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Oregon Health Authority

039-OHSU-Legacy



Line of arrows that says submission, preliminary, comprehensive, 1 year, 2 year, 5 year reviews. Currently on comprehensive. 

Current Status

OHA accepted a complete notice on October 4th, 2024 and is currently conducting a 180-day comprehensive review of this transaction. OHA requested more information from the entities on 3/24/25. The review period is paused until OHA accepts a complete response from the entities with the requested information. There are 87 days left in the review period after OHA accepts a complete response from the entities. 

OHSU has their own website dedicated to the transaction. Please note that the HCMO@OHSU.edu email address listed on OHSU's website is not affiliated with OHA. Feedback or comments submitted to HCMO@OHSU.edu will not be received by OHA. 

OHA is accepting public comments throughout the review period. To submit a public comment to OHA, include the word "OHSU" or "Legacy" in your comment and share your thoughts in one of these ways:

For any questions, email hcmo.info@oha.oregon.gov.

OHA Publications

OHA has published the following reports and communications to date:

Community Review Board

OHA is convening a community review board for this transaction. Community review boards are temporary groups formed solely to provide input to OHA about a particular health care business deal. The community review board has two key roles:

  1. Help OHA understand how a deal could affect people and communities in Oregon.
  2. Make a recommendation about whether OHA should approve a deal to proceed as planned, apply conditions to the deal, or disapprove the deal.

Community Review Board Meetings


Application Process

OHA is no longer accepting community review board applications for this transaction. For more information about the community review board application process, see the following materials:

Community Review Board Promotional Flyer:
For any questions, email hcmo.info@oha.oregon.gov. 

One Page Transaction Summary

Filings and Submissions

On November 13, 2024, OHA posted revised redacted materials from the entities as well as an updated redaction log. See documents linked below. On January 22, 2025, OHA posted additional materials from the entities and an updated redaction log.

Notice of M​aterial Change Transaction Form and Exhibits​

Supplemental Information from Notice



​Attachmen​ts to RFI response


The Community Review Board (CRB) hosted a public hearing​ where represententatives of OHSU and Legacy provided answers to questions the CRB created. During the public hearing, there was not enough time to answer all the questions, OHSU and Legacy provided a written response to the remaining questions:



Public Comments

  • Public comments received before the notice was submitted (8/21/23-10/4/24)
  • Public comments received after the notice was submitted (10/4/24-current)
  • Letter of support on behalf of SEIU Local 49, AFSCME, Basic Rights Oregon, and Oregon Nurses Association (submitted 10/31/2024)
  • Letter of opposition submitted by the Oregon Trial Lawyers (submitted 11/4/2024)
  • Public comment from the Inatai Foundation (submitted 11/15/24)
  • Public comment from Larry Kirsch (submitted 11/20/24)
  • Letter of opposition submitted by UFCW Local 555 (submitted 11/25/24)
  • Public comment submitted by Unrepresented Employees (submitted 11/26/24) 
  • Public comment submitted by Brown University and American Economic Liberties Project (submitted 1/6/25)
  • Letter originally submitted to OHSU Board of Directors 6/7/24, submitted by Joseph McNaught (submitted 1/10/25)
  • Report prepared for Community First Campaign, submitted by Scott Benbow as public comment (submitted 1/17/25)
  • Public comment submitted by OSPIRG, United States of Care, Oregon Consumer Justice, and Health Care for All Oregon (submitted 1/17/25)
  • Public comment submitted by OHSU 1/26/25
  • Public comment memo submitted by Larry Kirsch and John McAnulty (submitted 1/27/25)
  • Public comment submitted by Joe Ness, COO of OHSU (submitted 2/6/25)
  • Public comment submitted by the Community First Campaign (submitted 2/7/25)
  • Public comment submitted by Joseph McNaught (submitted 2/9/25)
  • Public comment submitted by AFSCME, ONA, SEIU (submitted 2/10/25)
  • Public comment submitted on behalf of a group of funders who support the Community First Campaign (submitted 2/12/25)
  • Public comment submitted by the Community First Campaign (submitted 2/12/25)
  • Public comment submitted by Larry Kirsch for the community review board (submitted 2/14/25)
  • Public comment submitted by the Oregon Anesthesiology Group (submitted 2/17/25)
  • Public comment submitted by John Santa for the community review board (submitted 2/17/25)
  • Public comment submitted by Neal Barnard, Physicians Committee for Responsible Medicine (submitted 2/18/25)
  • Public comment submitted by unrepresented employees (2/21/25)
  • Public comment submitted by Dr. Lisa Jones-Engel, PETA (2/25/25)
  • Public comment submitted by POIC President and CEO Joe McFerrin II (2/28/25)
  • Public comment submitted by many individuals regarding the Oregon National Primate Research Center (2/25/25-current)
  • Public comment submitted by Donn Spight (3/4/25)
  • Public comment submitted by John Santa (3/4/25)
  • Public comment submitted by the BIPOC Legislative Caucus (3/4/25)
  • Public comment submitted by Immigrant and Refugee Community Organization (IRCO) on behalf of Mr. Lee Po Cha (3/4/25)
  • Public comment submitted by the Oregon Academy of Family Physicians (3/4/25)
  • Public comment submitted 3/4/25
  • Public comments submitted during the public heaing 3/5/25
  • Public comment submitted 3/5/25
  • Public comment submited by the Oregon Health Equity Alliance (3/5/25)
  • Public comment submitted by Neal Barnard (3/7/25)
  • Public comment submitted by UFCW 555 (3/10/25) 
  • Public comment submitted by Sheila Dooley (3/11/25)
  • Public comment submitted by Maria Rodriguez (3/11/25)
  • Public comment submitted by Planned Parenthood Columbia Willamette and Planned Parenthood of Southwestern Oregon (3/13/25)
  • Public comment submitted by Larry Kirsch (3/19/25)
  • Public comment submitted by Pastor Mark Jackson (3/21/25)
  • Public comment submitted by Neal Barnard (3/21/25)
  • Public comment submitted by Dr. Zaman (3/21/25)
  • Public comment submitted by Holden Leung, CEO of Asian Health & Service Center (3/21/25)
  • Public comment submitted by Steve Stadum (3/21/25)
  • Public comment submitted by SEIU Local 49 (3/21/25)
  • Public comment submitted by Legacy Health regarding public engagement (3/21/25)
  • Public comment submitted by Representative Gomberg, Representative Courtney Neron, and Representative Farrah Chaichi (3/23/25)
  • Public comment from multiple individuals about the Oregon National Primate Research Center (3/17/25-Current)
  • Public comment submitted by SEIU-UHW Education Fund (3/26/25)
  • Public comment from the Community First Campaign (3/26/25)
  • Public comment submitted by OHSU, their press release related to the Oregon National Primate Research Center. (3/27/25)
  • Public comment submitted by Rajesh Reddy regarding the Oregon National Primate Research Center (3/28/25)
  • Public comment submitted by Neal Barnard regarding the Oregon National Primate Research Center (3/28/25)
  • Public comment submitted 3/28/25
  • Public comment submitted 3/26/25
  • Public comment submitted by Gabby Martinez deCastro, Esq. (submitted 3/29/25)