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Generic Pharmaceutical Association
Letter From Markus H. Meier, Assistant Director, Health Care Division, Bureau of Competition, to E. John Steren, Ober, Kaler, Grimes & Shriver, Concerning the Generic Pharmaceutical Association's Proposed Initiative to Address Drug Shortages, dated August 8, 2012, and Incoming Letter from the Generic Pharmaceutical Association, Inc., dated July 16, 2012 [Public Record Version]
Rx-360 International Pharmaceutical Supply Chain Consortium.
Letter to Joanne Lewers, Concerning Proposal regarding the Rx-360 International Pharmaceutical Supply Chain Consortium (“Rx-360") to implement two supplier audit programs, which would permit pharmaceutical manufacturers to: (1) share information about the quality and safety of ingredients purchased from common suppliers; and (2) share the costs of sponsoring quality and safety audits of common suppliers.
Yakima Valley Memorial Hospital
Letter from Markus H. Meier to Robert J. Walerius, Concerning Whether, Under the Non-Profit Institutions Act Exemption From the Robinson-Patman Act, Yakima Valley Memorial Hospital May Sell Discounted Pharmaceutical Products To Employees of Two Affiliates, Memorial Physicians, PLLC, and Valley Imaging.
Community CarePartners, Inc.
Letter from Markus H. Meier to Vincent D. Childress, Jr., dated July 2, 2010, concerning whether, under the Non-Profit Institutions Act (“NPIA”) exemption to the Robinson-Patman Act, Community CarePartners, Inc. may lawfully extend sales of NPIA-discounted pharmaceutical products to its in-home hospice patients.
University of Michigan
Letter from Markus H. Meier to Kathleen Reed, dated April 9, 2010, concerning whether, under the Non-Profit Institutions Act exemption to the Robinson-Patman Act, University of Michigan may lawfully establish and operate a GPO replenishment-based drug benefit program.
TriState Health Partners, Inc.
Letter from Markus H. Meier to Christi J. Braun, dated April 13, 2009 concerning a proposal by a physician-hospital organization (PHO)
to negotiate contracts with payers in connection with its integrated services program and Incoming Letter from Christi Braun, dated July 9, 2007 [Public Record Version].
Kaiser Foundation Health Plan
Letter from Markus H. Meier to Robert E. Bloch, dated February 13, 2008, concerning whether -- under the Nonprofit Institutions Act exemption to the Robinson-Patman Act -- Kaiser may lawfully purchase discounted pharmaceuticals for use in certain programs to provide health care services.
Greater Rochester Independent Practice Association, Inc.
Letter from Markus H. Meier to Christi J. Braun and John J. Miles, dated September 17, 2007 concerning a proposal by a physician association to negotiate contracts with payers in connection with its integrated services program.
MedSouth, Inc.
Letter from Markus H. Meier to John J. Miles, Ober, Kaler, Grimes & Shriver, Dated June 18, 2007
Re: Follow-Up to February 9, 2002 MedSouth, Inc. Staff Advisory Opinion
St. John's Health System
Letter from Markus H. Meier to Michael Merrigan, dated September 13, 2006, concerning the provision of pharmaceuticals by St. John's Regional Health Center, a non-profit hospital, to three hospital-owned pharmacy sites, under the Non-Profit Institutions Act.
Alpena Public Schools
Letter from Markus H. Meier to Kathleen A. Reed, dated June 16, 2006, concerning a program to transfer pharmaceuticals at cost between a non-profit hospital and a non-profit public school system.
Suburban Health Organization
Letter from David R. Pender to Clifton E. Johnson and William H. Thompson, dated March 28, 2006, concerning the antitrust implications of a proposal to undertake a program involving partial integration among eight independent Suburban Health Organization member hospitals and the 192 primary care physicians that, in total, they employ.
North Mississippi Health Services
Letter from David R. Pender to Bruce J. Toppin, dated August 16, 2005, concerning the transfer of pharmaceuticals at cost by non-profit hospital to patients of non-profit clinic and hospice.
Stevens Hospital, of Edmonds, Washington
Letter from David Pender to Gordon J. Oakes, dated April 18, 2005, Concerning the Applicability of the Non-Profit Institutions Act Amendments to the Robinson-Patman Act to Stevens' Proposed Pricing of Pharmaceuticals, and Incoming Letter from Stevens Hospital, dated March 4, 2005.
Bristol-Myers Squibb Company
Letter from Donald S. Clark to Richard J. Stark, dated May 24, 2004.
re: Proposed settlement of infringement litigation with Teva Pharmaceuticals involving sharing of the exclusivity period for the drug Paraplatin.
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 centerAssociates 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 companiesSouthwest 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 urologistsSouthern 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: Aition 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 ventureRocky 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 conductPresentation 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
Unnamed Hospital.
