Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017 #00115 

Submission Number:
00115 
Commenter:
Constance Salemi
State:
Maryland
Initiative Name:
Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017

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.