Universal Health Services, Inc. and Psychiatric Solutions, Inc.; Analysis of Agreement Containing Consent Orders To Aid Public Comment, 71441-71443 [2010-29511]
Download as PDF
Federal Register / Vol. 75, No. 225 / Tuesday, November 23, 2010 / Notices
mstockstill on DSKH9S0YB1PROD with NOTICES
standards in section 4 of the BHC Act
(12 U.S.C. 1843). Unless otherwise
noted, nonbanking activities will be
conducted throughout the United States.
Unless otherwise noted, comments
regarding each of these applications
must be received at the Reserve Bank
indicated or the offices of the Board of
Governors not later than December 17,
2010.
A. Federal Reserve Bank of Boston
(Richard Walker, Community Affairs
Officer) P.O. Box 55882, Boston,
Massachusetts 02106–2204:
1. Brookline Bancorp, Inc., Brookline,
Massachusetts; to become a bank
holding company by acquiring 100
percent of the voting shares of First
Ipswich Bancorp, and thereby acquire
First National Bank of Ipswich, both of
Ipswich, Massachusetts.
In connection with this application,
Applicant also has applied to retain
voting shares of Brookline Bank,
Brookline, Massachusetts and thereby
continue to operate a savings
association, and Eastern Funding, LLC,
New York, New York, which will
continue to operate an equipment
finance company, pursuant to sections
225.28(b)(1), (b)(3), and (b)(4)(ii), of
Regulation Y.
B. Federal Reserve Bank of Chicago
(Colette A. Fried, Assistant Vice
President) 230 South LaSalle Street,
Chicago, Illinois 60690–1414:
1. River Holding Company, Stoddard,
Wisconsin; to acquire 51 percent of the
voting shares of Community Business
Bancshares, Inc., and thereby indirectly
acquire voting shares of Community
Business Bank, both of Sauk City,
Wisconsin.
C. Federal Reserve Bank of Dallas (E.
Ann Worthy, Vice President) 2200
North Pearl Street, Dallas, Texas 75201–
2272:
1. Commercial Bancshares, Inc., El
Campo, Texas; to become a bank
holding company by acquiring 60
percent of the voting shares of El Campo
Bancshares, Inc., and thereby indirectly
acquire voting shares of Commercial
State Bank, both of El Campo, Texas.
Board of Governors of the Federal Reserve
System, November 18, 2010.
Robert deV. Frierson,
Deputy Secretary of the Board.
FEDERAL TRADE COMMISSION
[File No. 101 0142]
Universal Health Services, Inc. and
Psychiatric Solutions, Inc.; Analysis of
Agreement Containing Consent Orders
To Aid Public Comment
Federal Trade Commission.
Proposed consent agreement.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
Federal law prohibiting unfair or
deceptive acts or practices or unfair
methods of competition. The attached
Analysis To Aid Public Comment
describes both the allegations in the
draft complaint and the terms of the
consent order—embodied in the consent
agreement—that would settle these
allegations.
DATES: Comments must be received on
or before December 15, 2010.
ADDRESSES: Interested parties are
invited to submit written comments
electronically or in paper form.
Comments should refer to ‘‘Universal
Health Services, File No. 101 0142’’ to
facilitate the organization of comments.
Please note that your comment—
including your name and your State—
will be placed on the public record of
this proceeding, including on the
publicly accessible FTC Web site, at
https://www.ftc.gov/os/
publiccomments.shtm.
Because comments will be made
public, they should not include any
sensitive personal information, such as
an individual’s Social Security Number;
date of birth; driver’s license number or
other State identification number, or
foreign country equivalent; passport
number; financial account number; or
credit or debit card number. Comments
also should not include any sensitive
health information, such as medical
records or other individually
identifiable health information. In
addition, comments should not include
any ‘‘[t]rade secret or any commercial or
financial information which is obtained
from any person and which is privileged
or confidential. * * * ’’ as provided in
Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and Commission Rule 4.10(a)(2),
16 CFR 4.10(a)(2). Comments containing
material for which confidential
treatment is requested must be filed in
paper form, must be clearly labeled
‘‘Confidential,’’ and must comply with
FTC Rule 4.9(c), 16 CFR 4.9(c).1
SUMMARY:
[FR Doc. 2010–29489 Filed 11–22–10; 8:45 am]
1 The comment must be accompanied by an
explicit request for confidential treatment,
including the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record.
