Increasing consolidation among hospitals, physician practices, and other health care entities is driving up health care prices. At the same time, growing corporatization of health care makes it increasingly hard to uncover which entities own or control a health care practice or other health care entity. As state policymakers grapple with high and rising commercial health care prices, they showed a growing interest during 2025 legislative sessions in leveraging ownership transparency as a tool to better understand their changing health care markets, strengthen oversight efforts, and inform consumers.
Bills to increase the transparency of ownership and control of health care entities were introduced in at least eight states in 2025, and made it across the finish line in four of them. The increase in state policymakers’ interest and activity likely reflects several interrelated factors, including:
This blog post examines the role of state ownership transparency within broader reform efforts and reviews ownership transparency-related laws passed in 2025 in Massachusetts, Indiana, New Mexico, and Washington, as well as bills considered, but not enacted, in Maine, Minnesota, Texas, and Vermont.
Who owns or controls a physician practice, hospital, and other providers—and their vested financial interests—can impact prices charged, services offered, quality, and access to care, yet it can be hard or impossible to know which entities own or control a health care practice or facility. A web of complex corporate structures among interrelated entities can obscure the ownership or controlling interests of individual practices or facilities, as well as overall trends in consolidation in health care markets. Existing data sources on ownership have gaps, and there is no complete, publicly available data source with ownership information for physician practices.
States generally collect some ownership information as part of state licensure of, for example, hospitals and health insurers. Some states go further, collecting additional information to leverage ownership transparency as a tool for monitoring and understanding their changing health care markets. Ownership transparency efforts, where they exist, generally require: (1) annual or periodic reporting, and/or (2) reporting triggered by proposed changes, such as mergers and acquisitions. These two structures serve different purposes and can be complementary:
- Annual reporting enables an ownership registry that can provide information—some or much of it otherwise unknowable—to several types of users. It could, for example, allow an individual patient to learn whether their doctor’s office is owned or controlled by a hospital, an insurance conglomerate, Amazon, private equity, or other corporate entities. Annual reporting can also help reveal the degree of consolidation in health care markets today and the nature of relationships between entities. This can inform state policymakers, regulators, and researchers seeking to better understand their markets or limit anticompetitive practices. Massachusetts has the longest-standing model for this approach that requires a range of provider organizations to systematically report ownership and control information on a regular basis, which the state then makes publicly available.
- Notices of proposed transactions alert states to impending or potential changes to ownership or control. They can provide information necessary for state certificate of need or pre-transaction review and oversight programs. Notices can be made public or kept confidential. Even in states that lack authority to administratively review or approve/reject proposed health care transactions, a broad requirement for health care entities to provide advance notice of transactions allows the state to track patterns of consolidation and fully leverage existing state antitrust authority. At least 35 states require hospitals, and in some cases, other health care entities, to provide notice of certain proposed transactions or changes.
Transparency alone cannot prevent harmful consolidation nor address anti-competitive behavior, as better calibrated tools can. But transparency provides insights into changing health care markets and can serve as a foundation for or complement to additional strategies to address consolidation and control the growth in commercial health care prices.
Massachusetts’ Registration of Provider Organizations (MA-RPO) program requires provider organizations that meet certain revenue and patient thresholds to annually file ownership, financial, and other information with relevant state agencies. In addition, large providers must submit a notice of material change 60 days before proposed changes, including mergers and acquisitions. This information informs the state’s market oversight and analysis functions, and Massachusetts publicly posts the provider registry data and material change notices to allow policymakers, researchers, and market participants to understand and improve the state’s health care system.
The 2024 collapse of Steward Health Care, which stemmed in part from destabilizing private equity tactics, provided a stress test for these state programs and exposed a few blind spots. In response, Massachusetts enacted a law in January 2025 that, among other provisions, closed loopholes that had effectively exempted many private equity and corporate investors from provider transparency and oversight requirements. The law extends MA-RPO reporting requirements to include new information related to private equity investors, real estate investment trusts, and management services organizations, and increases the penalties for failing to report information from $1,000 per week to $25,000 per week. The law also adds specific transactions– such as private equity taking ownership or control of a provider group and a significant transfer of assets, including the sale and subsequent lease-back of a health care provider’s real estate –to the state’s list of material changes that require an advance notice.
