AAEM Board of Directors response to DOJ/FTC on merger guidelines

DOJ/FTC Request for Information on Merger Enforcement

Comments from the American Academy of Emergency Medicine

Thank you for looking into this important issue. In 2018, the AMA conducted their yearly Physician Practices Benchmark Survey and concluded that for the first time, more physicians were employees rather than owners of their practices1. While this may not seem like a significant finding, the systematic consolidation and buy-out of private practice physicians is detrimental to both patients and physicians. Physicians take the Hippocratic oath upon embarking in the practice of medicine, an ethical code of conduct which requires that their duty be first and foremost to their patients. This code obligates physicians to put the needs of the patients first, both in the practice of medicine and their business; whereas, non-physician owned/operated practices lack this ethical code, leading to poor patient care and higher healthcare costs to patients. The most deleterious of these employers are Emergency Department corporate management groups (CMGs) with private equity backing and/or ownership (Teamhealth, Envision (previously Emcare), APP, Schumacher, USACS, etc.). Emergency departments act as the safety net for medical care in this country, providing care to patients in their most vulnerable moments. While these companies argue that they have no undue effect on physician practice, this could not be further from the truth.

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