The rescission of the 2021 Executive Order on Promoting Competition, coupled with a more permissive tone from the Federal Trade Commission (FTC), marks a pivotal shift in the hospital and health system M&A landscape. While not a full deregulation, this change signals greater flexibility for health systems pursuing strategic growth, consolidation, or restructuring. For executives, this moment presents both a time-sensitive opportunity and a call for disciplined, community-conscious action.
A strategic opportunity: Federal tailwinds, local imperatives
Guidehouse’s health system M&A playbook emphasizes that M&A is not just transactional—it’s transformational. In today’s climate, transaction decisions around acquiring, divesting, or partnering must align with long-term strategy, community benefit, and operational sustainability.
With federal scrutiny easing, regulatory authority will increasingly shift to state regulators—attorneys generals, governors, certificate of need (CON) laws, local/municipal stakeholders, and health system boards. Health systems must now evaluate M&A through parallel lenses: regulatory feasibility, community impact, operational transformation, and long-term sustainability. Local factors like payer mix, provider relationships, workforce dynamics, cost structure, digital maturity, and rural access carry greater weight than ever.
While many health systems may benefit from increased latitude under this revised posture, the greatest advantage accrues to organizations that know their transactional identity—buyer, seller, or partner—and can align it to local market needs, organizational strengths, and community responsibilities. Systems that previously paused transactions due to federal headwinds should revisit those plays under today’s conditions. Buyer and seller archetypes will help executives navigate this evolving M&A environment with greater precision.
Buy-side leverage
Organizations with scale, capital, and strategic clarity can seize this opportunity, particularly if they operate with a disciplined integration playbook and a transformative operating model vision.
Sell-side negotiating power
Certain health systems and standalone hospitals, especially those facing performance or sustainability challenges, may find this climate more favorable to reposition, realign, or offload assets on better terms. Selling is not a retreat but a strategic act of stewardship when it preserves access, unlocks needed capital, and improves community resilience.
Balancing speed with strategy
Looser regulations may accelerate deal-making, but speed alone is not the goal—it’s a lever for strategic alignment. Without discipline, rapid moves risk unrealized synergies, integration drag, and financial strain. The optimal posture is to move quickly where the strategic fit is clear. A fast, focused, and deliberate tempo can seamlessly shape markets, set terms, mitigate risk, and secure stakeholder buy-in.
Five ways to align strategy with speed
The health system M&A playbook provides a disciplined lens to evaluate this changing terrain. The focus now must shift from regulatory hurdles to strategic alignment and operating model impact.
The regulatory climate may be more permissive, but the real opportunity lies in strategic execution. Executives who align M&A moves with their system’s mission, market role, and technology priorities will drive resilient, value-based growth—and shape the future of healthcare delivery—amid uncertainty.
Guidehouse is a global AI-led professional services firm delivering advisory, technology, and managed services to the commercial and government sectors. With an integrated business technology approach, Guidehouse drives efficiency and resilience in the healthcare, financial services, energy, infrastructure, and national security markets.