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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 on June 5, 2024. This version of the letter replaces an earlier version of the letter submitted on May 6, 2024 and corrects the description of what provider ownership data the Centers for Medicare and Medicaid Services are currently collecting.

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 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 release all the provider ownership data it collects as part of the Medicare enrollment process, as it does for many types of 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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