Health care collaborations among competitors: minimizing antitrust risks
- Establish clear evidence of efficiency-enhancing integration:
- Agree to enter into only capitated contracts with payers or other forms of substantial financial risk sharing (e.g., agreeing to withhold 20 percent or more of provider compensation subject to meeting group cost savings and/or quality goals); or
- Adopt a program of clinical integration;
Published December 21, 2015
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