CHA News

Major OHCA Developments to Track in 2024

What’s happening: OHCA ended 2023 with a proposed preliminary spending target of 3% annually for five years and it finalized cost and market impact review regulations.  

What else to know: OHCA’s policy development and implementation is expected to accelerate in 2024, specifically related to the adoption of an initial health care spending target. 

OHCA ended 2023 having achieved three important implementation milestones:  

  • On Dec. 18, 2023, OHCA finalized its regulations on the cost and market impact review (CMIR) process. On Jan. 1, OHCA began accepting online filings for material market transactions proposed to take place on or after April 1. OHCA leadership will provide an overview of the final CMIR regulations and be available to answer questions at CHA’s Jan. 8 webinar on the CMIR process.  
  • On Dec. 19, 2023, the Health Care Affordability Board met to discuss OHCA staff’s preliminary recommendation for the first statewide health care spending target. Specifically, staff proposed a 3% spending target for 2025-29. The proposal sparked significant conversation among the board members. With initial feedback from the board in hand, OHCA intends to return with a final staff recommendation for a spending target on Jan. 15, after which there will be additional board discussion of the proposal followed by a 45-day public comment period. Between early March and the end of May, the board must adopt a final target. CHA submitted relevant comments to the board ahead of the Dec. 19 meeting.  
  • OHCA made progress toward establishing a process for collecting health care spending data. In fall 2023, OHCA proposed regulations and supplemental guidance on the total health care expenditure data collection process. The rules place the responsibility for providing this data on payers instead of providers. After consideration of public comments (including those from CHA) and additional public meetings on the proposed regulations, OHCA will finalize the regulations in spring 2024.  

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In 2024, OHCA policy development and implementation will only accelerate, specifically as it relates to the adoption of an initial health care spending target. Engagement from California’s hospitals and health systems will be critical to ensure OHCA sets standards that are attainable, sustainable, and supportive of hospitals’ ability to provide access to high-quality and equitable care. 

For more information, contact Ben Johnson, vice president, policy at