|
Appendix B:
Public Comments
FTC Workshop on Health Care and Competition Law and Policy
September 9-10, 2002
Primary Source: http://www.ftc.gov/os/comments/healthcarecomments/index.htm.
| Name |
Title of Comment |
|---|
| American Bar Association,
Section of Antitrust Law |
- Comments Regarding The Federal Trade Commission's
Workshop on Health Care and Competition Law and
Policy (Oct. 2002)
|
| American College of Surgeons
(ACS)
|
- Comments Regarding the Federal Trade Commission
(FTC) Workshop on Health Care Competition Law and
Policy (Sept. 30, 2002) [Submitted by Thomas R. Russell]
|
| American Medical Association
(AMA) |
- On Integration, Physician Joint Contracting, and
Quality: Taking a Fresh Look at Some "Settled"
Questions (Sept. 9, 2002) [Presentation by Catherine
Hanson]
|
| Carolyn Buppert
|
- Comments Regarding Competition Law and Policy &
Health Care (Aug. 30, 2002)
|
| George H. Koenig |
- Additional Testimony Subsequent to FTC Workshop on
Health Care and Competition Law and Policy (Sept. 16,
2002)
|
| Robert F. Leibenluft
|
- Comments Regarding Competition Law and Policy &
Health Care (Sept. 30, 2002) [On Behalf of The Antitrust
Coalition for Consumer Choice in Health Care (ACCC-HC)]
- Letter to Member of Congress (Apr. 12, 2002) (The
Antitrust Coalition For Consumer Choice in Health Care)
- Competition in Health Insurance and Physician Markets:
A Review of "Competition in Health Insurance: A
Comprehensive Study of US Markets" By the American
Medical Association (Apr. 2002) (Prepared by Charles
River Associates)
- "Why Physician Cartels Do Not Need a "Fresh Look" —
a Response to the AMA's Testimony at the FTC Health
Care Competition Workshop
|
| Magazine Publishers of
America (MPA) |
- Comments Regarding Competition Law and Policy &
Health Care (Sept. 30, 2002) [Submitted by James R.
Cregan]
|
| Roy J. Meidinger |
- Health Industry: Great Intentions Gone Bad
|
| Novation |
- Comment Regarding Competition Law and Policy &
Health Care (Sept. 30, 2002) [Submitted by Jody
Hatcher]
|
| Pfizer Inc.
|
- Comments of Pfizer Inc. in Response to FDA Request for
Comments on First Amendment Issues, Docket No. 02N-0209 (Sept. 13, 2002) [George W. Evans & Arnold I.
Friede]
|
| Prairie Health Purchasing
Alliance (PHPA) |
- Comments Regarding Competition Law and Policy &
Health Care
(Sept. 27, 2002)[Submitted by Benjamin
Vander Kooi, Jr.]
|
| David L. Redfern
|
- Competition in Health Care Workshop (Oct. 8, 2002)
- Attachment 1 - Woman's Clinic, Inc. v. St. John's Health
System, Inc., Cause No. 01-3245-CV-S AE-ECF (Dec. 21,
2001) (First Amended Complaint)
- Attachment 2 - Compromise and Settlement Agreement
Between Sisters of Mercy Health System, St. Louis, Inc.
and State of Missouri
- Attachment 3 - Executive Council of Greene County
Medical Society Memo (July 12, 2001); Letter from
Rosary Payne, Division Counsel, American Medical
Association (AMA) (Sept. 12, 2001); Sandy Z. Poneleit,
Doctors' Departures Worry Medical Society,
Springfield News-Leader (July 24, 2001)
- Attachment 4 - Claudette Riley, Premiums Eat Up
Teachers' Raises, Springfield News-Leader (Sept. 6,
2001); Claudette Riley, Focus Put on School Health
Benefits, Springfield News - Leader (Sept. 14, 2001);
Sandy Z. Poneleit, Companies' Health Care Costs Soar,
Springfield News -Leader (Feb. 15, 2002); Jack Wang,
Health Insurance Premiums Will Skyrocket for Some
State Employees, KY3 News (Aug. 21, 2002); Cheryl
Capages, Economic Survey Reveals Local Optimism,
Springfield Bus. J. 3 (Oct. 29 - Nov. 4, 2001);
Commerce Bank, 2002 Economic Survey Results
- Attachment 5 - American Medical Association,
Competition in Health Insurance: A Comprehensive
Study of U.S. Markets. (Nov. 2001)
|
| Washington Business Group on
Health (WBGH) |
- Comments Regarding Competition Law and Policy &
Health Care (Sept. 30, 2002) [Submitted by Helen
Darling]
|
FTC/DOJ Hearings on Health Care and Competition Law and Policy
February to September 2003
Primary Source: http://www.ftc.gov/os/comments/healthcarecomments2/index.htm.
| Name |
Title of Comment |
|---|
| Academy of Managed Care
Pharmacy (AMCP) |
- Comments Regarding the June 26, 2003 Joint FTC-DOJ
Hearings on Health Care and Competition Law and
Policy (Pharmaceuticals: Formulary) (Aug. 5, 2003)
- Principles of a Sound Drug Formulary System (Oct.
