On June 9, 2025, Oregon Governor Tina Kotek signed into law Senate Bill 951 (the “2025 Act”). Unlike California’s AB 3129, which was vetoed by California Governor Gavin Newsom in September 2024, the passage of the 2025 Act is the culmination of the state’s efforts to strengthen controls on health care transactions involving management services organizations (“MSOs”) and private equity investors. The 2025 Act implements significant changes to Oregon’s existing corporate practice of medicine (“CPOM”) doctrine and materially affects existing arrangements between MSOs and the professional medical entities that they manage. Significantly, the 2025 Act prohibits several material aspects of health care transactions that are standard in states that restrict CPOM.
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