BILLING CODE 6210–01–P
VerDate Mar<15>2010
18:02 Nov 22, 2010
Jkt 223001
PO 00000
Frm 00030
Fmt 4703
Sfmt 4703
71441
Because paper mail addressed to the
FTC is subject to delay due to
heightened security screening, please
consider submitting your comments in
electronic form. Comments filed in
electronic form should be submitted by
using the following Web link: https://
ftcpublic.commentworks.com/ftc/
psychsolutions and following the
instructions on the Web-based form. To
ensure that the Commission considers
an electronic comment, you must file it
on the Web-based form at the Web link:
https://ftcpublic.commentworks.com/
ftc/psychsolutions. If this Notice
appears at https://www.regulations.gov/
search/index.jsp, you may also file an
electronic comment through that Web
site. The Commission will consider all
comments that regulations.gov forwards
to it. You may also visit the FTC Web
site at https://www.ftc.gov/ to read the
Notice and the news release describing
it.
A comment filed in paper form
should include the ‘‘Universal Health
Services, File No. 101 0142’’ reference
both in the text and on the envelope,
and should be mailed or delivered to the
following address: Federal Trade
Commission, Office of the Secretary,
Room H–135 (Annex D), 600
Pennsylvania Avenue, NW.,
Washington, DC 20580. The FTC is
requesting that any comment filed in
paper form be sent by courier or
overnight service, if possible, because
U.S. postal mail in the Washington area
and at the Commission is subject to
delay due to heightened security
precautions.
The Federal Trade Commission Act
(‘‘FTC Act’’) and other laws the
Commission administers permit the
collection of public comments to
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives,
whether filed in paper or electronic
form. Comments received will be
available to the public on the FTC Web
site, to the extent practicable, at
https://www.ftc.gov/os/
publiccomments.shtm. As a matter of
discretion, the Commission makes every
effort to remove home contact
information for individuals from the
public comments it receives before
placing those comments on the FTC
Web site. More information, including
routine uses permitted by the Privacy
Act, may be found in the FTC’s privacy
The request will be granted or denied by the
Commission’s General Counsel, consistent with
applicable law and the public interest. See FTC
Rule 4.9(c), 16 CFR 4.9(c).
E:\FR\FM\23NON1.SGM
23NON1
71442
Federal Register / Vol. 75, No. 225 / Tuesday, November 23, 2010 / Notices
policy, at https://www.ftc.gov/ftc/
privacy.shtm.
FOR FURTHER INFORMATION CONTACT:
Kenneth W. Field (202–326–2868), FTC
Bureau of Competition, 600
Pennsylvania Avenue, NW.,
Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant
to section 6(f) of the Federal Trade
Commission Act, 38 Stat. 721, 15 U.S.C.
46(f), and § 2.34 the Commission Rules
of Practice, 16 CFR § 2.34, notice is
hereby given that the above-captioned
consent agreement containing a consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of thirty (30) days. The following
Analysis to Aid Public Comment
describes the terms of the consent
agreement, and the allegations in the
complaint. An electronic copy of the
full text of the consent agreement
package can be obtained from the FTC
Home Page (for November 15, 2010), on
the World Wide Web, at https://
www.ftc.gov/os/actions.shtm. A paper
copy can be obtained from the FTC
Public Reference Room, Room 130–H,
600 Pennsylvania Avenue, NW.,
Washington, DC 20580, either in person
or by calling (202) 326–2222.
Public comments are invited, and may
be filed with the Commission in either
paper or electronic form. All comments
should be filed as prescribed in the
ADDRESSES section above, and must be
received on or before the date specified
in the DATES section.
mstockstill on DSKH9S0YB1PROD with NOTICES
Analysis of Agreement Containing
Consent Order To Aid Public Comment
I. Introduction
The Federal Trade Commission
(‘‘Commission’’) has accepted for public
comment, subject to final approval, an
Agreement Containing Consent Orders
(‘‘Consent Agreement’’) from Alan B.
