Classic Antitrust Principles Apply To Health Care Mergers Even Post-ACA

The Ninth Circuit last week held that St. Luke's Health System's purchase of a physician practice group violated federal antitrust laws. In doing so, it upheld a district court's order that the merger be dissolved.

The ruling has added significance given the Affordable Care Act's (ACA) emphasis on health care integration. It shows that even against the backdrop of the ACA, courts' antitrust analysis for horizontal mergers remains unchanged.

The case concerned St. Luke's 2012 acquisition of Saltzer Medical Group, the largest physician practice group in Idaho. The Federal Trade Commission (FTC), the State of Idaho, and two local hospitals sued, alleging that the merger violated the Clayton Act and state law.