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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

Tying, Tiering, Steering and Gag Clause Issues Front and Center Again

We previously reported on several cases involving successful antitrust challenges to proposed hospital mergers involving Hackensack Meridian Health System and Englewood Hospital in Bergen County New Jersey; RWJ Barnabas...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

FTC Seeks to Block Hospital “Mergers” in New Jersey and Utah

Just eight weeks after Hackensack Meridian Health System and Englewood Healthcare Foundation notified the Federal Trade Commission (“FTC”) that they were calling off their proposed merger following the Third Circuit Court of...more

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