Miller and Universal Health Services,
Inc. (collectively, ‘‘UHS’’) and
Psychiatric Solutions, Inc. (‘‘PSI’’). The
purpose of the proposed Consent
Agreement is to remedy the
anticompetitive effects that would
otherwise result from UHS’s acquisition
of PSI. Under the terms of the proposed
Consent Agreement, UHS is required to
divest four psychiatric facilities and
eleven affiliated clinics operating in
three local acute inpatient psychiatric
care markets to acquirers who receive
the approval of the Commission. The
proposed Consent Agreement also
requires UHS to divest all related assets
and real property necessary to ensure
that the buyer(s) of the divested
facilities will be able to quickly and
VerDate Mar<15>2010
18:02 Nov 22, 2010
Jkt 223001
fully replicate the competition that
would have otherwise been eliminated
by the acquisition. Finally, UHS and PSI
have agreed to an Order to Hold
Separate and Maintain Assets (‘‘Hold
Separate Order’’) that requires UHS to
maintain and hold separate the facilities
to be divested pending their final
divestiture pursuant to the Consent
Agreement.
The proposed Consent Agreement has
been placed on the public record for
thirty days to solicit comments from
interested persons. Comments received
during this period will become part of
the public record. After thirty days, the
Commission again will review the
proposed Consent Agreement and
comments received, and decide whether
it should withdraw the Consent
Agreement, modify the Consent
Agreement, or make it final.
On May 16, 2010, UHS and PSI
entered into a merger agreement under
which UHS proposes to acquire all of
the outstanding voting securities of PSI
for approximately $2.0 billion in cash,
and to assume approximately $1.1
billion of PSI debt. The Commission’s
complaint alleges that the proposed
acquisition, if consummated, would
violate Section 7 of the Clayton Act, as
amended, 15 U.S.C. 18, and Section 5 of
the Federal Trade Commission Act, as
amended, 15 U.S.C. 45, by removing an
actual, direct, and substantial
competitor from three local markets for
acute inpatient psychiatric care. The
proposed Consent Agreement would
remedy the alleged violations by
requiring complete divestitures in each
of the three markets. These divestitures
will replace the competition that
otherwise would be lost in these
markets as a result of the proposed
acquisition.
The Parties
UHS, headquartered in King of
Prussia, Pennsylvania, owns or operates
25 general acute care hospitals and 102
behavioral health facilities located in 32
States, Washington, DC, and Puerto
Rico. It is one of the nation’s largest
hospital management companies, with
2009 revenues totaling approximately
$5.2 billion. In 2009, UHS’s 102
behavioral health facilities generated
approximately $1.3 billion in revenue
(25% of total revenues) from nearly
8,000 licensed beds and over 2 million
patient days.
PSI, headquartered in Franklin,
Tennessee, operates 94 inpatient
behavioral health facilities in 32 States,
Puerto Rico, and the U.S. Virgin Islands.
The 11,000 licensed beds at these
facilities accounted for 2.8 million
patient days in 2009. The company also
PO 00000
Frm 00031
Fmt 4703
Sfmt 4703
manages the behavioral health programs
for 109 general acute care hospitals
owned by third parties. PSI’s revenue
for the twelve months ending December
31, 2009 was approximately $1.8
billion. Behavioral health facilities and
residential treatment centers generated
93% of 2009 revenues and the contract
management business accounted for the
remaining 7%.
Acute Inpatient Psychiatric Services
UHS’s proposed acquisition of PSI
poses substantial antitrust concerns in
the relevant product market of acute
inpatient psychiatric services. Acute
inpatient psychiatric services are those
provided for the diagnosis, treatment,
and care of patients deemed to be a
threat to themselves or others or unable
to perform basic life functions, due to an
acute psychiatric condition.
The three acute inpatient psychiatric
services markets are local in nature.
Analysis of patient flow data and
evidence gathered from market
participants indicate that patients and
their families prefer to find care close to
home in order to facilitate visits or
participation in family therapy. Also,
emergency responders typically
transport patients in acute psychiatric
distress to the nearest emergency room
for treatment or placement. The three
acute inpatient psychiatric services
markets affected by the proposed
acquisition are: the State of Delaware;
the Las Vegas, Nevada metropolitan
statistical area; and the Commonwealth
of Puerto Rico.
