By Thomas L. Greaney, Richard M. Scheffler, Katherine L. Gudiksen, Jaime S. King, Amy Y. Gu, Brent D. Fulton, Paul B. Ginsburg, and Daniel R. Arnold | Link to Full Comment
The Draft Merger Guidelines (DMGs) constitute a major step forward in providing economically sound guidance to practitioners and courts for evaluating the potential competitive impact of mergers and acquisitions. These comments are offered by a group of law professors, economists, and policy experts who have devoted most of their professional careers to issues concerning market and regulatory issues involving health care providers and payors. The comment focus on several proposed changes that are of particular importance to improving oversight of consolidation in the health care sector.