

Oklahoma — SB1626 would ban “all-or nothing” clauses, “anti-steering/anti-tiering” clauses, “gag” clauses, and “most-favored-nation” clauses from contracts between health insurance companies, health plan administrators, and providers. Terms would be considered unfair or deceptive acts enforceable by the Attorney General. Parties could get a waiver if they can demonstrate the term is necessary for a consumer welfare improvement that could not be achieved by less restrictive means.

Rhode Island — H7862/S3089 prohibits a healthcare entity from unilaterally changing, amending, or reinterpreting any significant part of a contract with a healthcare provider while that contract is still active.

Washington — HB1589/SB5588 would require carriers to give providers a meaningful change to engage in good faith negotiations. The bill would also prohibit “all-or-nothing” contract clauses.

Washington — HB2106 requires health insurers to provide notice to healthcare providers and facilities before making any significant contract modifications, which include any change that affects provider payments, reimbursement methodologies, service delivery requirements, administrative processes, or provider expenses.

Arizona — HB2361 would prohibit employers from requiring current or prospective employees to agree to a noncompete clause as a condition of employment.

Illinois — HB4221 prohibits employers from enforcing noncompete and nonsolicitation clauses against healthcare professionals entered into after January 1, 2027.

Illinois — SB3607 declares that covenants not to compete entered into after January 1, 2027 will be considered against public policy and therefore void and unenforceable by an employer. Noncompetes could still be enforceable in cases involving the sale or transfer of ownership of a business entity.

Iowa — HF2254 would prevent the University of Iowa Hospitals and Clinics from using noncompete clauses in contracts with physicians.

Kansas — SB504 prohibits most post-employment noncompete agreements for healthcare professionals, with exceptions for the first 24 months of initial employment if the employee voluntarily terminates their position, and it does not prohibit agreements protecting trade secrets or proprietary information, nor does it affect covenants made during the sale of a medical practice with goodwill. Employers are also forbidden from preventing healthcare professionals from informing patients about their departure or new practice locations.

Maine — LD2200 adds healthcare practitioners to the existing list of workers for whom noncompete agreements are prohibited.

Massachusetts — S1336 would ban noncompete agreements, making them void and unenforceable.

Michigan — HB4514 would change the Michigan Antitrust Reform Act to add a new prohibition against noncompete agreements specifically for physicians.

Michigan — HB4040 intends to restrict noncompete agreements prohibiting businesses from enforcing them, with exceptions that include when a worker is selling their ownership stake. Businesses are still allowed to protecting legitimate interests, such as trade secrets.

Missouri — HB2184 would prevent employers from including noncompete clauses in physician employment contracts.

Missouri — HB2821 declares that any noncompete clause in an employment contract between a healthcare employer and a physician is void and unenforceable.

North Carolina — S673 prevents employment contracts from containing noncompete clauses for healthcare professionals employed by hospitals, or terms that prevent professionals from providing practice information on patient request. The bill also adds whistleblower protections for healthcare professionals, and restricts nondisclosure agreements so professionals can report concerns with safety, ethics, and illegal activities.

New Jersey — A1829 prohibits employers from using non-compete clauses, and applies to all workers. It also bans no-poach agreements: where employers agree not to hire each other’s employees. There are exceptions for sale of a business.

New York — S04641 would prohibit noncompete agreements for most workers, declaring them null and void. There would be exceptions for workers earning over $500,000 annually, and for protecting trade secrets, confidential information, client solicitation, and in specific business sale scenarios. The bill also prevents employers from using alternative legal strategies, such as choosing a different venue, to circumvent its protections.

New York — A10023 prohibits employers from using noncompete clauses with exceptions for individuals earning over $500,000 annually, and in specific business sale scenarios.

New York — S09228 prohibits the use of non-compete agreements with certain medical professionals, including physicians, nurses, dentists, and therapists. Professionals would be allowed to sue an employer who violates the prohibition. There are exceptions for the sale of a business and does not affect agreements related to trade secrets or confidentiality.

Rhode Island — S2160 generally prohibits noncompetition agreements, with an exception between a seller and buyer of a business. The bill would allow employers to sue employees who violate agreements addressing trade secrets.