The proposed acquisition would
dramatically increase market
concentration in each of the relevant
acute inpatient psychiatric markets. The
markets already range from moderately
to highly concentrated prior to the
acquisition. In each market, the
proposed acquisition would
significantly increase market
concentration and eliminate substantial,
direct competition between two
significant acute inpatient psychiatric
care providers. Under the 2010
Department of Justice and Federal Trade
Commission Horizontal Merger
Guidelines, an acquisition is presumed
to enhance market power or facilitate its
exercise if it increases the HerfindahlHirschman Index (AHHI@) by more than
200 points and results in a postacquisition HHI that exceeds 2,500
points. The proposed acquisition far
exceeds these thresholds: the postacquisition HHIs range from 3916 to
4942, and HHI levels would increase by
1428 to 2610 points above preacquisition levels. The proposed
acquisition also would result in UHS
controlling approximately 60 percent or
E:\FR\FM\23NON1.SGM
23NON1
Federal Register / Vol. 75, No. 225 / Tuesday, November 23, 2010 / Notices
mstockstill on DSKH9S0YB1PROD with NOTICES
more of the acute inpatient psychiatric
beds in each of the affected markets.
The presumption of anticompetitive
harm created by the steep increases in
market concentration is further
supported by evidence of the intense
rivalry between UHS- and PSI-owned
facilities that would be eliminated by
the proposed acquisition. In each of the
local markets, consumers have
benefitted from the head-to-head
competition in the form of lower health
care costs, higher quality of care, and
improved service offerings. Left
unremedied, the proposed acquisition
likely would cause anticompetitive
harm by enabling UHS to profit by
unilaterally raising the reimbursement
rates negotiated with commercial health
plans. These costs are ultimately passed
on to consumers in the form of higher
premiums, co-pays, and other out-ofpocket costs. The loss of competition
also reduces UHS’s incentive to improve
quality and provide better service.
New entry is unlikely to deter or
counteract the anticompetitive effects of
the proposed acquisition. Among other
entry barriers, regulatory requirements
pose substantial barriers to entrants
attempting to establish new psychiatric
facilities or to expand their offerings in
the relevant markets. In particular,
Delaware and Puerto Rico require
Certificates of Need in order to enter or
significantly expand the number of beds
provided in the market. The availability
of suitable land, local zoning
regulations, and Medicare and Medicaid
certifications also impact significantly
the ability of firms to enter or expand.
As a result, new entry sufficient to
achieve a significant market impact is
unlikely to occur in a timely manner in
these markets.
The Proposed Consent Agreement
The proposed Consent Agreement
wholly remedies the anticompetitive
effects of the acquisition by requiring
the divestiture of all of the PSI or UHS
assets to a Commission-approved buyer
(or buyers) within six months of the
date the Consent Agreement becomes
final in Delaware and Las Vegas, and
within nine months in Puerto Rico.
Specifically, the proposed Consent
Agreement requires the divestiture of
four facilities that provide acute
inpatient psychiatric care, as well as
related outpatient clinics, contracts,
commercial trade names, and real
property, in the three geographic
markets. See Appendix A for a complete
list of the divestiture assets. Each
psychiatric facility and its associated
clinics to be divested in Delaware and
Puerto Rico is a stand-alone business,
and includes all of the assets necessary
VerDate Mar<15>2010
18:02 Nov 22, 2010
Jkt 223001
for a Commission-approved buyer to
independently and effectively operate
each facility. The two facilities in Las
Vegas are closely related and
complementary businesses and were
jointly managed within PSI; as such, the
two facilities together constitute a standalone business, and include all of the
assets necessary for a Commissionapproved buyer to independently and
effectively operate the business.
The proposed Consent Agreement
contains several provisions designed to
ensure that the divestitures are
successful. First, the Commission will
evaluate the suitability of possible
purchasers of the divested assets to
ensure that the competitive
environment that would have existed
but for the transaction is replicated by
the required divestitures. If UHS fails to
divest the assets within the required
time period to a Commission-approved
buyer, the Consent Agreement permits
the Commission to appoint a trustee to
divest the assets. Second, UHS is
required to provide transitional services
to the Commission-approved buyer.
These services will facilitate a smooth
transition of the assets to the acquirer,
and ensure continued and
uninterrupted operation of the assets
during the transition. Third, the Consent
Agreement requires UHS to remove any
contractual impediments that may deter
the current managers of the facilities to
be divested from accepting offers of
employment from any Commissionapproved acquirer and to obtain all
consents necessary to transfer the
required assets. Finally, to ensure that
the Commission will have an
opportunity to review any future
attempt by UHS to acquire any acute
inpatient psychiatric services provider
in any of the three geographic markets
at issue, the proposed Consent
Agreement contains a ten-year prior
notice provision.
