Praxedes E. Alverez Santiago, M.D., Daniel Perez Brisebois, M.D., Jorge Grillasca Palou, M.D., Rafael Garcia Nieves, M.D., Francis M. Vazques Roura, M.D., Angel B. Rivera Santos, M.D., Cosme D. Santos Torres, M.D., and Juan L. Vilaro Chardon, M.D.; Analysis of Agreement Containing Consent Order To Aid Public Comment, 14547-14549 [2013-05126]
Download as PDF
Federal Register / Vol. 78, No. 44 / Wednesday, March 6, 2013 / Notices
classification, false weighing, false
report of weight, false measurement, or
any other unjust or unfair device or
means, obtain or attempt to obtain ocean
transportation for property at less than
the rates or charges that would
otherwise apply.’’
Complainant requests that the
Commission issue the following relief:
‘‘(1) An Order compelling Respondents
to Answer the charges made herein and
scheduling a hearing in Washington, DC
during which the Commission may
receive evidence in this matter; (2) An
Order holding that the Respondents,
Centrus, Gren, and Mr. Liu Shao
individually violated § 41102(a) of the
Shipping Act; (3) An Order compelling
Respondents, Centrus, Gren, and Liu
Shao individually to make reparations
to Complainant SMA in the amount of
$63,010.68 for failure to pay freight and
related charges as describe herein; (4)
An Order requiring Respondents to
compensate SMA for its attorney’s fees,
interests, and costs and expenses
incurred in this matter according to
proof; (5) Such other and further relief
as the Commission deems just and
proper.’’
The full text of the complaint can be
found in the Commission’s Electronic
Reading Room at www.fmc.gov/13–03.
This proceeding has been assigned to
the Office of Administrative Law Judges.
The initial decision of the presiding
officer in this proceeding shall be issued
by March 3, 2014 and the final decision
of the Commission shall be issued by
July 1, 2014.
Rachel E. Dickon,
Assistant Secretary.
[FR Doc. 2013–05253 Filed 3–5–13; 8:45 am]
BILLING CODE 6730–01–P
FEDERAL TRADE COMMISSION
[File No. 121 0098]
pmangrum on DSK3VPTVN1PROD with NOTICES
Praxedes E. Alverez Santiago, M.D.,
Daniel Perez Brisebois, M.D., Jorge
Grillasca Palou, M.D., Rafael Garcia
Nieves, M.D., Francis M. Vazques
Roura, M.D., Angel B. Rivera Santos,
M.D., Cosme D. Santos Torres, M.D.,
and Juan L. Vilaro Chardon, M.D.;
Analysis of Agreement Containing
Consent Order To Aid Public Comment
Federal Trade Commission.
Proposed consent agreement.
AGENCY:
ACTION:
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
VerDate Mar<15>2010
15:01 Mar 05, 2013
Jkt 229001
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 April 2, 2013.
ADDRESSES: Interested parties may file a
comment at https://
ftcpublic.commentworks.com/ftc/
prnephrologistsconsent online or on
paper, by following the instructions in
the Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘PR Nephrologists, File
No. 121 0098’’ on your comment and
file your comment online at https://
ftcpublic.commentworks.com/ftc/
prneprologistsconsent by following the
instructions on the web-based form. If
you prefer to file your comment on
paper, mail or deliver your comment to
the following address: Federal Trade
Commission, Office of the Secretary,
Room H–113 (Annex D), 600
Pennsylvania Avenue NW., Washington,
DC 20580.
FOR FURTHER INFORMATION CONTACT:
Garry Gibbs (202–326–2767), FTC,
Bureau of Competition, 600
Pennsylvania Avenue NW., Washington,
DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 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 February 28, 2013), 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.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before April 2, 2013. Write ‘‘PR
Nephrologists, File No. 1211 0098’’ on
your comment. Your comment—
including your name and your state—
will be placed on the public record of
this proceeding, including, to the extent
practicable, on the public Commission
Web site, at https://www.ftc.gov/os/
PO 00000
Frm 00040
Fmt 4703
Sfmt 4703
14547
publiccomments.shtm. As a matter of
discretion, the Commission tries to
remove individuals’ home contact
information from comments before
placing them on the Commission Web
site.
