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Challenging the FTC’s Constitutionality in the Aftermath of Jarkesy

The Supreme Court on June 27 issued its opinion in Securities and Exchange Commission v. Jarkesy in which it held that when the SEC seeks civil penalties against a defendant for securities fraud, the Seventh Amendment...more

District Court Dismisses Welsh Carson While Allowing the FTC to Proceed Against U.S. Anesthesia Partners

In a prior post, we discussed the Federal Trade Commission’s (“FTC”) lawsuit against U.S. Anesthesia Partners (“USAP”) and the private equity firm Welsh, Carson, Anderson & Stowe (“Welsh Carson”). Most recently, the U.S....more

Analysis: How the FTC and DOJ Final Merger Guidelines Impact on Health Care System Mergers

In prior posts, we discussed the draft, updated merger guidelines that had been issued by the Federal Trade Commission and the Department of Justice (sometimes referred to as the “Agencies”) in July of last year. At that...more

U.S. Anesthesia Partners and Welsh Carson File Motions to Dismiss FTC Antitrust Case

As reported in a prior blog post, the Federal Trade Commission (“FTC”) filed suit in federal district court in September alleging that U.S. Anesthesia Partners, Inc. (“USAP”), and the private equity firm Welsh, Carson,...more

Patients Suing Hospitals for Antitrust Violations – Do They Have Standing?

A recently decided case out of Connecticut provides a useful examination of how antitrust standing issues may be analyzed in cases involving commercially-insured patients directly suing a health care system alleging economic...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 Calls for Major Changes in Hart-Scott-Rodino Rules

The Federal Trade Commission (“FTC”) on June 27 issued a proposed rule pursuant to which it would amend its Hart-Scott-Rodino Act (“HSR”) form and instructions and in so doing make major “top-to-bottom” changes for the first...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

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

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 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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