Letter from Karen G. Bokat to James D. Miller, dated 3/31/93
re: Concerning the dispensing of drugs by a non-profit hospital to HMO members and to members of a senior citizens' program.
Oneida City Hospital
Letter from Michael D. McNeely to Linus W. Walton, dated 06/01/92
re: Concerning the sale of prescription drugs by a city-operated hospital to city employees at a price reflecting discounts received by the hospital.
Benedictine Health Centers
Letter from Mark J. Horoschak to Patrick M. Sheller, dated 07/10/91
re: Concerning a hospital's offer of free office space to newly recruited physicians.
IPA Sponsored PPO
Letter from Mark J. Horoshak to Martin J. Thompson, dated 06/20/91
re: Concerning an IPA network's sponsorship of a PPO to negotiate prices with hospitals whose services will be marketed as part of the PPO.
Dental Consultant Salary Survey
Letter from Mark J. Horoschak to Samuel D. Dednam , dated 05/30/91
re: Relating to a survey of salary ranges for certified dental consultants.
Wichita Area Chamber of Commerce
Letter from Mark J. Horoschak to Tim Witsman , dated 05/22/91
re: Relating to collective allocation by hospitals of services, equipment, or facilities.
National Capital Society of Plastic and Reconstructive Surgeons
Letter from Mark J. Horoschak to Robert J. Wilensky , dated 04/23/91
re: Concerning a physician panel's rendering of advisory opinions regarding fee disputes.
American Society of Cataract and Refractive Surgeons
Letter from Mark J. Horoschak to Jerald A. Jacobs, dated 09/20/90
re: Concerning advisory advertising guidelines.
American Dental Association
Letter from Mark J. Horoschak to Peter Sfikas, dated 02/15/90
re: Concerning a study of the establishment of UCR rates by dental insurers and the impact of those rates on consumers' out-of-pocket costs.
Independent Video Services
Letter from Mark J. Horoschak to Bonnie B. Larson, Marketing Manager, dated 01/17/90
re: Concerning price differences in the sale of educational video programs to physicians and hospitals.
Pan American Management Associates
Letter from Michael D. McNeely to Robert P. Macina, dated 06/27/89
re: Concerning the creation of a limited partnership between hospital and physicians to establish a PPO in which the physicians are to be excluded from price negotiations with payers.
Intracorp
Letter from M. Elizabeth Gee to Sharon D. Doniz, dated 03/25/88
re: Concerning use of a physician-developed RVS by a cost-containment service to determine UCR price screens.
Washington Health Care Association
Letter from M. Elizabeth Gee to Stephen J. Maag, Director of Legal and Regulatory Affairs, dated 02/16/88
re: Concerning a nursing home association's program to evaluate the quality of care provided by nursing homes.
Academy of Ambulatory Foot Surgery
Letter from M. Elizabeth Gee to Andrew K. Dolan, Esq., dated 07/31/87
re: Concerning a professional association's assistance to third-party payers in determining when foot surgery may be restricted to less expensive outpatient settings.
Maryland Medical Eye Associates
Letter from M. Elizabeth Gee to Charles E. Rosolio, dated 05/15/87
re: Concerning the formation, marketing, and operation of a partially integrated professional organization, owned by nine ophthalmologists in five separate medical practices, to offer services to HMOs and other groups on a capitation and fee schedule basis.
Association for Quality Health Care, Inc
Letter from M. Elizabeth Gee to Cecil M. Cheves, Esq., dated 08/28/86
re: Concerning a proposal by an association of employers with self-funded health plans to negotiate with providers.
Pacific International Health, Inc.
Letter from M. Elizabeth Gee to Richard C. Greenberg, Esq., dated 08/28/86,
re: Concerning the formation and operation of a provider-controlled PPO in which the price agreements are between individual participating physicians and each payer.
The Equitable Life Assurance Society
Letter from M. Elizabeth Gee to Jonathan E. Gaines, Esq., V.P. and Counsel, dated 03/26/86
re: Concerning the proposal of an insurer to enter into contracts with hospitals for DRG-based payment.
California PPO
Letter from M. Elizabeth Gee to Michael A. Duncheon, Esq., dated 03/17/86
re: Concerning a proposal by a PPO composed of multiple hospitals and physician organizations to negotiate contracts with third-party payers.
Passaic County Medical Society
Letter from M. Elizabeth Gee to William T. McGuire, Executive Director, dated 01/03/86
re: Concerning a professional society’s peer review of physicians' fees that is mandatory and binding on the physician.
North Texas Chapter of the American College of Surgeons
Letter from Nina B. Hale to B. Ward Lane, M.D., President, dated 12/12/85
re: Relating to a survey of members' fees.
American Intra-Ocular Implant Society
Letter from Arthur N. Lerner to Jerald A. Jacobs, Esq., dated 10/11/85
re: Concerning the development of a standard disclosure protocol for intraocular lens manufacturers who offer inducements to physicians.
