Norman PHO

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Norman Physician Hospital Organization — Factors Supporting Clinical Integration

Clinical integration is a somewhat imprecisely defined concept in the health care industry. Lawyers and health care executives have identified components and elements of clinical integration and frequently ask how many of...more

Price Fixing and Leveraging Concerns Alleviated by Promoted Efficiencies: More FTC Guidance on Clinical Integration

The Federal Trade Commission (FTC) has provided additional guidance, and comfort, to physicians seeking to clinically integrate for the purpose of, among other things, jointly negotiating payor contracts. This additional...more

Clinical Integration On A Promise And A Plan Federal Trade Commission Declines To Challenge Norman PHO On Antitrust Grounds

In This Issue: - Norman PHO - Key Conclusions - Implications for Established and Newly Forming Networks - Excerpt from Norman PHO: The Norman PHO is comprised of a single hospital system and...more

Just How Much Integration Is Enough: FTC Advisory Opinion Finally Provides Guidance For Competitors Seeking To Collaborate Or...

The Federal Trade Commission (FTC) recently issued its first advisory opinion addressing clinical integration programs since the enactment of the Affordable Care Act (ACA). Without a doubt the advisory opinion is useful for...more

FTC's Norman PHO Advisory Opinion - New Clinical Integration Guidance, Same Antitrust Analysis

The Federal Trade Commission (FTC) provided its first guidance for clinically integrated networks since passage of the Affordable Care Act (ACA) and the joint FTC/DOJ Accountable Care Organization (ACO) Antitrust Policy...more

FTC Staff Issues Favorable Clinical Integration Advisory Opinion That It Does Not Intend to Challenge Proposed Formation of...

On February 13, 2013, the FTC issued an advisory opinion letter that it did not plan to challenge the proposed creation of the Norman Physician Hospital Organization (“Norman PHO”)—which includes approximately 280...more

FTC Issues Another Favorable Clinical Integration Program Advisory Opinion

In a February 13, 2013, advisory opinion, the Federal Trade Commission (FTC) Bureau of Competition stated that it has no present intention to recommend that the FTC challenge a clinical integration program (CIP) proposed by...more

FTC Issues First Clinical Integration Advisory Opinion Post-ACA

FTC staff advisory opinions are not issued all that frequently and advisory opinions regarding clinical integration are issued even less frequently. The latest advisory opinion, issued last week, is therefore noteworthy, not...more

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