News & Analysis as of

Accountable Care Organizations Antitrust Provisions

Foley & Lardner LLP

Antitrust: DOJ Scuttles ACO Guidance, Unsettles Ground under Provider Joint Contracting Models

Foley & Lardner LLP on

On Friday, February 6, 2023, the Department of Justice (DOJ) announced the withdrawal of the 2011 Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings...more

WilmerHale

Highway to the Danger Zone: DOJ Withdraws Safety Zone Guidance for Healthcare Industry

WilmerHale on

The Department of Justice Antitrust Division (DOJ) recently withdrew three sets of policy statements regarding the US antitrust agencies’ enforcement approach to conduct in the healthcare industry. These policy statements...more

Holland & Hart LLP

Withdrawal of Antitrust "Safety Zones"

Holland & Hart LLP on

The US Department of Justice recently announced its withdrawal of three decades-old policy statements recognizing antitrust “safety zones” relating to information sharing and collaboration among competitors. The statements...more

King & Spalding

DOJ Alters Standards for Information Sharing in Healthcare

King & Spalding on

On Friday, February 3, DOJ announced that it is withdrawing three policy statements of antitrust guidance it has provided and that have been adopted by the healthcare industry for close to 30 years. The statements include...more

Epstein Becker & Green

Antitrust Concerns for Large ACOs Operating in Commercial Markets

Epstein Becker & Green on

According to the “Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program” (“Policy Statement”), issued by the Federal Trade Commission and the...more

Epstein Becker & Green

Is Your Agreement Non-Exclusive in Name Only?

Epstein Becker & Green on

The legality of certain collaborative arrangements and contracts often rises and falls on whether the relationship between the parties involved is exclusive or non-exclusive. For example, the issue of exclusivity often...more

Polsinelli

DOJ-AmEx Case Could Have Ramifications for Health Care Providers

Polsinelli on

The U.S. Department of Justice's loss to American Express sends a message to health care providers: Steering, tiering, exclusive dealing and other contractual arrangements that appear to suppress competition in one part of...more

Sheppard Mullin Richter & Hampton LLP

CMS’ Proposed Regulations Include Significant Antitrust Implications For Entities Interested In Forming ACOs

The Centers for Medicare & Medicaid Services (CMS) released proposed regulations to clarify and build on current regulatory requirements for Accountable Care Organizations (ACOs) that participate in the Medicare Shared...more

Mintz

Antitrust and Health Care: An Update from the Federal Trade Commission

Mintz on

The interplay between the Affordable Care Act (ACA), Accountable Care Organizations (ACOs), and antitrust has been a matter of great moment for several years. It has been an issue in litigation such as the Federal Trade...more

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