This ruling can harm the viability of doctors' practices if presented in a "one size fits all" manner. Perhaps you might permit some sort of algorithm by which doctor's may charge private rates higher than Medicare rates? I am intimately familiar with this situation as I maintain an office in a high-rent underserved area of New York City. It is underserved because of the high rents. My solution is to charge rates 20% higher to cover the rent. I don't take home any more money, but I provide a much needed service in this neighborhood. A subtle analysis of the factors driving the higher rates in Roaring Fork would allow you to create an algorithm that defeats collusion but at the same time permits physicians to charge rates high enough to keep their practices afloat. Please keep in mind the history regarding Ob-Gyn malpractice premiums: if you don't let the physicians make enough money to reward their hard work (a quarter of million dollars in education debt, 12 years of training, sacrifice of family and friends for the greater good), they will leave and you will have a major physician shortage. Samuel L. Sharmat, MD
Proposed Consent Agreement In the Matter of Roaring Fork Valley Physicians I.P.A., Inc., FTC File No. 061 0172 #546725-00003
Samuel L. Sharmat, M.D., P.C.
Proposed Consent Agreement In the Matter of Roaring Fork Valley Physicians I.P.A., Inc., FTC File No. 061 0172