On September 16, 2026, Senators Elizabeth Warren (D-MA), Ron Wyden (D-OR), and Jeff Merkley (D-OR)—along with House companion sponsors Representatives Val Hoyle (D-OR), Suhas Subramanyam (D-VA), and Alexandria Ocasio-Cortez (D-NY)—introduced the Stop Corporate Takeovers of Physicians Act of 2026. Modeled after Oregon’s recent corporate practice of medicine (CPOM) law, the bill would, with limited exceptions, impose a federal CPOM prohibition, barring any partnership or corporate entity not majority-owned and controlled by licensees from owning or controlling a medical practice, employing or contracting for a licensee’s professional services, or engaging in the practice of medicine.

The bill separately targets management services organizations (MSOs), prohibiting MSOs, as well as their shareholders, directors, officers, employees, or contractors, from controlling the transfer of a practice’s equity or assets, issuing or causing issuance of practice equity, paying dividends from practice ownership interests, holding ownership or governance roles in a practice, or exercising de facto control over administrative, business, or clinical operations in a manner affecting care quality. The bill also voids non-compete, non-disclosure, and non-disparagement agreements involving licensees—with a narrow non-compete carve-out for licensees holding 25 percent or more ownership—and requires licensee-owners to be licensed, present, and substantially engaged in delivering care in the state of practice.

The bill grants enforcement authority to the Federal Trade Commission (FTC) (as an unfair/deceptive acts or practices violation) and state attorneys general, and establishes a private right of action, all with mandatory injunctive relief, divestment, and disgorgement on a finding of violation. Under the bill, violations could also result in exclusion from federal healthcare programs.

The bill has attracted headlines and may provide a model for interested states to replicate in their upcoming legislative sessions. California and Oregon have passed similar laws, and several other states have recently passed healthcare transaction notification laws to increase oversight of healthcare transactions.

Please contact any member of Wilson Sonsini’s Healthcare and FDA Regulatory practice with questions.

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Photo of Andrea Linna Andrea Linna

Andrea is a partner and member of the digital health industry group and healthcare practice. With more than 15 years dedicated to healthcare law, she represents digital health and health tech clients on regulatory matters throughout the business life cycle, including care delivery…

Andrea is a partner and member of the digital health industry group and healthcare practice. With more than 15 years dedicated to healthcare law, she represents digital health and health tech clients on regulatory matters throughout the business life cycle, including care delivery structures, reimbursement, telehealth, healthcare transactions, and compliance with federal and state healthcare laws.

Photo of Nawa Lodin Nawa Lodin

Nawa is a Chambers USA-ranked associate whose practice focuses on healthcare regulatory and transactional matters. She advises healthcare, digital health, life sciences, and technology companies on artificial intelligence and machine learning, telehealth, fraud and abuse laws, and complex healthcare transactions, including evolving state…

Nawa is a Chambers USA-ranked associate whose practice focuses on healthcare regulatory and transactional matters. She advises healthcare, digital health, life sciences, and technology companies on artificial intelligence and machine learning, telehealth, fraud and abuse laws, and complex healthcare transactions, including evolving state healthcare transaction review and notification requirements.

Photo of Ty Kayam Ty Kayam

Ty Kayam is Of Counsel in the Seattle office of Wilson Sonsini Goodrich & Rosati, where she advises companies and investors on regulatory strategy for health technology products, with a particular focus on health AI, digital health, wearables, medical robotics, and health data…

Ty Kayam is Of Counsel in the Seattle office of Wilson Sonsini Goodrich & Rosati, where she advises companies and investors on regulatory strategy for health technology products, with a particular focus on health AI, digital health, wearables, medical robotics, and health data infrastructure. She counsels clients throughout product development and commercialization and advises on health regulatory issues arising in financings, investments, partnerships, and strategic transactions.

Photo of Seamus Taylor Seamus Taylor

Seamus is an associate and member of the digital health industry group and healthcare practice. He advises companies on healthcare regulatory matters including corporate practice of medicine, fraud and abuse laws, HIPAA, Medicare and Medicaid, and state licensing requirements. He also counsels clients…

Seamus is an associate and member of the digital health industry group and healthcare practice. He advises companies on healthcare regulatory matters including corporate practice of medicine, fraud and abuse laws, HIPAA, Medicare and Medicaid, and state licensing requirements. He also counsels clients on healthcare transactions, contractual arrangements, entity formation, governance, and compliance programs.