Because your comment will be made
public, you are solely responsible for
making sure that your comment does
not include any sensitive personal
information, like anyone’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. You are also solely responsible
for making sure that your comment does
not include any sensitive health
information, like medical records or
other individually identifiable health
information. In addition, do not include
any ‘‘[t]rade secret or any commercial or
financial information which * * * is
privileged or confidential,’’ as discussed
in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
4.9(c).1 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
prnephrologistsconsent by following the
instructions on the web-based form. If
this Notice appears at https://
www.regulations.gov/#!home, you also
may file a comment through that Web
site.
If you file your comment on paper,
write ‘‘PR Nephrologists, File No. 121
0098’’ on your comment and on the
envelope, and mail or deliver it to the
following address: Federal Trade
1 In particular, the written request for confidential
treatment that accompanies the comment must
include the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record. See
FTC Rule 4.9(c), 16 CFR 4.9(c).
E:\FR\FM\06MRN1.SGM
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14548
Federal Register / Vol. 78, No. 44 / Wednesday, March 6, 2013 / Notices
Commission, Office of the Secretary,
Room H–113 (Annex D), 600
Pennsylvania Avenue NW., Washington,
DC 20580. If possible, submit your
paper comment to the Commission by
courier or overnight service.
Visit the Commission Web site at
https://www.ftc.gov to read this Notice
and the news release describing it. The
FTC Act and other laws that 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 on or
before April 2, 2013. You can find more
information, including routine uses
permitted by the Privacy Act, in the
Commission’s privacy policy, at
https://www.ftc.gov/ftc/privacy.htm.
pmangrum on DSK3VPTVN1PROD with NOTICES
Analysis of Agreement Containing
Consent Order To Aid Public Comment
The Federal Trade Commission has
accepted, subject to final approval, an
agreement containing a proposed
´
consent order with Praxedes E. Alvarez
´
Santiago, M.D., Daniel Perez Brisebois,
M.D., Jorge Grillasca Palou, M.D., Rafael
´
Garcıa Nieves, M.D., Francis M.
´
Vazquez Roura, M.D., Angel B. Rivera
Santos, M.D., Cosme D. Santos Torres,
´
´
M.D., and Juan L. Vilaro Chardon, M.D.
(‘‘Respondents’’). The agreement settles
charges that Respondents violated
Section 5 of the Federal Trade
Commission Act, as amended, 15 U.S.C.
45, by jointly negotiating contracts to fix
the prices for their services and by
collectively refusing to deal with a
third-party payer in Puerto Rico.
The proposed consent order has been
placed on the public record for 30 days
to receive comments from interested
persons. Comments received during this
period will become part of the public
record. After 30 days, the Commission
will review the agreement and the
comments received, and will decide
whether it should withdraw from the
agreement or make the proposed
consent order final.
The purpose of this analysis is to
facilitate public comment on the
proposed consent order. The analysis is
not intended to constitute an official
interpretation of the agreement and
proposed consent order, or to modify
their terms in any way. Further, the
proposed consent order has been
entered into for settlement purposes
only and does not constitute an
admission by Respondents that they
violated the law or that the facts alleged
in the proposed complaint (other than
jurisdictional facts) are true.
VerDate Mar<15>2010
15:01 Mar 05, 2013
Jkt 229001
The Proposed Complaint
Respondents are eight independent
physicians in southwestern Puerto Rico
who provide nephrology services for
commercial, Medicare, and Medicaid
patients through contracts with various
payers. Respondents constitute almost
90 percent of the nephrologists in the
southwestern region of Puerto Rico.
The Medicaid program in Puerto Rico,
Mi Salud, is administered by
´
Administracion de Seguros de Salud
(‘‘ASES’’), a public corporation that is
charged with ensuring that the more
than 1.5 million indigent residents of
Puerto Rico have access to a full
complement of medical services. ASES
determines the benefits Mi Salud
members will receive. ASES contracts
with two health plans, Humana Health
Plans of Puerto Rico, Inc. (‘‘Humana’’)
and Triple-S, to facilitate the provision
of medical services to Mi Salud
members and payments to participating
providers. Humana administers the Mi
Salud program in the southwestern
region of Puerto Rico, where the
Respondents do business.
