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Hospital associations argue premerger notification overhaul was unnecessary and harmful to industry

By Epstein Becker Green  
   August 29, 2025

During the Biden administration and under the leadership of then-Chair Lina Khan, the FTC adopted sweeping changes to the Hart-Scott-Rodino premerger notification requirements that went into effect on February 10, 2025. By the FTC’s own admission, these changes substantially increased the volume of information and the number of documentary attachments required to properly notify the enforcement agencies of a proposed transaction and, by conservative estimates, imposed a roughly fourfold increase in the time needed to prepare the HSR filing.

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