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Has Humphrey’s Executor Been Effectively Overruled on the Supreme Court’s Emergency Docket with Impact on the FTC?

The Supreme Court last week granted the stay requested by the Government enjoining the enforcement of the U.S. District Court for the District of Columbia’s orders involving President Trump’s firing of members of the National...more

Federal Court: No Sherman Act Violation Absent Anticompetitive Conduct and Anticompetitive Effects

Back in late January, U.S. District Court Judge Xavier Rodriguez in the Western District of Texas granted summary judgment to Loredo Medical Center (LMC) and a locally-based interventional cardiology group (LMC Cardiology...more

Higher Prices, Reduced Access, Lower Quality Care: HHS, FTC, DOJ Report Harshly Criticizes Provider Consolidation and Private...

In March 2024, the Federal Trade Commission (FTC), the Department of Justice (DOJ) and the Department of Health and Human Services (HHS) (collectively, Agencies) issued a request for information (RFI) seeking public comment...more

FTC Settlement Proposes Consent Order to Monitor Private Equity Firm Welsh Carson’s Acquisitions Plans

We previously reported on the Federal Trade Commission’s (FTC) lawsuit against U.S. Anesthesia Partners (USAP) and the private equity firm Welsh, Carson, Anderson & Stowe (Welsh Carson). In the lawsuit, the FTC alleges that...more

Novant Health Abandons Proposed Purchase Following Fourth Circuit’s Issuance of Injunction

We have been reporting on the Federal Trade Commission’s continuing effort to block Novant Health’s purchase of Lake Norman Regional Medical Center and Davis Regional Psychiatric Hospital from Community Health Systems. Last...more

Health Care Antitrust Update Part II: Recent Federal and State Enforcement Initiatives and Litigation Involving the FTC’s...

Over the past several months, antitrust enforcement activity in the healthcare provider sector has continued to steadily increase. In Part I of this two-part update, we discussed recent lawsuits involving private equity...more

Health Care Antitrust Update Part I: Key Developments in Antitrust Litigation Involving Health Care Acquisitions and Mergers

Over the past several months, antitrust enforcement activity in the healthcare provider sector has continued to steadily increase. In the litigation context, this has involved, in addition to new lawsuits filed by the...more

Louisiana’s COPA Exempts Hospital Acquisitions from Federal Antitrust Laws

As explained in prior posts, the Federal Trade Commission (“FTC”) filed suit in April of this year in Federal District Court for the District of Columbia seeking to enjoin Louisiana Children’s Medical Center (“LCMC”) from...more

FTC Sues Private Equity Firm and Anesthesia Group Alleging Unlawful Monopolization in Texas Market

Yesterday, the Federal Trade Commission (“FTC”) filed suit in federal district court alleging that U.S. Anesthesia Partners, Inc. (“USAP”), and the private equity firm Welsh, Carson, Anderson & Stowe (“Welsh Carson”), which...more

Details on the 2023 DOJ and FTC Proposed Merger Guidelines’ Potential Impact on Health Care Systems

In a prior post, we reported on the issuance by the U.S. Department of Justice and the Federal Trade Commission (the “Agencies”) of a draft update to their merger guidelines (the “Proposed Guidelines”) intended to describe...more

FTC Follows DOJ and Withdraws Antitrust Policy Statements

On July 14, the Federal Trade Commission (“FTC”), as anticipated, announced that it was withdrawing two antitrust policy statements related to enforcement in health care markets: • Statements of Antitrust Enforcement Policy...more

Federal Court Grants Medical Center’s Request for Transfer of FTC Suit

As explained in prior posts, the Federal Trade Commission (“FTC”) filed suit in the U.S. District Court for the District of Columbia seeking to enjoin Louisiana Children’s Medical Center (“LCMC”) from continuing to integrate...more

FTC Sues to Compel State-Approved Hospital Acquisitions to Comply with Hart-Scott-Rodino Act Requirements

Last Thursday, the Federal Trade Commission (“FTC”) took the step of filing suit in federal court asserting that parties to a hospital acquisition who had obtained a Certificate of Public Advantage (“COPA”) from their state...more

U.S. DOJ Announces Withdrawal of Health Care Market Policy Statements

Last Friday, Feb. 3, the U.S. Department of Justice (“DOJ”) issued a press release in which it announced the withdrawal of what it described as three “outdated” antitrust policy statements related to enforcement in health...more

Continued Spotlight on Cross-Market Hospital Mergers

Mergers between competitor hospitals in the same geographic market have been routinely scrutinized and often challenged by the Federal Trade Commission (“FTC”) and the U.S. Department of Justice (“DOJ”). Cross-market mergers...more

COPA-Like Agreements in Pennsylvania and COPA Rules in Neighboring States

In the first part of this article, we discussed the Federal Trade Commission’s (“FTC”) recently issued staff policy paper strongly urging states to avoid using Certificates of Public Advantage (“COPA”) which seek to immunize...more

Federal Trade Commission Policy Paper Takes Hard Stance Against Certificates of Public Advantage

Background- Many states have enacted Certificate of Public Advantage (“COPA”) laws which seek to permit hospital mergers that might otherwise have been challenged by the Federal Trade Commission (“FTC”) and found to violate...more

Possible Changes to the 2010 Merger Guidelines Regarding Pro-Competitive Efficiencies

In the recent hospital merger cases successfully challenged by the FTC (whether via the parties calling off the merger or losing in federal court), the merging parties have argued that, while the merger would not be likely to...more

FTC Reemphasizes Antitrust Concerns as New Jersey and Utah Health Systems Abandon Proposed Mergers

As reported in our June 13, 2022 blog post, the Federal Trade Commission (FTC) filed complaints on June 2 seeking to block the proposed merger of RWJBarnabas Health and Saint Peter’s Healthcare System in New Jersey and the...more

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