2000)
- Where We Stand: Regulation of Pharmacy Benefit
Management Companies (Approved by the AMCP Board
of Directors Apr. 3, 2002)
- Where We Stand: Formularies (Revised by the AMCP
Board of Directors Feb. 2003)
- Concepts in Managed Care Pharmacy: Formulary
Management (June 1998)
|
| American Academy of
Pediatrics |
- Testimony Before the Federal Trade Commission on
Health Care and Competition Law and Policy (Feb. 27,
2003) [Presented by Tim Doran]
|
| American Association of
Health Plans (AAHP)
|
- Perspectives on Competition Policy and the Health Care
Marketplace (Feb. 27, 2003) [Statement of Stephanie
Kanwit]
- Additional Talking Points in Response to AHA's Study on
Hospital Costs (Feb. 27, 2003) [Submitted by Stephanie
Kanwit]
- The Myth of Health Plan Monopsony Power (Apr. 25,
2003) [Presentation by Stephanie Kanwit]
- The Myth of Health Plan Monopsony Power (Apr. 25,
2003) [Statement of Stephanie Kanwit]
- Toward A More Accountable Regulatory System (June 25,
2003) [Presentation by Karen Ignagni]
|
| American Association of Nurse
Anesthetists (AANA) |
- Comments Regarding Hearings on Health Care and
Competition Law and Policy (Nov. 20, 2003) [Submitted
by Frank Purcell]
- Selected Literature on Anesthesia Markets, Quality
Outcomes, and Responses to Anti-competitive Behaviors
- New Economic Perspectives on the Market for Anesthesia
Services: Achieving Desired Reforms Through Fair
Competition (Nov. 2003) [Presented by Jeffrey C. Bauer]
- John D. Klein, When Will Managed Care Come to
Anesthesia?, 23 J. Health Care Fin. 62 (1997)
- Ira P. Gunn, Health Educational Costs, Provider Mix,
and Healthcare Reform: A Case in Point - Nurse
Anesthetists and Anesthesiologists, 64 J. Am. Ass'n of
Nurse Anesthetists 48 (1996)
- Michael Pine et al.,Surgical Mortality and Type of
Anesthesia Provider, 71 AANA J. 109 (2003)
- Jeffrey H. Silber et al., Anesthesiologist Direction and
Patient Outcomes, 93 Anesthesiology 152 (2000)
- Medicare and Medicaid Programs; Hospital Conditions
of Participation: Anesthesia Services, 66 Fed. Reg. 4,674
(2001)
- Quality of Care in Anesthesia (Oct. 23, 2003), at
http://www.aana.com/crna/prof/quality_silber2.asp
- Jerry Cromwell, Health Professions Substitution: A Case
Study of Anesthesia, in The U.S. Health Workforce:
Power, Politics, and Policy 219 (Marian Osterweis et
al. ed., 1996)
- Testimony of Jan Stewart On Behalf of the American
Association of Nurse Anesthetists, Before the House
Judiciary Committee (June 22, 1999)
- Quality of Care in Anesthesia: Synopsis of Published
Information Comparing Certified Registered Nurse
Anesthetist and Anesthesiologist Patient Outcomes (2002)
|
| American Bar Association,
Section of Antitrust Law |
- Comments on the Public Hearings on Health Care and
Competition Law and Policy (Dec. 18, 2003)
|
| American Chiropractic
Association (ACA) |
- Comments Regarding Health Care and Competition Law
and Policy (Sept. 9, 2003) [Submitted by Daryl D. Wills
& James D. Edwards]
- Comments Regarding Health Care and Competition Law
and Policy (Nov. 25, 2003) [Submitted by Donald J.
Krippendorf & George B. McClelland]
- Brief of Appellants, American Chiropractic Association,
Inc. v. Trigon Health Care Inc. (4th Cir. 2003) (No.
