Washington expands oversight of healthcare ownership transactions

In March, The Washington State Legislature enacted HB 2548, expanding state oversight of healthcare ownership transactions and requiring new disclosures when hospitals and provider organizations change hands.

Washington already requires hospitals, hospital systems, and provider organizations to give the Attorney General at least 60 days’ notice before certain transactions that result in a material change, so the Attorney General can evaluate whether an antitrust investigation is warranted.

HB 2548 broadens those notice triggers to include:

• changes in majority ownership or control of a hospital, hospital system, or provider organization;
• acquisitions, sales, or transfers of a majority of an entity’s assets, including real estate sale-leaseback transactions; and
• conversions of nonprofit healthcare entities into for-profit corporations or unincorporated entities.

The bill also adds ownership disclosures, filing fees scaled to the transaction’s value, post-transaction notification within 30 days of a deal being completed, and quarterly public notice of pending and completed transactions on the Attorney General’s website. It also requires transactions to pause until 30 days after the parties certify substantial compliance with any request for additional information from the Attorney General.

The law does not expand the Attorney General’s authority to block or unwind transactions beyond existing antitrust law, but instead strengthens notice, disclosure, and investigatory capacity.

Private equity in Washington

The legislation comes amid growing concern about consolidation and investment activity in Washington’s healthcare sector.

In its December 2025 annual report, the Washington Health Care Cost Transparency Board stated that when healthcare organizations are acquired, merged, or affiliated with private equity, patient prices and healthcare spending go up, driven by increases in provider fees, hospital prices, drug prices, and insurance premiums. The board also noted that consolidation leads to fewer patient choices and decreased or unchanged quality of care, slower wage growth and worse working conditions for healthcare workers, and hospital closures linked to delays in care and increased mortality.

On private equity specifically, the board flagged Washington’s substantial growth in private equity ownership over the past decade and noted that private equity firms often acquire additional nearby practices after an initial acquisition, laying the groundwork for further consolidation

A January 2026 report from the Washington Office of the Insurance Commissioner documented 551 healthcare acquisitions in Washington since 2015, with deal values peaking at $11.3 billion in 2023 and transaction volume peaking at 111 deals in 2021. Nationally, private equity investors spent more than $200 billion on healthcare acquisitions in 2021 alone and $1 trillion over the past decade. The most heavily targeted sectors in Washington by deal count were veterinary, dental, mental health, dermatology, musculoskeletal, vision, and gastroenterology, while veterinary care dominated by total deal value.

Earlier efforts at oversight

HB 2548 comes after earlier legislative proposals in Washington to establish more comprehensive oversight of healthcare transactions.

In 2025, Washington legislators introduced HB 1881, the Keep Our Care Act, which would have amended state law to prohibit any merger, acquisition, or contracting affiliation among hospitals, hospital systems, or provider organizations that would “detrimentally affect the continued existence of accessible, affordable health care in Washington state for at least five years after the transaction occurs.”

The Washington Health Care Authority would have had authority to conduct a formal review of each covered transaction – including at least one public hearing – and submit a report and recommendation to the Attorney General, who would have authority to approve, conditionally approve, or disapprove the deal outright. The bill was referred to the Committee on Civil Rights & Judiciary, where it did not advance.

While comprehensive transaction oversight stalled last year, the legislature did take a step toward greater transparency. Last April, the governor signed HB 1686 into law, requiring the Department of Health to develop a plan for a complete interactive registry of Washington’s healthcare landscape, including the ownership, investment, and governance structures of healthcare entities. DOH must deliver a progress update by December 31, 2027, and a final report with implementation recommendations by November 1, 2028.

A step towards more transparency

HB 2548 expands Washington’s healthcare transaction notification framework to include a wider range of ownership changes, asset transfers, and organizational conversions, while increasing disclosure requirements and public reporting.

The law does not alter the Attorney General’s underlying authority to review or challenge transactions, but gives regulators access to more information under existing legal standards.

The changes in HB 2548 give regulators earlier notice and more detailed information about consolidation activity across the state’s healthcare system, positioning Washington to more effectively monitor consolidation trends, including activity by private equity and other profit-driven actors.