Comments on the Request for Information on consolidation in health care markets

Exterior of a hospital building on a sunny day
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Editor's note:

The authors submitted this comment letter to the Departments on May 6, 2024.

Loren Adler and Matthew Fiedler commented on a request for information on consolidation in health care markets by the Department of Justice, the Department of Health and Human Services, and the Federal Trade Commission. Their letter responds to the agencies’ questions about whether there is a need to expand transparency about the ownership structure of health care entities and, if so, how the agencies could help achieve that.

The authors recommend that the agencies collect and make available systematic, high-quality data on the ownership structures of health care entities, with a particular focus on improving the data available on physician practices. The letter makes two specific recommendations to improve the availability of ownership data: (1) the Centers for Medicare and Medicaid Services (CMS) should collect systematic data on physician practice ownership as part of the Medicare enrollment process, as it does for institutional providers; and (2) CMS should take steps to improve the quality of entity-reported data.

Read the full comment letter here.

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