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AHA Response to Employee Retirement Income Security Act (ERISA) RFI
Health insurers have gone through dramatic vertical consolidation since ERISA was signed into law. Over the last decade, the major corporate insurers have spent billions of dollars acquiring not only other plans, but also providers, pharmacy service companies, and health technology and claims adjudication systems.
AHA Letter to the Attorney General and FTC on Draft Merger Guidelines
The Agencies now offer draft merger guidelines that provide virtually no meaningful guidance to hospitals and health systems. The Draft Guidelines ignore serious flaws in contemporary enforcement practice and overlook recent judicial opinions that contradict their more aggressive proposed changes. The Agencies propose a structural presumption that is arbitrarily low and potentially fatal to beneficial transactions.
AHA Urges FTC to Withdraw Proposed Changes to Premerger Notification Rules
American Hospital Association opposes the Federal Trade Commission’s proposed amendments to the Hart-Scott-Rodino (HSR) form and instructions.
FTC Urged to Extend Comment Period for Draft Merger Guidelines
The AHA joins the U.S. Chamber of Commerce and other organizations in urging the Federal Trade Commission to extend for at least 60 days the comment period for their draft guidance revising how they review mergers and acquisitions to determine compliance with federal antitrust laws.
Request to FTC for Extension on Proposed Rulemaking for the HSR Filing Process
Request to the Federal Trade Commission and the Department of Justice to extend the comment period to the above-referenced rulemaking (the "Proposal") for an additional 60 days.
Hospital Organizations Urge FTC to Abandon Opposition Effort in La. Merger
AHA expresses serious concerns about the Federal Trade Commission’s unprecedented attempt to enforce the Hart-Scott-Rodino Act (HSR) against a Louisiana hospital’s acquisition of three hospitals in the New Orleans area.
AHA Comments on the NLRB’s Notice of Proposed Rulemaking Re: the Standard for Determining Joint-Employer Status
November 4, 2022
Roxanne Rothschild
Executive Secretary
National Labor Relations Board
1015 Half Street, S.E.
Washington, D.C. 20570-0001
AHA Urges Two Changes to FTC/DOJ Merger Guidelines
As the Federal Trade Commission and Department of Justice contemplate changes to their guidelines for horizontal and vertical mergers, AHA today urged the agencies to update the guidelines to properly recognize the benefits that hospital mergers produce.
AHA, Others Urge Congress to Maintain Current Merger Evaluation Framework
The U.S. Chamber of Commerce and 21 other organizations, including the AHA, urge Congress to maintain the current legal and regulatory framework for evaluating mergers and acquisitions.
AHA Letter to White House, HHS, DOJ, and FTC on Study of Benefits of Hospital Mergers with Attachments
President Biden’s Executive Order on Promoting Competition in the American Economy called upon all agencies of the federal government to protect and promote fair competition throughout the economy. Achieving that objective will require each agency to assess fairly the activities of those fields and industries that fall within its purview.