The Hold Separate Order requires the
parties to maintain the viability of the
divestiture assets as competitive
operations until each facility is
transferred to a Commission-approved
buyer. Specifically, the parties must
maintain the confidentiality of sensitive
business information, and take all
actions necessary to prevent the
destruction or wasting of the divestiture
assets. After UHS acquires PSI, the Hold
Separate Order requires that UHS
separately hold and maintain the
divestiture assets and appoint a Hold
Separate Manager to operate these assets
pending their divestiture.
The sole purpose of this analysis is to
facilitate public comment on the
Consent Agreement. This analysis does
not constitute an official interpretation
PO 00000
Frm 00032
Fmt 4703
Sfmt 4703
71443
of the Consent Agreement or modify its
terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2010–29511 Filed 11–22–10; 8:45 am]
BILLING CODE 6750–01–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Renewal of Charter for the Secretary’s
Advisory Committee on Human
Research Protections
Department of Health and
Human Services, Office of the Secretary,
Office of the Assistant Secretary for
Health.
ACTION: Notice.
AGENCY:
As stipulated by the Federal
Advisory Committee Act, as amended (5
U.S.C. App), the U.S. Department of
Health and Human Services is hereby
announcing renewal of the charter for
the Secretary’s Advisory Committee on
Human Research Protections (SACHRP).
FOR FURTHER INFORMATION CONTACT: Jerry
Menikoff, M.D., J.D., Director, Office for
Human Research Protections or Julia
Gorey, J.D., Executive Director,
SACHRP; U.S. Department of Health
and Human Services, 1101 Wootton
Parkway, Suite 200, Rockville, MD
20852; Telephone: (240) 453–6900; Fax:
(240) 453–6909; e-mail address:
julia.gorey@hhs.gov.
SUPPLEMENTARY INFORMATION: SACHRP
was established in October 2002. The
Committee was established to enhance
and expand the focus of the former
National Human Research Protections
Advisory Committee (NHRPAC), which
was terminated in August 2002.
SACHRP provides expert advice and
recommendations to the Secretary,
through the Assistant Secretary for
Health, on the conduct of research
involving human subjects with
particular emphasis on special
populations, such as neonates and
children, prisoners, and the decisionally
impaired; pregnant women, embryos,
and fetuses; individuals and
populations in international studies;
populations in which there are
individually identifiable samples, data,
or information; and investigator
conflicts of interest.
Since SACHRP was established,
renewal of the Committee charter has
been carried out at the appropriate
intervals as stipulated by FACA. The
previous Committee charter was
scheduled to expire on October 1, 2010.
On October 1, 2010, the Secretary of
SUMMARY:
E:\FR\FM\23NON1.SGM
23NON1
Agencies
[Federal Register Volume 75, Number 225 (Tuesday, November 23, 2010)]
[Notices]
[Pages 71441-71443]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-29511]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 101 0142]
Universal Health Services, Inc. and Psychiatric Solutions, Inc.;
Analysis of Agreement Containing Consent Orders To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement.
-----------------------------------------------------------------------
SUMMARY: The consent agreement in this matter settles alleged
violations of Federal law prohibiting unfair or deceptive acts or
practices or unfair methods of competition. The attached Analysis To
Aid Public Comment describes both the allegations in the draft
complaint and the terms of the consent order--embodied in the consent
agreement--that would settle these allegations.
DATES: Comments must be received on or before December 15, 2010.
ADDRESSES: Interested parties are invited to submit written comments
electronically or in paper form. Comments should refer to ``Universal
Health Services, File No. 101 0142'' to facilitate the organization of
comments. Please note that your comment--including your name and your
State--will be placed on the public record of this proceeding,
including on the publicly accessible FTC Web site, at https://www.ftc.gov/os/publiccomments.shtm.
Because comments will be made public, they should not include any
sensitive personal information, such as an individual's Social Security
Number; date of birth; driver's license number or other State
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. Comments also
should not include any sensitive health information, such as medical
records or other individually identifiable health information. In
addition, comments should not include any ``[t]rade secret or any
commercial or financial information which is obtained from any person
and which is privileged or confidential. * * * '' as provided in
Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and Commission Rule
4.10(a)(2), 16 CFR 4.10(a)(2). Comments containing material for which
confidential treatment is requested must be filed in paper form, must
be clearly labeled ``Confidential,'' and must comply with FTC Rule
4.9(c), 16 CFR 4.9(c).\1\
---------------------------------------------------------------------------
\1\ The comment must be accompanied by an explicit request for
confidential treatment, including the factual and legal basis for
the request, and must identify the specific portions of the comment
to be withheld from the public record. The request will be granted
or denied by the Commission's General Counsel, consistent with
applicable law and the public interest. See FTC Rule 4.9(c), 16 CFR
4.9(c).
