Back in 1996, the Federal Trade Commission and Department of Justice, in providing antitrust guidance for multi-provider networks, considered financial integration and clinical integration as separate pathways for such networks to avoid per se violations of the antitrust laws and, instead, to be treated under the rule of reason, allowing for an assessment of their procompetitive vs. anticompetitive effects. With 65 organizations now participating in Medicare shared savings initiatives, including the 27 Medicare Shared Savings Program participants announced on April 10 ...
Blog Editors
Recent Updates
- DOJ Subpoena Seeks Health Information of Hospital Patients Receiving Gender-Affirming Care: Will Judge Grant Motion to Quash?
- Podcast: 42 CFR Part 2 Final Rule: What’s Changing and What Do You Need to Know? – Diagnosing Health Care
- Congress Creates Yet Another Cliff for Medicare Telehealth Extensions (and We’re Running Out of Metaphors)
- OIRA Memo on Agency Deregulation: Implications for Health Care
- Outside Counsel’s Internal Investigations—Including Those Relating to Health Care—Are Privileged and Protected from Disclosure