Oregon’s Health Care Market Oversight (HCMO) program regulations underwent significant amendments that took effect on July 1, 2026, expanding which entities may qualify as “out-of-state” for HCMO purposes, narrowing the internal reorganization exclusion, and substantially increasing review fees. Preliminary review fees increased from $2,000 to $30,000, and comprehensive review fees increased to a range of $200,000 to $350,000.

The rules also introduce a new civil penalty schedule of up to $10,000 per offense, a 60-day deadline for consummating approved transactions, and a new seven-business-day notification requirement if an approved transaction is abandoned. These changes may materially affect transaction timing, cost allocation, and compliance planning for parties involved in Oregon healthcare transactions.

Read the full alert.