Indiana enacted a slate of health care cost containment bills in 2025, including HB 1666, which requires a range of health care entities that operate in Indiana to report ownership information to the state on a regular basis. A similar bill failed to pass the year before. The law applies broadly to health care providers (though certain practitioner-owned practices are exempted) along with health insurers, health maintenance organizations (HMOs), third-party administrators (TPAs), and pharmacy benefit managers (PBMs). These entities must generally disclose the entities or people that hold an ownership or controlling interest or interest as a private equity partner to an applicable state agency. Hospitals, insurers, HMOs, TPAs, and PBMs must report annually and are subject to fines for noncompliance. Health care providers other than hospitals must report every other year and are not subject to fines.
The Department of Health must compile the ownership information reported to various state agencies into an annual report and post it online. As filed, the bill would have made this ownership information publicly available, but as passed, it contains broad exclusions. The state may omit the name of a person or entity that holds an ownership stake in any health care entity, as well as ownership information that is not widely available to the general public. It remains to be seen whether the information released under this law could, for example, help a person understand which entity owns or controls their doctor’s practice. The Department of Health can, however, share ownership information with the Office of Attorney General, which is authorized under this law to investigate the market concentration of a health care entity at any time, in addition to its existing authority related to health care antitrust investigations.
In April, New Mexico enacted a law to extend and expand expiring state regulatory authority from the Health Care Consolidation Oversight Act passed the previous year. HB 586 authorizes state regulators to oversee proposed transactions, including a change in ownership or control of a hospital, a change in control of the real estate on which a hospital is located, and the acquisition of an independent provider practice by an insurer or its affiliates. The updated law adds transparency provisions that the prior version lacked. It requires the New Mexico Health Care Authority to publicly post notice of and take public comment on proposed transactions. The agency must also annually post hospital ownership on its website and provide updates when there are changes to a hospital’s ownership or the real estate on which it stands. HB 586 passed on the heels of the failure of a separate oversight bill that included more robust reporting on ownership and control of health care entities.
Washington enacted a law that lays the groundwork for future ownership transparency. The preamble of the new law explains that Washington is currently ill-equipped to monitor trends in its health care market, including significant consolidation among health care entities and a sharp increase in private equity acquisitions, and understand their impacts on health care access and affordability.
The law directs the Department of Health, in consultation with other state agencies, to develop a plan for a “complete and interactive registry” that makes health care entity ownership and control transparent. The Department must specify which entities should report (including at least health systems, facilities, providers, insurers, and health care benefit managers) and what information should be collected. The law acknowledges the complexity in unearthing layers of often-obscured ownership or control and calls for strategies to understand direct and indirect ownership and control (and changes to them) by monitoring corporate structures, funding, and contractual relationships. The Department must submit a progress report to the legislature by the end of 2027 and a final report by late 2028. Lawmakers allocated $500,000 for the biennium to develop the plan.
Lawmakers in Maine, Minnesota, Texas, and Vermont filed ownership transparency bills in 2025 that did not ultimately make it across the finish line. These bills would have required certain health care entities to report on their ownership both annually and after a material change, and information would have been made publicly available. The bills would have generally required health care entities to disclose the entities or individuals that hold an ownership, investment, or controlling interest in them, along with their significant equity investors and relationships with management services organizations.
The states that passed ownership transparency bills thus far in 2025 demonstrate that progress is possible in states with starkly different political environments, though in some cases, only after a multi-session effort. Legislation considered in 2025 also shows that states are responding to the increasing corporatization of health care by tailoring transparency requirements to capture which corporate actors exert control over a health care entity’s operations or take possession of its real estate, even if they do not directly own the health care entity. Interest in ownership transparency may continue to grow as state policymakers seek tools to help inform consumers, control the growth in health care prices, and mitigate harms from consolidation in health care markets.