The Mi Salud reimbursement program
was modified in October 2010 for Mi
Salud members who are also covered by
Medicare (‘‘dual eligibles’’). Under the
previous program Medicare paid 80
percent of its established rate, and
payers administering the Mi Salud
program paid the remaining 20 percent,
known as the coordination of benefits
amount (‘‘20 percent COB’’). After
October 2010, providers no longer
received a coordination of benefits
amount for dual eligibles, except in rare
circumstances. As a result of this
change, providers’ reimbursements
decreased for dual eligibles under the
Mi Salud program.
The proposed complaint alleges that
Respondents collectively (1) negotiated
in an attempt to extract higher
reimbursement rates by fixing the prices
upon which Respondents would
contract with Humana and (2)
terminated their contracts with Humana
and refused to treat Humana patients
enrolled in the Mi Salud program
because Humana would not acquiesce to
Respondents’ price-related demands.
The joint price negotiations and
collective refusals to deal commenced
in late 2011. On October 28, 2011, Dr.
Jorge Grillasca sent an email to Humana
stating that Humana’s failure to
reimburse the full 20 percent COB
would force him to discontinue his
treatment of Humana’s Mi Salud
members and create a dangerous
situation for these patients. He
requested that Humana ‘‘hold an urgent
meeting with me and other colleagues
PO 00000
Frm 00041
Fmt 4703
Sfmt 4703
that share the same concern.’’ He copied
all of the other Respondents on this
email.
The meeting occurred on December 8,
2011, when two of the Respondents, Dr.
Angel Rivera Santos and Dr. Daniel
Perez, met with Humana representatives
to discuss the 20 percent COB. During
that meeting, Dr. Daniel Perez presented
to Humana a fee schedule that proposed
higher reimbursement rates. The next
day Dr. Rivera Santos wrote an email to
Humana stating, ‘‘I understand as well
that I have the right to receive the 20%
that had been denied. It will depend on
these issues if I decide to continue my
professional relationship with Humana
Mi Salud. Also remember that I am
waiting for your response related to the
newly proposed rates that were handed
to you yesterday by my colleague Dr.
Daniel Perez.’’ Dr. Rivera Santos copied
all the other Respondents on this email.
The following February 2012, ASES
and Humana met with Respondents to
discuss the 20 percent COB rule. At the
conclusion of the meeting, Dr. Grillasca
presented to Humana a fee schedule
proposing increased rates. On February
28, 2012, Dr. Grillasca stated in an email
to Humana that the payer had until
March 1, 2012, to respond to the
Respondents’ proposed fee schedule. He
copied the other Respondents on this
email. When Humana did not respond
by the March 1 deadline, all eight
Respondents terminated their Mi Salud
service agreements with Humana with
virtually identical letters.
Respondents immediately ceased
providing nephrology services to
Humana Mi Salud patients despite
having a legal obligation under their
contract with Humana to continue
providing services for 120 days after
giving written notice of termination.
The termination of services had
significant and real consequences to
patients. In one instance, a patient with
critical renal failure arrived at an area
hospital in need of immediate care and
likely long-term dialysis treatment. All
of the nephrologists refused to treat the
patient, whose condition worsened and
who was later transferred to a hospital
74 miles away in San Juan. Dr. Grillasca
told hospital personnel that the
nephrologists were not taking Mi Salud
patients due to a disagreement with
Humana over rates. On the same day,
Respondents refused to treat another
Humana Mi Salud patient admitted to
another area hospital with a renal
illness. The patient’s family objected to
the patient’s transfer to a hospital with
nephrology services that was 67 miles
away. Respondents eventually began
treating patients again only after being
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06MRN1
Federal Register / Vol. 78, No. 44 / Wednesday, March 6, 2013 / Notices
pmangrum on DSK3VPTVN1PROD with NOTICES
ordered to do so by Puerto Rico’s Office
of the Health Advocate.
