Submission Number: 00037 

Received: 5/31/2011 9:28:50 AM
Commenter: Matthew  Cantor
Organization: Constantine Cannon
State: New York
Agency: Federal Trade Commission
Initiative: Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program; FTC Matter No: V100017
Attachments:
00037-60097.pdf Size = 51 KB
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Submission Text
To Whom It May Concern: Attached is my comment on the Joint Proposed Statement of Antitrust Enforcer Policy regarding Accounting Care Organizations. It raises issues relevant to how market shares will be calculated of proposed ACOs for the purposes of determining whether they need not/may/must make filings with the Agencies in order to participate in Medicare's Shared Savings Program. I suggest herein that shares of commercially-insured ACO businesses be used to calculate these shares, as opposed to the share of Medicare businesses for which they are responsible. As the principal antitrust concern raised by ACOs is that they will allow collaborations of competitors to exercise market power in medical services markets for commercially-insured patients, I believe that the agencies should measure market share in that way. Thank you for your attention. Sincerely, Matthew L. Cantor