Physician Certification Group Wins Dismissal Of Antitrust Suit Brought By Physicians

A physician organization has failed to sufficiently plead that a physician certification group caused an unreasonable restraint of trade through its actions to promulgate its certification program. Last week, a district court dismissed the case that centered on the defendant organization's agreement with a hospital accreditation company to encourage the use of its certification program. Assoc. of Amer. Physicians & Surgeons v. Amer. Bd. of Med. Specialties, Case No. 1:14-cv-02705 (N.D. Ill. Dec. 13, 2017). 

Plaintiff Association of American Physicians & Surgeons, Inc. ("AAPS") is a membership organization of thousands of practicing physicians in nearly all specialties. Defendant American Board of Medical Specialties ("ABMS") is a nonprofit umbrella organization for 24 medical specialty boards ("Member Boards") that certify physicians in various specialties. Under the current requirements of the ABMS and Member Boards, physicians must participate in the ABMS