Submission Number: 00115
Received: 5/31/2011 7:57:09 PM
Commenter: Constance Salemi
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: No Attachments
I would like to submit a suggestion for simplyfying the physician market share analysis. Markets in which familypractitioners, internists, general practitioners, and geriatric practitioners provide services are usually competitive. In contrast, the market in which a specialist competes is very likely to be concentrated. Therefore, the proposed rule should be amended to presume that a specialist has market power and impose a requirement that the specialist should be non exclusive in any ACO in which the specialist participates. If a specialist should want to be exclusive to an ACO, the proposed rule should give the specialist the oppoetunity to perform a market analysis.