ASES ultimately agreed to
Respondents’ demand for higher
reimbursement rates. ASES believed it
had no choice but to acquiesce to
Respondents’ demands because of its
concerns over access to nephrology
services for Mi Salud patients. On June
13, 2012, ASES abandoned the new
reimbursement formula and reinstated
the 20 percent COB. The requirement
that payers reimburse providers the full
20 percent COB, retroactive to March
16, 2012, is estimated to cost ASES and
the Mi Salud program an additional $4
million to $6 million annually. Thus,
the denial of nephrology services and
the demands for higher reimbursement
rates caused substantial harm to the
consumers of Puerto Rico.
Finally, the proposed complaint
alleges that Respondents’ actions were a
naked agreement to fix prices and a
collective refusal to deal, not related to
any efficiency-enhancing justification or
any efforts at clinical or financial
integration. Respondents, at all times
relevant to the proposed complaint,
maintained separate, independent
nephrology practices and made no
attempt to share the financial risk in the
provision of nephrology services or to
clinically integrate the delivery of care
to patients, which might justify the
otherwise illegal joint activity.
The Proposed Consent Order
The proposed consent order is
designed to prevent the continuance
and recurrence of the illegal conduct
alleged in the proposed complaint,
while not prohibiting the Respondents
to engage in legitimate joint conduct in
the future, if they so choose.
Paragraph II of the proposed consent
order prevents Respondents from
continuing the challenged conduct. In
particular, Paragraph II.A prevents
Respondents from entering into or
participating in agreements: (1) To
negotiate on behalf of another physician
with any payer, (2) to refuse to deal, or
threaten to refuse to deal with any
payer, or (3) regarding any term,
condition, or requirement upon which
another physician deals, or is willing to
deal, with any payer, including, but not
limited to, price terms.
The other parts of Paragraph II
reinforce these general prohibitions.
Paragraph II.B prohibits Respondents
from exchanging information with
another physician concerning whether
and on what terms that other physician
is willing to contract with a payer.
Paragraph II.C prevents Respondents
from entering into agreements to
withhold services from any person.
VerDate Mar<15>2010
15:01 Mar 05, 2013
Jkt 229001
Paragraph II.D bars Respondents from
exchanging information among
physicians concerning any physician’s
willingness to offer or withhold services
from any person. Paragraph II.E
prohibits attempts to engage in the
actions precluded by Paragraphs II.A,
II.B, II.C, or II.D. Paragraph II.F
proscribes encouraging or attempting to
induce any action that would be
prohibited by Paragraph II. Nothing in
Paragraph II prohibits any agreement or
conduct among Respondents that is
reasonably necessary to a Qualified
Arrangement.
Paragraph III requires Respondents to
provide the Commission with notice
and certain information before entering
into a Qualified Arrangement. Paragraph
III.A requires Respondents to notify the
Commission 60 days prior to entering
into any Qualified Arrangement.
Paragraph III.B requires Respondents to
provide information about the nature
and effects of the proposed agreement as
part of the Paragraph III.A notification.
Paragraph III.C allows the Commission
to make a written request for additional
information within 60 days, which then
prevents the participating Respondents
from entering into the proposed
agreement until 30 days after
substantially complying with the
request for additional information.
Paragraphs III.D through F state that
certain actions with respect to a
proposed Qualified Arrangement should
not be construed as a determination by
the Commission that the action violates
the law, is approved, or violates this
order.
Paragraph IV is similarly designed to
prevent the challenged conduct from
recurring by requiring Respondents to
send copies of the complaint and
consent order to those impacted by its
terms. Paragraph IV.A requires each
Respondent to send a copy of the
complaint and consent order to every
physician, officer, manager, and staff
member in each Respondent’s medical
practice group at any time since January
1, 2010. Paragraph IV.A also requires
each Respondent to send a copy of the
complaint and consent order to every
payer whom Respondent had contacted
regarding contracting for physician
services at any time since January 1,
2010. Paragraph IV.B carries the
provisions in Paragraph IV.A forward
for three years from the date of the
order.
Paragraphs V, VI, and VII impose
various obligations on Respondents to
report or to provide access to
information to the Commission to
facilitate Respondents’ compliance with
the consent order. Finally, Paragraph
VIII provides that the proposed consent
PO 00000
Frm 00042
Fmt 4703
Sfmt 4703
14549
order will expire 20 years from the date
it is issued.