---------------------------------------------------------------------------
Because paper mail addressed to the FTC is subject to delay due to
heightened security screening, please consider submitting your comments
in electronic form. Comments filed in electronic form should be
submitted by using the following Web link: https://ftcpublic.commentworks.com/ftc/psychsolutions and following the
instructions on the Web-based form. To ensure that the Commission
considers an electronic comment, you must file it on the Web-based form
at the Web link: https://ftcpublic.commentworks.com/ftc/psychsolutions.
If this Notice appears at https://www.regulations.gov/search/index.jsp,
you may also file an electronic comment through that Web site. The
Commission will consider all comments that regulations.gov forwards to
it. You may also visit the FTC Web site at https://www.ftc.gov/ to read
the Notice and the news release describing it.
A comment filed in paper form should include the ``Universal Health
Services, File No. 101 0142'' reference both in the text and on the
envelope, and should be mailed or delivered to the following address:
Federal Trade Commission, Office of the Secretary, Room H-135 (Annex
D), 600 Pennsylvania Avenue, NW., Washington, DC 20580. The FTC is
requesting that any comment filed in paper form be sent by courier or
overnight service, if possible, because U.S. postal mail in the
Washington area and at the Commission is subject to delay due to
heightened security precautions.
The Federal Trade Commission Act (``FTC Act'') and other laws the
Commission administers permit the collection of public comments to
consider and use in this proceeding as appropriate. The Commission will
consider all timely and responsive public comments that it receives,
whether filed in paper or electronic form. Comments received will be
available to the public on the FTC Web site, to the extent practicable,
at https://www.ftc.gov/os/publiccomments.shtm. As a matter of
discretion, the Commission makes every effort to remove home contact
information for individuals from the public comments it receives before
placing those comments on the FTC Web site. More information, including
routine uses permitted by the Privacy Act, may be found in the FTC's
privacy
[[Page 71442]]
policy, at https://www.ftc.gov/ftc/privacy.shtm.
FOR FURTHER INFORMATION CONTACT: Kenneth W. Field (202-326-2868), FTC
Bureau of Competition, 600 Pennsylvania Avenue, NW., Washington, DC
20580.
SUPPLEMENTARY INFORMATION: Pursuant to section 6(f) of the Federal
Trade Commission Act, 38 Stat. 721, 15 U.S.C. 46(f), and Sec. 2.34 the
Commission Rules of Practice, 16 CFR Sec. 2.34, notice is hereby given
that the above-captioned consent agreement containing a consent order
to cease and desist, having been filed with and accepted, subject to
final approval, by the Commission, has been placed on the public record
for a period of thirty (30) days. The following Analysis to Aid Public
Comment describes the terms of the consent agreement, and the
allegations in the complaint. An electronic copy of the full text of
the consent agreement package can be obtained from the FTC Home Page
(for November 15, 2010), on the World Wide Web, at https://www.ftc.gov/os/actions.shtm. A paper copy can be obtained from the FTC Public
Reference Room, Room 130-H, 600 Pennsylvania Avenue, NW., Washington,
DC 20580, either in person or by calling (202) 326-2222.
Public comments are invited, and may be filed with the Commission
in either paper or electronic form. All comments should be filed as
prescribed in the ADDRESSES section above, and must be received on or
before the date specified in the DATES section.
Analysis of Agreement Containing Consent Order To Aid Public Comment
I. Introduction
The Federal Trade Commission (``Commission'') has accepted for
public comment, subject to final approval, an Agreement Containing
Consent Orders (``Consent Agreement'') from Alan B. Miller and
Universal Health Services, Inc. (collectively, ``UHS'') and Psychiatric
Solutions, Inc. (``PSI''). The purpose of the proposed Consent
Agreement is to remedy the anticompetitive effects that would otherwise
result from UHS's acquisition of PSI. Under the terms of the proposed
Consent Agreement, UHS is required to divest four psychiatric
facilities and eleven affiliated clinics operating in three local acute
inpatient psychiatric care markets to acquirers who receive the
approval of the Commission. The proposed Consent Agreement also
requires UHS to divest all related assets and real property necessary
to ensure that the buyer(s) of the divested facilities will be able to
quickly and fully replicate the competition that would have otherwise
been eliminated by the acquisition. Finally, UHS and PSI have agreed to
an Order to Hold Separate and Maintain Assets (``Hold Separate Order'')
that requires UHS to maintain and hold separate the facilities to be
divested pending their final divestiture pursuant to the Consent
Agreement.