03-1675) (Aug. 18, 2003)
|
| American College of Nurse-Midwives |
- Addendum of Cases and Articles For Statement of Lynne
Loeffler for the American College of Nurse-Midwives (July 25, 2003)
|
| American Congress on
Electroneuromyography |
- Comments Regarding Health Care and Competition Law
and Policy (July 15, 2003)
|
| American Health Planning
Association (AHPA) |
- AHPA Testimony Support Information (June 10, 2003)
- Certificate of Need and Related Health Services
Regulation, Representative Publications and Reports
- Health Service Volume and Treatment Outcome,
Representative Published Studies
- Comparative Studies of For-Profit and Not-For-Profit
Health Care Services, Representative Publications and
Reports
- Thomas R. Piper, Certificate of Need: Protecting
Consumer Interests
|
| American Medical Association
(AMA)
|
- Health Care Competition Law and Policy — Quality and
Consumer Information: Market Entry (June 10, 2003)
- Physician Information Sharing (Sept. 24, 2003)
- Physician IPAs: Patterns and Benefits of Integration,
and Other Issues (Sept. 25, 2003)
- Physician IPAs: Messenger Model (Sept. 25, 2003) [Oral
Statement of J. Edward Hill]
- Health Care Competition Law and Policy — Quality and
Consumer Information: Physicians (May 30, 2003)
[Presented by Nancy H. Nielsen]
- The Impact of Monopsony on the Practice of Medicine:
Market Definition, Competitive Effects and
Countervailing Power Theory and Practice (Apr.-May
2003) [Presented by Stephen E. Foreman]
|
| American Nurses Association
|
- American Nurses Association, Testimony Before the
Federal Trade Commission and Department of Justice on
Perspectives on Competition Policy and the Health Care
Marketplace (Feb. 27, 2003) [Presented by Winifred
Carson-Smith]
- Attachment A - State Legislation Which Affects Nursing
Practice (1999 Chart)
- Attachment B - Linda Pearson, Fifteenth Annual
Legislative Update: How Each State Stands on
Legislative Issues Affecting Advanced Nursing Practice,
28 The Nurse Practitioner 26 (2003)
- Attachment C - References to Advanced Practice Nurses
As Primary Care Providers in State Statute (Feb. 2002)
- Attachment D - States Which Offer Nurse Privileging
(2001 Chart)
- Attachment E - Joint Regulation of Advanced Nursing
Practice (1992, revised 1997)
- Attachment F - Letter from Geri Marullo, Executive
Director, American Nurses Association, to Dennis
O'Leary, President, Joint Commission on the
Accreditation of Healthcare Organizations (Mar. 17,
1995)
- Attachment G - Letter from Winifred Y. Carson, Nurse
Practice Counsel, American Nurses Association, to David
J. Rubben, Legal Counsel, Secretary, United Behavioral
Health (July 21, 1997)
|
| Jonathan Bates |
- Comments Regarding Health Care Competition Law and
Policy (July 21, 2003)
|
| Patricia Cameron |
|
| Dan Caldwell |
- Health Care Competition Law and Policy Hearings
(Editorial submitted to Modern Healthcare weekly
magazine) (June 5, 2003)
|
| California Association of
Physician Groups (CAPG) |
- Clarifying the Health Care Statements' Policies of
Clinical Integration and Ancillarity (Mar. 2004)
|
| Sandy Duffy |
- Testimony of Sandy Duffy, Before the Government Reform
Committee, Wellness and Human Rights Subcommittee
(May 8, 2003)
|
| Einer Elhauge |
- Antitrust Analysis of GPO Exclusionary Agreements
(Sept. 26, [2]003)
|
| Melissa M. English |
- Comments Regarding Anti-Competition Practices (July
22, 2003)
|
| Michael Greger |
- Comments Regarding Hearings on Health Care and
Competition Law and Policy: Specifically in Reference to
the Practice of Unauthorized Pelvic Exams in Medical
Training
|
| Health Industry Group
Purchasing Association
(HIGPA) |
- Group Purchasing Organizations (Sept. 26, 2003) [Submitted by Robert Betz]
|
| Joe Holzer |
- Comments Regarding Hearings on Healthcare
Competition Law & Policy (July 10, 2003)
|
| Independence Blue Cross |
- FTC/DOJ Hearings on Health Care and Competition Law
and Policy (July 23, 2003) [Submitted by John A. Daddis]
|
| Institute on Health Care Costs
and Solutions |
- Transparency and Disclosure: The Route to
Accountability, 2 IssueBrief 1 (Mar./Apr. 2003
|
| James J. Kane, Jr. |
- Health Care Competition Law and Policy Hearings (June
4, 2003)
|
| Massachusetts Council of
Community Hospitals (MCCH) |
- Comments (Apr. 3, 2003) [Submitted by Donald J.