South Carolina — S0046 would prohibit contract terms that limit healthcare professionals’ ability to treat patients, practice in certain geographic areas, or maintain patient relationships after leaving employment. Exceptions include repayment of relocation or recruitment expenses, and protection of legitimate business interests like trade secrets. The prohibition would apply to contracts entered into or renewed after its effective date.

South Carolina — H4767 would prohibit noncompete terms that preventing physicians from practicing medicine in a geographic area after leaving employment, continuing to treat current patients, establishing new patient relationships, or notifying patients about their departure. The bill would allow employers to require repayment of expenses like relocation or signing bonuses and would still be allowed to protect trade secrets and confidential business information.

Tennessee — HB1034/SB0995 would broadly prohibit non-compete agreements, rendering restrictions on the right to practice professionally after terminating employment void and unenforceable. The bill specifically removes existing language that allowed noncompetes related to healthcare. The bill would apply to contracts entered into (or amended) on or after July 1, 2025.

Vermont — H0334 would restrict noncompete agreements and stay-or-pay provisions. Most noncompete agreements would be void, with exceptions for sale of a business, partnership dissolution, or limited liability company termination. Stay-or-pay provisions (which require employees to repay certain costs if they leave their job) would be generally unlawful, but with exceptions for specific, limited, conditions.

Vermont — H0071 prevents corporations from interfering with the clinical judgement of medical professionals, and prevents non-medical entities from controlling medical practices. It also requires healthcare entities to inform the state before any material change transaction (mergers, acquisitions or partnerships) of over $1 million or more. The bill would also require physicians to have majority ownership and control of medical practices, and would void any non-competition and non-disclosure agreements that could restrict rights.

Virginia — HB627/SB128 expands protections against non-compete agreements to include healthcare professionals, similar to existing state prohibitions for low-wage employees.

Washington — HB1155/SB5437 prohibits noncompetition agreements, rendering them void and unenforceable regardless of when they were originally signed. Nonsolicitation agreements would still be permitted, but must be narrowly construed.

Wisconsin — AB567 makes most post-employment noncompete clauses illegal and unenforceable with exceptions if they are reasonably necessary to protect the employer’s interests.

Wisconsin — AB675/SB657 makes noncompete clauses illegal and unenforceable if they prevent medical practitioners from working in their field for more than 24 months after employment, or if the employer terminates the medical practitioner’s employment.

Mississippi — HB500 declares that any contract term that restricts the ability of a healthcare provider to practice their profession in any geographic area or for any period of time after the relationship ends void and unenforceable.

California — AB1900 creates a universal, single-payer healthcare program called for all state residents, aiming to control healthcare costs and provide comprehensive coverage.

Florida — S0348 would create a task force to design a single-payer healthcare system and submit recommendations back to the state legislature.

Florida — H1489/S0740 would create the “Healthy Florida Act,” a state-managed health care system providing universal health coverage for all Florida residents, regardless of immigration status.

Georgia — HB1480 establishes a universal, single-payer healthcare program for all state residents to provide comprehensive coverage and control healthcare costs.

Hawaii — HB1490/SB1179 establishes a universal, single-payer health care system to provide comprehensive health coverage for all residents of Hawaii. The system would allow residents to maintain supplemental health insurance if desired.

Hawaii — HB2143/SB3305 establishes “Hawaii Care,” a universal, single-payer healthcare system intended to replace existing health insurance plans.

Hawaii — HB1789/SB3243 establishes a “Health Care for All Hawaii Board” to develop a publicly funded, universal healthcare system.

Hawaii — HR87 supports the reactivation of the Hawaii Health Authority, an existing state entity tasked with planning for a universal healthcare system, with the goal of developing a plan for transitioning Hawaii to a single-payer health care system.

Illinois — HB3287 would create the Illinois Medicare for All Health Care Act, providing comprehensive health coverage to all state residents. Funding would come from a progressive contribution model, supplemented by federal healthcare funds, grants, and other designated revenues. Only non-profit healthcare providers would be able to participate, and private insurers would be prohibited from offering duplicate coverage.

Illinois — HB3568 establishes the Health Care for All Illinois Act, a comprehensive universal healthcare program to provide health insurance to all state residents. Funding would come from a progressive contribution model, supplemented by federal healthcare funds, grants, and other designated revenues. Only non-profit healthcare providers would be able to participate, and private insurers would be prohibited from offering duplicate coverage.