The proposed Consent Agreement has been placed on the public record
for thirty days to solicit comments from interested persons. Comments
received during this period will become part of the public record.
After thirty days, the Commission again will review the proposed
Consent Agreement and comments received, and decide whether it should
withdraw the Consent Agreement, modify the Consent Agreement, or make
it final.
On May 16, 2010, UHS and PSI entered into a merger agreement under
which UHS proposes to acquire all of the outstanding voting securities
of PSI for approximately $2.0 billion in cash, and to assume
approximately $1.1 billion of PSI debt. The Commission's complaint
alleges that the proposed acquisition, if consummated, would violate
Section 7 of the Clayton Act, as amended, 15 U.S.C. 18, and Section 5
of the Federal Trade Commission Act, as amended, 15 U.S.C. 45, by
removing an actual, direct, and substantial competitor from three local
markets for acute inpatient psychiatric care. The proposed Consent
Agreement would remedy the alleged violations by requiring complete
divestitures in each of the three markets. These divestitures will
replace the competition that otherwise would be lost in these markets
as a result of the proposed acquisition.
The Parties
UHS, headquartered in King of Prussia, Pennsylvania, owns or
operates 25 general acute care hospitals and 102 behavioral health
facilities located in 32 States, Washington, DC, and Puerto Rico. It is
one of the nation's largest hospital management companies, with 2009
revenues totaling approximately $5.2 billion. In 2009, UHS's 102
behavioral health facilities generated approximately $1.3 billion in
revenue (25% of total revenues) from nearly 8,000 licensed beds and
over 2 million patient days.
PSI, headquartered in Franklin, Tennessee, operates 94 inpatient
behavioral health facilities in 32 States, Puerto Rico, and the U.S.
Virgin Islands. The 11,000 licensed beds at these facilities accounted
for 2.8 million patient days in 2009. The company also manages the
behavioral health programs for 109 general acute care hospitals owned
by third parties. PSI's revenue for the twelve months ending December
31, 2009 was approximately $1.8 billion. Behavioral health facilities
and residential treatment centers generated 93% of 2009 revenues and
the contract management business accounted for the remaining 7%.
Acute Inpatient Psychiatric Services
UHS's proposed acquisition of PSI poses substantial antitrust
concerns in the relevant product market of acute inpatient psychiatric
services. Acute inpatient psychiatric services are those provided for
the diagnosis, treatment, and care of patients deemed to be a threat to
themselves or others or unable to perform basic life functions, due to
an acute psychiatric condition.
The three acute inpatient psychiatric services markets are local in
nature. Analysis of patient flow data and evidence gathered from market
participants indicate that patients and their families prefer to find
care close to home in order to facilitate visits or participation in
family therapy. Also, emergency responders typically transport patients
in acute psychiatric distress to the nearest emergency room for
treatment or placement. The three acute inpatient psychiatric services
markets affected by the proposed acquisition are: the State of
Delaware; the Las Vegas, Nevada metropolitan statistical area; and the
Commonwealth of Puerto Rico.
The proposed acquisition would dramatically increase market
concentration in each of the relevant acute inpatient psychiatric
markets. The markets already range from moderately to highly
concentrated prior to the acquisition. In each market, the proposed
acquisition would significantly increase market concentration and
eliminate substantial, direct competition between two significant acute
inpatient psychiatric care providers. Under the 2010 Department of
Justice and Federal Trade Commission Horizontal Merger Guidelines, an
acquisition is presumed to enhance market power or facilitate its
exercise if it increases the Herfindahl-Hirschman Index (AHHI@) by more
than 200 points and results in a post-acquisition HHI that exceeds
2,500 points. The proposed acquisition far exceeds these thresholds:
the post-acquisition HHIs range from 3916 to 4942, and HHI levels would
increase by 1428 to 2610 points above pre-acquisition levels. The
proposed acquisition also would result in UHS controlling approximately
60 percent or
[[Page 71443]]
more of the acute inpatient psychiatric beds in each of the affected
markets.