Thieme]
- Cape Ann Economics Report for MCCH (June 2001)
|
| Robert M. McNair, Jr. |
- FTC/DOJ Hearings on Health Care and Competition Law
and Policy (July 24, 2003)
|
| Woodrow A. Myers |
- Quality and Consumer Information (May 29, 2003)
|
| National Association of Clinical
Nurse Specialists (NACNS) |
- Comments Regarding Health Care and Competition Law
and Policy (Nov. 24, 2003)
|
| National Board for
Certification of Hospice and
Palliative Nurses (NBCHPN) |
- NBCHPN Response to Hearings on Health Care and
Competition Law and Policy Regarding Advanced
Practice Registered Nurse Task Force of the National
Council for State Boards of Nursing, Inc. (Sept. 30, 2003)
- Attachment A - Backgrounds and Qualifications of the
Content Expert Panel for the Advanced Practice
Palliative Care Certification Examination
- Attachment B - Fifth Iteration Draft of the Voluntary
Consensus Standards for Quality Palliative Care
- Attachment C - Selected Provision of the Bylaws of
NCSBN
|
| National Council of State
Boards of Nursing, Inc.
(NCSBN) |
- Comments Regarding Hearings on Health Care and
Competition Law and Policy (July 31, 2003) [Submitted
by Donna M. Dorsey]
- Comments Re: Letter from the National Board for
Certification of Hospice and Palliative Nurses (Jan. 8,
2004) [Submitted by Donna M. Dorsey]
|
| National Surgical Hospitals |
- Single Specialty Hospitals (Mar. 27, 2003)
|
| National Women's Law Center
(NWLC) |
- Comments Regarding Health Care and Competition Law
and Policy (Nov. 25, 2003)
|
| Noreen Farrell Nickolas |
- Comments Regarding Health Care and Competition Law
and Policy (July 17, 2003)
|
| NOVA Biomedical |
- Comments Regarding Health Care and Competition Law
and Policy (Nov. 7, 2003) [Submitted by Howard Deahr]
|
| Lynne Odell-Holzer |
- Comments: FTC/DOJ Hearings Regarding Anti-competitive Practices in Healthcare Industry
|
| PacifiCare of California |
- Health Insurance Monopoly Issues — Competitive Effects
(Apr. 23, 2003) [Statement of Fred Dodson]
|
| Roger G. Pariseau, Jr. |
|
| Partners |
- Comments (Apr. 11, 2003) [Submitted by Brent L. Henry]
|
| Elissa Schoenlank |
- Federal Trade Commission and U.S. Department of
Justice Hearings on Health Care and Competition Law
and Policy (Feb. 25, 2003)
- Exhibit A - BlueCross BlueShield of Utica - Watertown
Comprehensive Coverage
- Exhibit B - Letter from Woods McCahill, Medical
Director, Health Centers (Apr. 9, 2002)
- Exhibit C - Letter from Debra Mangino, Memorial Sloan-Kettering Cancer Center
- Exhibit D - Letter from Kitty Houghtalling, Customer
Advocate Associate, BlueCross BlueShield, to Karl F.
Glindmyer, Examiner, Consumer Service Bureau, State of
New York Insurance Department (Sept. 3, 2002)
- Exhibit E - List of Account Services
|
| Vincent Scicchitano |
- Contracting Practices (Mar. 27, 2003)
|
| Service Employees
International Union (SEIU) |
- Comments Regarding Hearings on Health Care and
Competition Law and Policy
|
| Spectrum Health
|
- Comments Regarding Hearings on Health Care
Competition Law and Policy (June 26, 2003) [Submitted
by Michael Freed]
- Medicare Study Shows Best Care Isn't Always the Most
Expensive, The Wall Street Journal (Feb. 18, 2003)
- Spectrum Health, Defining Health Care Value (Sept.
2002)
|
| Christine A. Sullivan |
- Comments Regarding Hearings on Health Care
Competition Law and Policy (Sept. 19, 2003)
|
| Reed V. Tuckson |
- UnitedHealth Group Initiatives to Improve Quality,
Safety and Consumer Decision Making (May 30, 2003)
|
| Cathryn Wright |
- Comments Regarding Hearings on Health Care
Competition Law and Policy (July 22, 2003)
|
|