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  Contents    Advisory Opinions: Health Care Antitrust Issues

Topic and Yearly Indices of Health Care Antitrust  Advisory Opinions By Commission and Staff [PDF 100KB]

Overview of the Advisory Opinion Process at the Federal Trade Commission
Presented by Judith A. Moreland at the National Health Lawyers Association/Antitrust in the Health Care Field on February 13 and 14, 1997.

Dunlap Memorial Hospital
Letter from Jeffrey W. Brennan to Judy Erb, dated January 6, 2004

re: Transfer of pharmaceuticals at cost by non-profit hospital to patients of non-profit Free Clinic
Medical Group Management Association
Letter from Jeffrey W. Brennan to Gerald Niederman, dated November 3, 2003
Bay Area Preferred Physicians
Letter from Jeffrey W. Brennan to Martin J. Thompson, dated September 23, 2003
Arkansas Children's Hospital

Letter from Jeffrey W. Brennan to Victoria Bennet, dated March 13, 2003

re: Sale of pharmaceuticals by non-profit children's hospital to patients seen in clinics operated by the University of Arkansas for Medical Sciences on the hospital's campus.

Valley Baptist Medical Center
Letter from Jeffrey W. Brennan to Louise M. Joy, dated March 13, 2003
 
re: Sale of pharmaceuticals by non-profit hospital to contracted workers who provide services at the hospital.
 
PriMed Physicians
Letter from Jeffrey W. Brennan to Gregory G. Binford, Benesch Friedlander Coplan & Aronoff LLP, dated February 6, 2003

re: proposal of PriMed Physicians, a physician group practice with 55 physician employees located in Dayton, Ohio, to create with other Dayton-area physicians an advocacy group to undertake "a campaign to inform and educate the general public" about, in the physicians' opinion, the "ill effects and other consequences of the policies and procedures, including depressed reimbursement, by third party payers in Dayton."
 
Health Access Inc.
Letter from Jeffrey W. Brennan to Stephen D. Keiss, dated March 8, 2002

re: Sale of vaccines by non-profit hospital to affiliated wellness center.

MedSouth, Inc.
Letter from Jeffrey W. Brennan to John J. Miles, Ober, Kaler, Grimes & Shriver, dated February 19, 2002

re: proposal of MedSouth, Inc., a physician independent practice association located in Denver, Colorado, to integrate partially its member physicians' practices.
 
Connecticut Hospital Association
Letter from Jeffrey W. Brennan to Robert M. Langer, Wiggin & Dana LLP, dated December 20, 2001

re: The applicability of the Non-Profit Institutions Act (NPIA or the Act) to sales of pharmaceuticals by CHA member hospitals to their retired employees
 
Harvard Vanguard Medical Associates, Inc.
Letter from Jeffrey W. Brennan to David Marx, Jr., dated 12/18/01

re: Sale of pharmaceuticals by non-profit, multi-specialty medical clinic to employees and to patients treated at the clinic).
 
Northeast Pharmacy Service Corporation
Letter from Richard A. Feinstein to Paul E. Levenson, The Rufus Choate House, dated July 27, 2000

re: Proposal to establish a network of independent pharmacies in Massachusetts and Connecticut.
 
BJC Health System
Letter from Richard A. Feinstein to Gary Senner, dated November 9, 1999 
 
re: Applicability of the Non-Profit Institutions Act 
 
Orange Pharmacy Equitable Network
Letter from Richard A. Feinstein to John A. Cronin, Pharm D., J.D, dated May 19, 1999
 
re: OPEN's intention to establish a network of independent community pharmacies and pharmacists
 
Wesley Health Care Center, Inc.
Letter from Richard A. Feinstein to David A. Ruffo, dated 4/29/99
 
re: Sales of pharmaceuticals by non-profit skilled nursing facility to volunteers working at the center
 
Associates in Neurology
Letter from Robert F. Leibenluft to Robert C. Norton, dated 8/13/98

re: Independent provider association composed of eleven neuorologists in the Los Angeles area
 
Phoenix Medical Network, Inc.
Letter from Robert F. Leibenluft to William T. Harvey, dated 5/19/98

re: Physician network of osteopathic services providers
 
North Mississippi Health Services
Letter from Michael D. McNeely to Bruce J. Toppin, dated 1/7/98
 
re: Sales of pharmaceuticals by non-profit hospital to patients of the hospital’s cancer treatment center).
 
