What was signed
Reed Smith reported that Illinois HB 5000, Public Act 104-0782, was signed by Governor Pritzker on August 7, 2026, with the amended provisions taking effect January 1, 2027. The law removes the January 1, 2027 sunset from the state's health care transaction notice provisions, making them permanent. Reed Smith notes that one related provision, in the Health Facilities Planning Act, loses its 2027 sunset but still repeals on December 31, 2029.
What it covers
The 2024 notice requirement applied to deals between two or more health care facilities or provider organizations. According to the article, coverage now extends to any transaction involving those entities, and to any entity that will directly or indirectly own or control one or more of them. The article says the law now expressly reaches private equity. It defines a private equity company as one that pools capital from individuals or entities and, at any level of ownership, directly or indirectly owns or controls an Illinois health care entity, or an out of state health care entity with at least $10 million in annual revenue from Illinois patients. Partial and indirect ownership count.
Notice, timing and enforcement
Written notice to the Attorney General is due no later than 30 days before closing. If the Attorney General asks for more information before closing, the closing date moves to 30 days after the parties comply. The Attorney General can seek $500 per day from parties that fail to give timely notice, and can seek a temporary restraining order or injunction in the circuit courts of Sangamon or Cook County after giving a noncompliant party 10 days to cure.
Does it reach ABA practices?
The article says physician groups are covered only if they qualify as provider organizations, meaning entities that represent 20 or more providers and contract with health carriers, and that facilities operated as part of a physician's practice are excluded. It does not address behavioral health providers. We have not read the statute, so whether a particular ABA practice or sale is covered depends on whether it fits a covered facility category or the provider organization definition.
Why it matters to an owner preparing to sell
Analysis: If a sale is covered, the 30 day notice and the Attorney General's power to move the closing date become part of the timeline, and a buyer that is a private equity company is now within the definition. In Illinois this sits on top of the licensee ownership rule in Section 150, so an owner should ask counsel early which of the two rules shape the structure of the deal.
If a sale is on your horizon, the sell side diligence work reads your compliance record the way a buyer's counsel will, before the buyer does, alongside your counsel. If you are already in a sale process, your counsel comes first.
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This brief rests on the reporting linked above and is labeled accordingly. Dossiers on this site are read to primary sources. Education only; nothing here is legal advice.
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