By direction of the Commission.,
Chairman Leibowitz not participating.
Donald S. Clark,
Secretary.
[FR Doc. 2013–05126 Filed 3–5–13; 8:45 am]
BILLING CODE 6750–01–P
GENERAL SERVICES
ADMINISTRATION
[OMB Control No. 3090–0278; Docket 2012–
0001; Sequence 19]
National Contact Center; Information
Collection; National Contact Center
Customer Evaluation Survey
Contact Center Services,
Federal Citizen Information Center,
Office of Citizen Services and
Innovative Technologies, General
Services Administration.
ACTION: Notice of request for comments
regarding an extension to an existing
OMB clearance.
AGENCY:
SUMMARY: Under the provisions of the
Paperwork Reduction Act, the General
Services Administration will be
submitting to the Office of Management
and Budget (OMB) a request to review
and approve an extension of a
previously approved information
collection requirement regarding the
National Contact Center customer
evaluation surveys. In this request, the
previously approved surveys have been
supplemented with surveys that will
temporarily replace those existing
surveys for one period of several
months. These temporary surveys will
allow the National Contact Center to
compare its customer service levels to
those of private industry contact
centers.
Submit comments on or before:
May 6, 2013.
FOR FURTHER INFORMATION CONTACT:
Tonya Beres, Federal Information
Specialist, Office of Citizen Services and
Communications, at telephone (202)
501–1803 or via email to
tonya.beres@gsa.gov.
DATES:
Submit comments
identified by Information Collection
3090–0278, National Contact Center
Evaluation Survey, by any of the
following methods:
• Regulations.gov: https://
www.regulations.gov. Submit comments
via the Federal eRulemaking portal by
searching the OMB control number.
Select the link ‘‘Submit a Comment’’
that corresponds with ‘‘Information
Collection 3090–0278, National Contract
ADDRESSES:
E:\FR\FM\06MRN1.SGM
06MRN1
Agencies
[Federal Register Volume 78, Number 44 (Wednesday, March 6, 2013)]
[Notices]
[Pages 14547-14549]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-05126]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 121 0098]
Praxedes E. Alverez Santiago, M.D., Daniel Perez Brisebois, M.D.,
Jorge Grillasca Palou, M.D., Rafael Garcia Nieves, M.D., Francis M.
Vazques Roura, M.D., Angel B. Rivera Santos, M.D., Cosme D. Santos
Torres, M.D., and Juan L. Vilaro Chardon, M.D.; Analysis of Agreement
Containing Consent Order 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 April 2, 2013.
ADDRESSES: Interested parties may file a comment at https://ftcpublic.commentworks.com/ftc/prnephrologistsconsent online or on
paper, by following the instructions in the Request for Comment part of
the SUPPLEMENTARY INFORMATION section below. Write ``PR Nephrologists,
File No. 121 0098'' on your comment and file your comment online at
https://ftcpublic.commentworks.com/ftc/prneprologistsconsent by
following the instructions on the web-based form. If you prefer to file
your comment on paper, mail or deliver your comment to the following
address: Federal Trade Commission, Office of the Secretary, Room H-113
(Annex D), 600 Pennsylvania Avenue NW., Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Garry Gibbs (202-326-2767), FTC,
Bureau of Competition, 600 Pennsylvania Avenue NW., Washington, DC
20580.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 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 February 28, 2013), 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.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before April 2, 2013.
Write ``PR Nephrologists, File No. 1211 0098'' on your comment. Your
comment--including your name and your state--will be placed on the
public record of this proceeding, including, to the extent practicable,
on the public Commission Web site, at https://www.ftc.gov/os/publiccomments.shtm. As a matter of discretion, the Commission tries to
remove individuals' home contact information from comments before
placing them on the Commission Web site.
Because your comment will be made public, you are solely
responsible for making sure that your comment does not include any
sensitive personal information, like anyone'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. You are also solely
responsible for making sure that your comment does not include any
sensitive health information, like medical records or other
individually identifiable health information. In addition, do not
include any ``[t]rade secret or any commercial or financial information
which * * * is privileged or confidential,'' as discussed in Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
If you want the Commission to give your comment confidential
treatment, you must file it in paper form, with a request for
confidential treatment, and you have to follow the procedure explained
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept
confidential only if the FTC General Counsel, in his or her sole
discretion, grants your request in accordance with the law and the
public interest.