Illinois — HB3780 creates the Illinois Universal Health Care Act, establishing a comprehensive, state-wide health insurance program to cover all state residents, funded through government appropriations, progressive income contributions, and federal healthcare funds. Only non-profit healthcare providers would be able to participate, and private insurers would be prohibited from offering duplicate coverage.

Illinois — SB2873 would provide universal health insurance coverage for all Illinois residents through a new state-administered program called the Illinois Health Services Program.

Massachusetts — S849 explores the possibility of a single-payer healthcare system in Massachusetts by establishing a comprehensive benchmark and evaluation process.

Massachusetts — S860 would establish a single-payer healthcare system to provide universal healthcare coverage.

Michigan — HB4407 establishes a comprehensive universal health care system for state residents to provide publicly financed and administered health coverage for all state residents regardless of income, health status, or existing insurance.

New Jersey — S426 would expand Medicare to cover all residents of New Jersey, regardless of their age, health, or disability status. The bill would eventually prohibit private health insurance companies from offering comparable plans to ensure that everyone participates in the Medicare program.

New York — A06273 establishes the New York State Public Health Care Option Program to offer competitive, affordable health insurance with access to quality providers, and will be available through the state’s health insurance Marketplace. The program would be funded through member premiums, potential federal payments, and other state funds.

New York — S03425 would create the New York Health program to provide universal health coverage for all New York state residents without premiums, deductibles, or co-pays funded through payroll and non-payroll income taxes.

New York — S08614 creates a buy-in option for the Basic Health Program allowing individuals and small groups to purchase health coverage even if they don’t meet the traditional eligibility requirements.

New York — A01466 creates the New York Health program, a comprehensive single-payer health insurance system.

North Carolina — H714 would create a state-run universal healthcare benefit plan to provide affordable health insurance to state residents whose incomes are too high to qualify for Medicaid but who may not be able to obtain private coverage.

Ohio — SB78 would create a single, comprehensive universal healthcare system for all residents in Ohio, funded through federal funding, payroll taxes, and other new taxes.

Rhode Island — H7823/S2567 creates a unified, publicly financed, and publicly administered healthcare system with a single payment system.

Washington — HB1445/SB5233 would create the Washington Health Trust to provide universal health coverage to all state residents via a comprehensive healthcare system. Funding would come from new capital gains taxes and employer contributions, guaranteeing coverage without premiums, deductibles or copayments.

Washington — SB5947 creates the Washington Health Care Board to design and implement a universal healthcare plan to provide state-based healthcare for all residents.

Washington — SB5948 creates a universal health care commission to develop a detailed plan for a unified health care financing system that provides universal coverage for all state residents.

California — SB351 prohibits private equity groups from interfering with healthcare clinical decision making, but also prevents the investment groups from exercising control over non-clinical aspects, including staffing, relationships with payers, and billing decisions. The bill includes invalidating healthcare provider noncompete and nondisclosure clauses.

Illinois — SB1998 would require healthcare facilities or provider organizations to notify the AG at least 30 days before any mergers or new affiliations. The bill adds that the AG must provide written consent if a private equity group is providing financing for the transaction. The AG would be given power to investigate the transaction.

Illinois — HB5000 extends the requirement for health care entities to notify the Attorney General before a merger or affiliation where private equity companies own or control two or more health care facilities or provider organizations that will come under common ownership or contracting affiliation.

Massachusetts — S1628 prohibits entities from interfering with the professional judgment of any clinician, including restrictions on controlling patient care decisions.

Massachusetts — H2486 / S1534 requires that healthcare practices must be owned and controlled by licensed clinicians and prohibits entities like management services organizations from interfering with clinical judgments.

Minnesota — SF3354 would prevent private equity companies from acquiring (or increasing) their ownership or control over healthcare providers. Exceptions allow for routine replacement of employees or directors as part of normal business.

New Hampshire — SB666 allows the Department of Justice to review material healthcare transactions and may prohibit them or impose conditions to protect competition, cost, and quality of care. The bill also prohibits private equity or for-profit owners from interfering with the independent clinical judgment of healthcare professionals.

New York — A09012/S08442 requires that licensed physicians hold the majority of voting shares, constitute a majority of the board of directors, and serve as most corporate officers in medical professional corporations.