The presumption of anticompetitive harm created by the steep
increases in market concentration is further supported by evidence of
the intense rivalry between UHS- and PSI-owned facilities that would be
eliminated by the proposed acquisition. In each of the local markets,
consumers have benefitted from the head-to-head competition in the form
of lower health care costs, higher quality of care, and improved
service offerings. Left unremedied, the proposed acquisition likely
would cause anticompetitive harm by enabling UHS to profit by
unilaterally raising the reimbursement rates negotiated with commercial
health plans. These costs are ultimately passed on to consumers in the
form of higher premiums, co-pays, and other out-of-pocket costs. The
loss of competition also reduces UHS's incentive to improve quality and
provide better service.
New entry is unlikely to deter or counteract the anticompetitive
effects of the proposed acquisition. Among other entry barriers,
regulatory requirements pose substantial barriers to entrants
attempting to establish new psychiatric facilities or to expand their
offerings in the relevant markets. In particular, Delaware and Puerto
Rico require Certificates of Need in order to enter or significantly
expand the number of beds provided in the market. The availability of
suitable land, local zoning regulations, and Medicare and Medicaid
certifications also impact significantly the ability of firms to enter
or expand. As a result, new entry sufficient to achieve a significant
market impact is unlikely to occur in a timely manner in these markets.
The Proposed Consent Agreement
The proposed Consent Agreement wholly remedies the anticompetitive
effects of the acquisition by requiring the divestiture of all of the
PSI or UHS assets to a Commission-approved buyer (or buyers) within six
months of the date the Consent Agreement becomes final in Delaware and
Las Vegas, and within nine months in Puerto Rico. Specifically, the
proposed Consent Agreement requires the divestiture of four facilities
that provide acute inpatient psychiatric care, as well as related
outpatient clinics, contracts, commercial trade names, and real
property, in the three geographic markets. See Appendix A for a
complete list of the divestiture assets. Each psychiatric facility and
its associated clinics to be divested in Delaware and Puerto Rico is a
stand-alone business, and includes all of the assets necessary for a
Commission-approved buyer to independently and effectively operate each
facility. The two facilities in Las Vegas are closely related and
complementary businesses and were jointly managed within PSI; as such,
the two facilities together constitute a stand-alone business, and
include all of the assets necessary for a Commission-approved buyer to
independently and effectively operate the business.
The proposed Consent Agreement contains several provisions designed
to ensure that the divestitures are successful. First, the Commission
will evaluate the suitability of possible purchasers of the divested
assets to ensure that the competitive environment that would have
existed but for the transaction is replicated by the required
divestitures. If UHS fails to divest the assets within the required
time period to a Commission-approved buyer, the Consent Agreement
permits the Commission to appoint a trustee to divest the assets.
Second, UHS is required to provide transitional services to the
Commission-approved buyer. These services will facilitate a smooth
transition of the assets to the acquirer, and ensure continued and
uninterrupted operation of the assets during the transition. Third, the
Consent Agreement requires UHS to remove any contractual impediments
that may deter the current managers of the facilities to be divested
from accepting offers of employment from any Commission-approved
acquirer and to obtain all consents necessary to transfer the required
assets. Finally, to ensure that the Commission will have an opportunity
to review any future attempt by UHS to acquire any acute inpatient
psychiatric services provider in any of the three geographic markets at
issue, the proposed Consent Agreement contains a ten-year prior notice
provision.
The Hold Separate Order requires the parties to maintain the
viability of the divestiture assets as competitive operations until
each facility is transferred to a Commission-approved buyer.
Specifically, the parties must maintain the confidentiality of
sensitive business information, and take all actions necessary to
prevent the destruction or wasting of the divestiture assets. After UHS
acquires PSI, the Hold Separate Order requires that UHS separately hold
and maintain the divestiture assets and appoint a Hold Separate Manager
to operate these assets pending their divestiture.
The sole purpose of this analysis is to facilitate public comment
on the Consent Agreement. This analysis does not constitute an official
interpretation of the Consent Agreement or modify its terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2010-29511 Filed 11-22-10; 8:45 am]
BILLING CODE 6750-01-P