Private Healthcare Systems
Letter from Arthur N. Lerner to Michael L. Denger, Esq., dated 09/24/85
re: Concerning a proposal by an insurer to develop a proprietary national network of managed health care systems and to function as a joint purchasing agent for commercial health insurers.
American Dental Association
Letter from Timothy J. Muris to Peter M. Sfikas, Esq, dated 08/26/85
re: Rrelating to a survey of the range of dentists' fees in local markets.
American Society of Internal Medicine (105 F.T.C. 505 (1985))
Letter from Emily Rock to William G. Kopit, Esq., dated 04/19/85
re: Concerning the development and dissemination of a RVS by an association of physicians.
Utah Society of Oral and Maxillofacial Surgeons
Letter from Arthur Lerner to Dennis L. Dedecker, D.D.S., Secretary, dated 02/08/85
re: Concerning a survey of range of fees and average fees charged by members.
Tarrant County Medical Society
Letter from Arthur Lerner to Lynn C. Perkins, M.D., President, dated 07/11/84
re: Concerning a medical society’s advisory fee review program for the voluntary resolution of disputes.
Maine Medical Association
Letter from Arthur N. Lerner to Frederick C. Holler, M.D., President, dated 05/14/84
re: Concerning a proposal by a physician association to urge members to freeze fees or to lower fees by a given percentage.
Peer Review Organizations of Ohio Foundation
Letter from Arthur N. Lerner to Larry D. Spencer, Executive Director, dated 04/25/84
re: Concerning a proposal by an association of nine Professional Standards Review Organizations to bid for contract with HHS to serve as a Peer Review Organization for Ohio under the Medicare program.
Kitsap Physicians Service
Letter from Arthur N. Lerner to William G. Kopit, Esq., dated 03/26/84
re: Concerning a proposal by a physician-owned IPA/HMO, with most of the local physicians as participants, to close off access to the plan to new/additional physicians.
Kitsap Physicians Service
Letter from Arthur N. Lerner to William G. Kopit, Esq., dated 05/22/84
re: Concerning a proposal by a physician-owned IPA/HMO, with most of the local physicians as participants, to close off access to the plan to additional physicians.
HMO/IPA
Letter from Arthur N. Lerner to Gilbert M. Frimet, Esq., dated 03/22/84
re: Concerning the use by an IPA of a fee schedule to allocate capitation payment among participating physicians, and a proposal to require exclusive dealing by IPA members with the IPA.
American Podiatry Association
Letter from Arthur N. Lerner to Werner Strupp, Esq., dated 03/13/84
re: Concerning the use of HCFA's Medicare fee profile by the association as a reference aid in reviewing the reasonableness of disputed fees.
Medical Society of the County of Erie
Letter from Arthur N. Lerner to James F. Phillips, M.D., President, dated 03/12/84
re: Concerning discussions with third-party payers regarding fee allowances.
North Carolina Chiropractic Association
Letter from Arthur N. Lerner to Collin M. Haynie, D.C., Chairman, Ethics Committee, dated 02/29/84
re: Cconcerning provisions in the association’s code of ethics regarding advertising, prior approval of advertising, and fee discounts.
American Podiatry Association
Letter from Timothy Muris to Norman Klombers, DPM, Executive Director, and John Grad, Esq., General Counsel, Podiatry Society of Virginia, dated 08/18/83
re: Concerning peer review of fees, utilization, and quality of care.
American Academy of Ophthalmology, 101 F.T.C. 1018 (1983)
Letter from Michael A. Baggage to Jerald A. Jacobs, Esq., dated 06/17/83
re: Concerning provisions in a code of ethics regarding delegation of services to non-physician health care providers, arrangements for postoperative care, use of experimental procedures, and advertising.
Health Care Management Associates, 101 F.T.C. 1014 (1983)
Letter from Emily H. Rock to Irwin S. Smith, M.D., President, dated 06/07/83
re: Concerning a PPO organized by an independent intermediary between physicians and payers.
Rhode Island Professional Standards Review Organization, 101 F.T.C. 1010 (1983)
Letter from Emily H. Rock to Edward J. Lynch, Executive V.P., dated 05/09/83
re: Concerning peer review of a private employers' health benefits programs.
Burnham Hospital, 101 F.T.C. 991 (1983)
Letter from the Commission to Robert E. Nord, dated 02/24/83
re: Concerning the grant to a physician group of the exclusive right to offer radiology services at a hospital.
Louisiana Health Care Association
Letter from Thomas J. Campbell to Steven E. Adams, J.D., Director of Governmental Relations dated 04/23/82
re: Concerning a group purchasing agreement for nursing home association's members.
Iowa Dental Association,99 F.T.C. 648 (1982)
Letter from Carol M. Thomas to Peter M. Sfikas, Esq., dated 04/08/82
re: Concerning a professional society’s peer review of dentists' fees.
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