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CA SB 184: Implications for Health Care Access, Pricing, and Transactions

By Karl Rebay, Partner, Health Care Consulting Practice, Moss Adams
By Joanna Omi, Director, Lean Health Care Practice, Moss Adams
By Georgia Green, Manager

See all this Month's Articles

Original Publish Date: November 8, 2022

On June 30, 2022, California Governor Gavin Newsom signed the 2022–2023 state budget, which included a trailer bill, Senate Bill (SB) 184, with significant, long-term implications for health care providers, payers, and consumers.

In the coming years, providers can expect to see mandated reporting requirements and potential enforcement actions related to health care in the following sectors:

Additionally, SB 184 legislates expansions to Medi-Cal services and eligibility, provides for mental health crisis grants, and is anticipated to support significant health care payment reform.

Impact on Health Care Transactions

Providers, health plans, investors, as well as market disruptors can expect to see increased scrutiny and reporting related to business transactions. Particularly concerning is the effect CA SB 184 will likely have on transactions due to:

Legislating Health Care Affordability

SB 184 provides the funding to establish a health care cost commission called the Office of Health Care Affordability (OHCA) within the Department of Health Care Access and Information (HCAI).

California will be the fourth state to establish such an office, joining Massachusetts, Oregon, and Rhode Island. The OHCA’s responsibilities will include:

OHCA has been granted broad access to request data from health care providers, public and private data sources, and state agencies to facilitate its analyses. OHCA will be responsible for setting standards for health care metrics, including those that address:

The role OHCA plays in analyzing proposed transactions is anticipated to broadly affect all types of health care provider and service organizations.

Implementation Timeline for Health Care Affordability Initiatives

The new legislation proposes an aggressive timeline beginning in 2024.

Chart with an overview of the legislations proposed agressive timeline beginning in 2024

Other Impacts

SB 184 also includes a myriad of policy changes with financial impacts on health care providers, payers, and patients in California including, but not limited to:

SB 184 demonstrates California’s commitment to health care equity by expanding Medi-Cal eligibility and covered services, and by supporting the expansion of crisis mental health services.

California health care providers should take advantage of the service expansions this enables and should also keep apprised of the newly created Office of Health Care Affordability and prepare to report data as required.

Some providers may be subject to enforcement actions, and it may be advisable to conduct an internal risk assessment related to health care affordability and other quality metrics. Any entity that’s planning a transaction in the coming years should be aware of the increased scrutiny and reporting requirements.

We’re Here to Help

To learn more about California health care initiatives, visit our webpage.

Assurance, tax, and consulting offered through Moss Adams LLP. ISO/IEC 27001 services offered by Cadence Assurance LLC, a Moss Adams company. Wealth management offered through Moss Adams Wealth Advisors LLC.