Publications by Michael R. Greer

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FTC Not Finished with Non-Competes in Health Care – Issues Press Release and “Warning” Letters to Some Health Care Entities

[09/18/25]

Michigan Sues PBMs for Alleged Anticompetitive Conduct Impacting Independent Pharmacies

[05/21/25]

FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2025

[01/23/25]

HSR Bonanza: FTC Announces Record “Gun-Jumping” Fine; DOJ Sues for Serial Violations

[01/16/25]

FTC Announces Record “Gun-Jumping” Fine for Merging Parties

[01/13/25]

Federal Judge Provides Initial Approval for $2.8B Blue Cross Blue Shield Settlement Agreement

[12/09/24]

FTC Issues Rule Finalizing Substantial Changes to Premerger HSR Process: Detailed Analysis

[12/05/24]

"Next Steps In The $2.8B Blue Cross Payout To Providers." Law360, November 2024

[11/14/2024]

Blue Cross Blue Shield Settles for $2.8 Billion to Providers in Antitrust Class Action

[11/04/24]

FTC Finalizes Changes to Hart-Scott Rodino Premerger Notification Form

[10/15/24]

FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2024

[02/08/24]

FTC and DOJ Release Finalized Merger Guidelines

[12/27/23]

FTC Issues Proposed Rule Making Substantial Changes to the Premerger HSR Process

[07/20/23]

FTC and DOJ Release Significant Proposed Updates to the Merger Guidelines

[07/20/23]

FTC Announces Proposed Rule Updating the Hart-Scott-Rodino Form and Instructions

[06/29/23]

DOJ Withdraws Decades Old Antitrust Guidance as Scrutiny of Health Care Industry Continues

[02/14/23]

FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2023

[01/30/23]

Significant Changes to Current Filing Fees Required by Hart-Scott-Rodino Act Included in Omnibus Funding Bill

[01/12/23]

Real Estate Investor Identified as Conspirator in Recent Antitrust Monopolization Complaint

[09/30/22]

Antitrust Enforcers Set Sights on Private Equity Transactions in Health Care

[08/03/22]

FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2022

[02/01/22]

FTC Announces Changes to Second Request Process, Extending Scope and Timing of Merger Review

[10/08/21]

More Uncertainty in the FTC’s Transaction Review Process: FTC Warns Parties of Continuing Investigations Post Expiration of HSR Waiting Period Amid “Tidal Wave” of Filings

[08/20/21]

Antitrust Goes Mainstream – President Biden Issues Executive Order to Promote Competition

[07/28/21]

Antitrust in Health Care M&A: Five Key Considerations to Guide Competitive Behavior

[07/28/20]

DOJ, FTC Issue Vertical Merger Guidelines

[07/10/20]

DOJ Announces $100 Million Criminal Antitrust Penalty for Florida Oncology Provider

[05/13/20]

FTC, DOJ Worried About Collusion in Labor Markets During COVID-19 Pandemic

[04/16/20]

FTC, DOJ Issue Joint Antitrust Statement Regarding COVID-19

[03/26/20]

FTC, DOJ Announce COVID-19 Antitrust Guidance for Merger & Acquisition Review

[03/20/20]

FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2020

[02/03/20]

FTC, DOJ Release Draft Vertical Merger Guidelines

[01/21/20]

New DOJ Guidance for Antitrust Compliance Programs: Why Health Care Entities Need Antitrust Focus

[09/20/19]

Here’s Price Transparency![1]

[09/13/19]

No Surprise Here…the Debate Continues on Surprise Billing

[08/28/19]

Changes to Catholic Ethical and Religious Directives Impact Mergers and Partnerships Between Catholic and Non-Catholic Entities

[08/02/18]

Employers Could Have Egg on Their Faces with ‘No-Poaching’ Agreements

[04/18/18]

Antitrust Investigations: A Practical Guide for Handling Subpoenas and Civil Investigative Demands (CIDs)

The Academic Health Center: Delivery System Design in the Changing Health Care Ecosystem - Sizing the Clinical Enterprise to Support the Academic Mission

U.S. District Court Blocks Second Insurance Mega-Merger; Court Not Impressed with Anthem’s Plan to “Drop the Hammer” on Providers

[03/23/17]

U.S. District Court Blocks $37 Billion Aetna/Humana Merger; Decision Looming in Anthem/Cigna

[01/27/17]

FTC and DOJ Release Joint Antitrust Guidance for HR Professionals, Warn of Criminal Enforcement for “No-Poaching” and Wage-Fixing Agreements

[10/28/16]

Third Party Discovery Begins in Expedited Antitrust Challenge to Health Insurance Mega-Mergers

[08/19/16]

Will Consecutive FTC Losses Change the Antitrust Landscape for Hospital Mergers?

[07/13/16]

I Say Single Entity, You Say Antitrust Violation: Sixth Circuit Finds JOA Fails Antitrust Test

[06/03/16]

FTC Hospital Merger Win Streak Ends: PA Judge Rules in Favor of Hospitals, but FTC Fights On

[05/12/16]

What Is a Provider to Do? The Perceived Tension Between Health Care Reform and Federal Antitrust Enforcement (© 2014 American Health Law Association)

FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2016

[01/29/16]

Common Themes Emerge as FTC Challenges Three Hospital Mergers in Two-Month Period

[01/20/16]

FTC Challenges West Virginia Hospital Acquisition Despite Attorney General Approval

[12/02/15]

Antitrust Enforcers Tally Two More Wins in Provider Consolidation Battle

[02/17/15]

FTC Approves Norman PHO Clinical Integration Program

[02/20/13]

Hall Render’s Practical Health – Fourth Quarter 2012

[12/01/12]

As Physician Acquisitions Thrive, So Do Antitrust Enforcement Actions

[02/27/12]

Antitrust Implications for ACOs: FTC/DOJ Determine ACOs are Consistent with Indicia of Clinical Integration – Is This a Fundamental Shift in Antitrust Policy?

[01/31/12]

Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2012

[01/30/12]

Federal Trade Commission Revises Premerger Notification Rules and Report Form

[07/08/11]