---------------------------------------------------------------------------
\1\ In particular, the written request for confidential
treatment that accompanies the comment must include the factual and
legal basis for the request, and must identify the specific portions
of the comment to be withheld from the public record. See FTC Rule
4.9(c), 16 CFR 4.9(c).
---------------------------------------------------------------------------
Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/ftc/prnephrologistsconsent by following the instructions on the web-
based form. If this Notice appears at https://www.regulations.gov/#!home, you also may file a comment through that Web site.
If you file your comment on paper, write ``PR Nephrologists, File
No. 121 0098'' on your comment and on the envelope, and mail or deliver
it to the following address: Federal Trade
[[Page 14548]]
Commission, Office of the Secretary, Room H-113 (Annex D), 600
Pennsylvania Avenue NW., Washington, DC 20580. If possible, submit your
paper comment to the Commission by courier or overnight service.
Visit the Commission Web site at https://www.ftc.gov to read this
Notice and the news release describing it. The FTC Act and other laws
that 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 on or before April 2, 2013. You can find more information,
including routine uses permitted by the Privacy Act, in the
Commission's privacy policy, at https://www.ftc.gov/ftc/privacy.htm.
Analysis of Agreement Containing Consent Order To Aid Public Comment
The Federal Trade Commission has accepted, subject to final
approval, an agreement containing a proposed consent order with
Pr[aacute]xedes E. Alvarez Santiago, M.D., Daniel P[eacute]rez
Brisebois, M.D., Jorge Grillasca Palou, M.D., Rafael Garc[iacute]a
Nieves, M.D., Francis M. V[aacute]zquez Roura, M.D., Angel B. Rivera
Santos, M.D., Cosme D. Santos Torres, M.D., and Juan L. Vilar[oacute]
Chard[oacute]n, M.D. (``Respondents''). The agreement settles charges
that Respondents violated Section 5 of the Federal Trade Commission
Act, as amended, 15 U.S.C. 45, by jointly negotiating contracts to fix
the prices for their services and by collectively refusing to deal with
a third-party payer in Puerto Rico.
The proposed consent order has been placed on the public record for
30 days to receive comments from interested persons. Comments received
during this period will become part of the public record. After 30
days, the Commission will review the agreement and the comments
received, and will decide whether it should withdraw from the agreement
or make the proposed consent order final.
The purpose of this analysis is to facilitate public comment on the
proposed consent order. The analysis is not intended to constitute an
official interpretation of the agreement and proposed consent order, or
to modify their terms in any way. Further, the proposed consent order
has been entered into for settlement purposes only and does not
constitute an admission by Respondents that they violated the law or
that the facts alleged in the proposed complaint (other than
jurisdictional facts) are true.
The Proposed Complaint
Respondents are eight independent physicians in southwestern Puerto
Rico who provide nephrology services for commercial, Medicare, and
Medicaid patients through contracts with various payers. Respondents
constitute almost 90 percent of the nephrologists in the southwestern
region of Puerto Rico.
The Medicaid program in Puerto Rico, Mi Salud, is administered by
Administraci[oacute]n de Seguros de Salud (``ASES''), a public
corporation that is charged with ensuring that the more than 1.5
million indigent residents of Puerto Rico have access to a full
complement of medical services. ASES determines the benefits Mi Salud
members will receive. ASES contracts with two health plans, Humana
Health Plans of Puerto Rico, Inc. (``Humana'') and Triple-S, to
facilitate the provision of medical services to Mi Salud members and
payments to participating providers. Humana administers the Mi Salud
program in the southwestern region of Puerto Rico, where the
Respondents do business.
The Mi Salud reimbursement program was modified in October 2010 for
Mi Salud members who are also covered by Medicare (``dual eligibles'').
