Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207 #00094

Submission Number:
Yao He
New York
Initiative Name:
Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207
Reference Number: P131207 The use of retail clinics remains low despite market growth. The misaligned growth in market and usage and the lost opportunity of reducing health expenditures signal a problem that calls for market or government solutions. Since the Patient Protection and Affordable Care Act (ACA) is starting its full implementation, waiting for new market responses seems to be a viable option but may incur opportunity cost. Since about half of all retail clinics still do not accept Medicaid and under twenty percent operate in low-income communities, there is potential for retail clinics to increase share of health care provision by extending services to the low-income population. However, I recommend the Federal Trade Committee (FTC) eliminate the major regulatory barrier, state scope-of-practice laws. This is a fundamental approach that promises long-term increase in the use of retail clinics but may face strong deterrence from interest groups. The strong deterrence largely stems from physician groups' rent-seeking behavior that promotes physician monopoly in the market of primary care provision and hurts competition among equally qualified service providers. Many studies have warned that state scope-of-practice laws restrict the functionality of non-physician practitioners despite qualification comparable to that of physicians. Eliminating such regulations can simplify and reduce the cost of retail clinic operation, thus expanding the scope of services and attracting more usage in general. State legislatures are responsible for changing the scope-of-practice laws. However, this approach may not be feasible because of strong interest group opposition. Physician groups, e.g. the American Medical Association, have consistently voiced their concerns that retail clinics disrupt the continuity of traditional primary care. Caring as these concerns sound, they also characterize physicians' rent-seeking behavior, i.e. protecting their income by requesting the government to restrict the number of service providers in the market. This behavior only promotes monopoly and hurts competition among equally qualified primary care providers. Eliminating state scope-of-practice laws for non-physician practitioners will break this monopoly and introduce competition, but physician groups will vehemently oppose and stall this effort as much as they can. Therefore, the FTC should examine this issue closely and intervene. I recommend that the FTC: - investigate physician groups' market share of primary care provision - advise states to eliminate scope-of-practice laws By breaking down barriers for retail clinics to increase market share of primary care provision, the FTC will promote competition in the health care market and protect consumers' right to less costly, more accessible, and more convenient primary care services of equal quality compared to traditional services. Disclaimer: I am a student at Columbia University. This comment to the Federal Trade Commission reflects my own personal opinions. This is not representative of the views of Columbia University or the Trustees of Columbia University.