Vermont’s H.583 was signed on 15 June 2026 and took effect 1 July 2026. Coverage of it has focused, understandably, on the new restrictions aimed at private equity groups and hedge funds. That focus is causing operators to miss the section that actually creates an obligation for them.
§ 9773 requires that on or before 1 March 2027, each health care facility and each management services organization provide information to the Green Mountain Care Board. There are two routes, and every entity takes one of them.
The two routes
| Your position as of 1 June 2026 | What you file by 1 March 2027 |
|---|---|
| A private equity group or hedge fund held an ownership or investment interest | The full ownership and control report under § 9773(b) |
| None did | An attestation that the entity currently has no private equity or hedge fund ownership or investment |
Read the second row again. There is no “not applicable” option. An owner-operated med spa management company in Vermont with no outside capital at all still files — the attestation is the filing.
What the full report asks for
For entities in scope, § 9773(b) reaches names, business addresses and business identification numbers for each person with an ownership or investment interest, each person with a controlling interest, and, for health care facilities, the management services organization — along with entities under common control and the entity’s most recent financial statement.
This is a disclosure regime, and disclosure regimes reward structures that were built to be looked at. If your management agreement would embarrass you in front of a regulator, the time to fix it is before the filing rather than after.
And it is ongoing
§ 9773 also contemplates reporting after 1 March 2027 when a private equity group or hedge fund takes on an ownership or investment interest, or modifies an existing one. This is not a single-event compliance item; put it on the recurring calendar.
What to do now
- Determine whether your Vermont entity is a “health care facility” or a “management services organization” as H.583 defines them.
- Fix the 1 June 2026 snapshot date — that is the date the report keys to.
- Decide which of the two routes you are on, and diarize the 1 March 2027 deadline.
- Review your management agreement against the § 9772 control list before you file.
Not the only staged deadline out there
Oregon’s SB 951 phases in over years. Indiana’s registration requirement lands in 2027. California’s SB 351 reshapes MSO agreements. The regulatory direction across states is the same — more disclosure about who controls clinical entities — and the deadlines are staggered enough that a single review is not enough.
Related reading
Frequently asked questions
When does Vermont H.583 take effect?
It was signed 15 June 2026 and took effect 1 July 2026.
Who must file with the Green Mountain Care Board?
Every health care facility and every management services organization, on or before 1 March 2027.
What if there is no private equity in our structure?
You file an attestation that the entity currently has no private equity or hedge fund ownership or investment.
What date does the report key to?
Whether a private equity group or hedge fund held an ownership or investment interest as of 1 June 2026.
General information about Vermont law, not legal advice. Filing obligations and deadlines should be confirmed with the Green Mountain Care Board and counsel licensed in Vermont.