Alliance of Independent Medical Services, LLC
Letter from Robert F. Leibenluft to Timothy C. Cashmore, dated 12/22/97

re: Network of ambulance and ambulette services providers formed to contract for transportation services with third party payers
 
Community Hospital, Inc.
Letter from Robert F. Leibenluft to Darrell O. Fancher, dated 12/22/97

re: Corporate restructuring of nonprofit hospital corporation
 
New Jersey Pharmacists Association
Letter from Michael D. McNeely to Allen Nichol, Pharm.D., dated 8/12/97

re: NJPA Proposal to Establish Two Pharmacist Service Networks.
 
First Look, L.L.C.
Letter from Robert F. Leibenluft to James L. Wiant, dated 6/19/97

re: Network of optical and vision services providers
 
Yellowstone Physicians, L.L.C.
Letter from Robert F. Leibenluft to David V. Meany, dated 5/14/97
 
re: Multispecialty physician network joint venture
 
Henry County Memorial Hospital
Letter from Michael D. McNeely to Clifton E. Johnson, dated 4/10/97
 
re: Sales of pharmaceuticals by non-profit hospital to patients of hospital PHO
 
Foundation for the Accreditation of Hematopoietic Cell Therapy
Letter from Robert F. Leibenluft to Paul L. Yde, dated 4/17/97
 
re: Standard-setting and accreditation program
 
Ohio Ambulance Network
Letter from Robert F. Leibenluft to Shawn M. Lyden, dated 1/23/97

re: Network of ambulance and ambulette services providers
 
Mobile Health Resources, L.L.C.
Letter from Robert F. Leibenluft to John A. Cook, dated 1/23/97

re: Network of ambulance companies
 
Southwest Florida Oral Surgery Associates
Letter from Robert F. Leibenluft to Guy E. Whitesman, dated 12/2/96
 

re: Cooperative of oral and maxillofacial surgery practices
 
North Ottawa Community Hospital
Letter from Michael D. McNeely to Sheldon Klein, dated 10/22/96

re: Sales of pharmaceuticals by non-profit hospital to unaffiliated, non-profit hospice
 
Business Health Companies, Inc.
Letter from Robert F. Leibenluft to Ralph T. Smith, Jr., dated 10/18/96

re: Survey of hospital prices by third-party consultant
 
North Mississippi Health Services
Letter from Michael D. McNeely to Bruce J. Toppin, dated 10/3/96
 
re: Sales of pharmaceuticals by non-profit medical center to retired employees
 
Valley Baptist Medical Center
Letter from Michael D. McNeely to Daniel L. Wellington, dated 9/19/96

re: Sales of pharmaceuticals by non-profit medical center to medical center operated clinic
 
Mayo Medical Laboratories
Letter from Robert F. Leibenluft to George A. Cumming, Jr., Esquire, dated 7/17/96
 
re: Laboratory services
 
William W. Backus Hospital
Letter from Michael D. McNeely to Robert M. Langer, dated 6/11/96

re: Sales of pharmaceuticals by non-profit hospital to related non-profit clinics
 
American Medical Association
Letter from Robert F. Leibenluft to Kirk B. Johnson, dated 3/26/96

re: Dissemination of information concerning proposed revisions of the Medicare RBRVS
 
Uronet of Louisiana, L.L.C.
Letter from Robert F. Leibenluft to Christopher C. Johnston, dated 1/23/96
re: IPA network of urologists
 