North Carolina — S570 requires that medical corporations can only have licensed medical professionals as shareholders. The bill also mandates that physicians maintain full control over patient care decisions without interference from non-physicians or out-of-state medical professionals.

Rhode Island — H7721/S2459 prohibits unlicensed individuals or business entities from owning medical practices, employing healthcare professionals, or practicing medicine, with specific exceptions for entities where licensed physicians hold majority ownership and control, and for certain public or safety-net healthcare providers. The bill also bans straw ownership where ownership is not meaningful. The bill also voids most non-compete agreements for healthcare providers, with an exception for those with significant ownership stakes, and voids non-disclosure and non-disparagement agreements. Healthcare entities would also be required to report detailed information about their ownership, control, and business structure to the Department of Health annually.

Vermont — H0071 prevents corporations from interfering with the clinical judgement of medical professionals, and prevents non-medical entities from controlling medical practices. It also requires healthcare entities to inform the state before any material change transaction (mergers, acquisitions or partnerships) of over $1 million or more. The bill would also require physicians to have majority ownership and control of medical practices, and would void any non-competition and non-disclosure agreements that could restrict rights.

Vermont — H0583 would prevent corporations from practicing medicine or interfering with the professional judgement of healthcare providers.

Washington — HB1675 would prevent organizations and people without a medical license from interfering with providers’ professional decisions, such as treatments, coding and referrals. Any professional service corporation running a practice must have a majority of voting shares and directors be licensed providers.

Washington — SB5387 would prohibit anyone (including corporations) without a healthcare license from owning a healthcare practice and employing licensed providers. Any professional service corporation running a practice must have a majority of voting shares and directors be licensed providers. Non-licensed providers would be prevented from interfering in clinical decision-making in many settings. There are exemptions to these rules.

Maryland — HB277/SB139 requires insurers to report to the state how they use AI, including the types of AI models, their role in decision-making, training data, performance metrics, and risk management policies.

Alabama — SB63 creates rules for using artificial intelligence to make decisions about coverage, specifically for prior authorization requests, requiring that these decisions must consider the enrollee’s medical history, unique clinical circumstances presented by the healthcare provider, and any additional clinical information in the enrollee’s medical record. Additionally, any decision to deny, reduce, or delay a prior authorization request must ultimately be made by a licensed physician or qualified healthcare professional who evaluates the AI’s recommendation.

Illinois — SB3027 prohibits hospitals from using artificial intelligence in setting healthcare pricing or billing.

Rhode Island — S2010 requires insurers to report to the state how they use AI, including the types of AI models, their role in decision-making, training data, performance metrics, and risk management policies.

Tennessee — SB2010/HB1866 prevents health insurers from denying, delaying, or modifying healthcare services based on AI or algorithms, unless the decision is reviewed by a competent licensed healthcare professional.

Virginia — SB586 requires insurers to disclose their use of AI to manage claims and coverage, and cannot rely exclusively on AI for adverse determinations, and requires an externay review process for appealing such AI decisions.

New Jersey — S1386 allows healthcare providers to engage in joint negotiations with carriers on the terms and conditions of contracts.

New Jersey — S952 allows independent physicians to jointly negotiate with hospitals and commercial health insurers over non-fee-related matters impacting patient care. Negotiating jointly over fee-related matters can occur only if the Attorney General has determined that the health carrier has substantial market power and that the terms being negotiated threaten patient care quality and availability.

New Jersey — S3212 requires PBMs to pass on rebates and discounts, prohibits spread pricing I certain circumstances, and would require PBMs to reimburse pharmacies at rates at least equal to the National Average Drug Acquisition Cost with a dispensing fee. The bill would also prevent PBMs from steering patients to pharmacies they own.

New York — A06775 would allow physicians and dentists to collectively negotiate with health benefit plans under certain conditions.

Vermont — S0197 creates a program where participating primary care providers would receive a monthly payment from a patient’s insurer that covers routine primary care services without any out-of-pocket costs for the patient.

Virginia — SB593 extends existing balance billing prohibitions by prohibiting out-of-network insurance providers from balance billing for emergency medical services transportation.

Virginia — HB1332 allows hospitals to form compacts to collaborate on workforce development by pooling resources and sharing workforce data.