Southern Arizona Therapy Network, Inc.
Letter from David R. Pender to Martin Janello, dated, 12/7/95

re: provider network of physical, occupational and speech therpists
 
Columbine Family Health Center
Letter from David R. Pender to Richard J. Sahli, dated 11/8/95

re: Addition of a patient sorting provision to an agreement between an acute care hospital and a rural health care clinic
 
Eastern Ohio Physicians Organization, Inc.
Letter from Mark J. Horoschak to Stephen P. Nash, dated 9/28/95

Re: Multi speciality physician organization
 
Central Texas Medical Group
Letter from Mark J. Horoschak to John P. Dunn, M.D., dated 9/28/95

re: IPA plans to distribute information and educate its members on managed care and community issues).
 
Hematology/Oncology Care Specialists of Western Pennsylvania, P. C.
Letter from Mark J. Horoschak to Stephen P. Nash, dated 9/21/95

re: Physician network of hematology/oncology services providers
 
Otolaryngology Specialty Providers of Georgia
Letter from Mark J. Horoschak to Thomas W. Rhodes, dated 8/15/95

re: Physician network of otolaryngology services providers
 
Northwestern Nevada Orthopaedic Surgery Alliance
Letters from Mark J. Horoschak to Jacqueline C. Cox, dated 7/11/95 and 7/27/95

Re: Physician network of orthopaedic services providers
 
Elmore Community Hospital/Community Hospital
Letter from Mark J. Horoschak to Derrell O. Fancher, dated 06/20/95

re: a purchasing joint venture in AL
 
California All Health
Letter from Mark J. Horoschak to Messrs. Kopit and Barnes, dated 06/14/95

re: HMO joint venture in four counties: Los Angeles, San Bernardino, Riverside and Kern
 
Erlanger Medical Center/Memorial Hospital/Women's East
Letter from Mark J. Horoschak to Messrs. Smith and Boehm, dated 05/31/95

re: to operate jointly a new hospital in Chattanooga
 
Oakland Physician Network, L.L.C.
Letter from Mark J. Horoschak to John A. Cook, dated 3/28/95

re: Primary care physician network joint venture
 
Rocky Mountain Cardiovascular Affiliates
Letter from Mark J. Horoschak to Neil E. Ayervais, dated 9/23/94

re: Limited liability company composed of physician cardiovascular services practices
 
Palmetto Dental Alliance
Letter from Mark J. Horoschak to Scott Y. Barnes, dated 9/23/94

re: Proposed exclusive provider organization to provide dental services to beneficiaries of third party health benefits plans
 
Suffolk County Dental Society
Letter from Mark J. Horoschak to Steven L. Roberts and Albert A. Sunshine, dated 7/6/94

re: Legality of "exclusive dental plans"; proposed dental society disciplinary action against dentists sponsoring such plans
 
South East Managed Care Organization/Jackson Medical Cooperative
Letter from Mark J. Horoschak to George Q. Evans, dated 7/5/94
re: Physician network joint venture between physician directed managed care organization and group of physician providers
 
ACMG, Inc
Letter from Mark J. Horoschak to Paul W. McVay, dated 7/5/94

re: Proposed agreement between state medical society and independent health care management and development company to establish society sponsored state-wide PPO
 
Elkhart General Hospital
Letter from Michael D. McNeely to Clifton E. Johnson, dated 6/13/94

re: Sales of pharmaceuticals by non-profit hospital to hospital operated home health care program
 
American Medical Association
Letter from Donald S. Clark to Kirk B. Johnson, dated 2/14/94

re: Professional society peer review of physicians' fees: required physician participation in advisory fee review; medical society discipline for fee-related conduct
 
Presentation Health System
Letter from Donald S. Clark to Tamara D. Lee, dated 12/21/93

re: Sales of pharmaceuticals by non-profit hospitals to related non-profit long-term care facilities
 
California Managed Imaging Medical Group, Inc.
Letter from Mark J. Horoschak to J. Bert Morgan, dated 11/17/93

re: Radiology services PPO network

Last Updated: Wednesday, October 13, 2004