Under the previous program Medicare paid 80 percent of its established
rate, and payers administering the Mi Salud program paid the remaining
20 percent, known as the coordination of benefits amount (``20 percent
COB''). After October 2010, providers no longer received a coordination
of benefits amount for dual eligibles, except in rare circumstances. As
a result of this change, providers' reimbursements decreased for dual
eligibles under the Mi Salud program.
The proposed complaint alleges that Respondents collectively (1)
negotiated in an attempt to extract higher reimbursement rates by
fixing the prices upon which Respondents would contract with Humana and
(2) terminated their contracts with Humana and refused to treat Humana
patients enrolled in the Mi Salud program because Humana would not
acquiesce to Respondents' price-related demands.
The joint price negotiations and collective refusals to deal
commenced in late 2011. On October 28, 2011, Dr. Jorge Grillasca sent
an email to Humana stating that Humana's failure to reimburse the full
20 percent COB would force him to discontinue his treatment of Humana's
Mi Salud members and create a dangerous situation for these patients.
He requested that Humana ``hold an urgent meeting with me and other
colleagues that share the same concern.'' He copied all of the other
Respondents on this email.
The meeting occurred on December 8, 2011, when two of the
Respondents, Dr. Angel Rivera Santos and Dr. Daniel Perez, met with
Humana representatives to discuss the 20 percent COB. During that
meeting, Dr. Daniel Perez presented to Humana a fee schedule that
proposed higher reimbursement rates. The next day Dr. Rivera Santos
wrote an email to Humana stating, ``I understand as well that I have
the right to receive the 20% that had been denied. It will depend on
these issues if I decide to continue my professional relationship with
Humana Mi Salud. Also remember that I am waiting for your response
related to the newly proposed rates that were handed to you yesterday
by my colleague Dr. Daniel Perez.'' Dr. Rivera Santos copied all the
other Respondents on this email.
The following February 2012, ASES and Humana met with Respondents
to discuss the 20 percent COB rule. At the conclusion of the meeting,
Dr. Grillasca presented to Humana a fee schedule proposing increased
rates. On February 28, 2012, Dr. Grillasca stated in an email to Humana
that the payer had until March 1, 2012, to respond to the Respondents'
proposed fee schedule. He copied the other Respondents on this email.
When Humana did not respond by the March 1 deadline, all eight
Respondents terminated their Mi Salud service agreements with Humana
with virtually identical letters.
Respondents immediately ceased providing nephrology services to
Humana Mi Salud patients despite having a legal obligation under their
contract with Humana to continue providing services for 120 days after
giving written notice of termination. The termination of services had
significant and real consequences to patients. In one instance, a
patient with critical renal failure arrived at an area hospital in need
of immediate care and likely long-term dialysis treatment. All of the
nephrologists refused to treat the patient, whose condition worsened
and who was later transferred to a hospital 74 miles away in San Juan.
Dr. Grillasca told hospital personnel that the nephrologists were not
taking Mi Salud patients due to a disagreement with Humana over rates.
On the same day, Respondents refused to treat another Humana Mi Salud
patient admitted to another area hospital with a renal illness. The
patient's family objected to the patient's transfer to a hospital with
nephrology services that was 67 miles away. Respondents eventually
began treating patients again only after being
[[Page 14549]]
ordered to do so by Puerto Rico's Office of the Health Advocate.
ASES ultimately agreed to Respondents' demand for higher
reimbursement rates. ASES believed it had no choice but to acquiesce to
Respondents' demands because of its concerns over access to nephrology
services for Mi Salud patients. On June 13, 2012, ASES abandoned the
new reimbursement formula and reinstated the 20 percent COB. The
requirement that payers reimburse providers the full 20 percent COB,
retroactive to March 16, 2012, is estimated to cost ASES and the Mi
Salud program an additional $4 million to $6 million annually. Thus,
the denial of nephrology services and the demands for higher
reimbursement rates caused substantial harm to the consumers of Puerto
Rico.
Finally, the proposed complaint alleges that Respondents' actions
were a naked agreement to fix prices and a collective refusal to deal,
not related to any efficiency-enhancing justification or any efforts at
clinical or financial integration. Respondents, at all times relevant
to the proposed complaint, maintained separate, independent nephrology
practices and made no attempt to share the financial risk in the
provision of nephrology services or to clinically integrate the
delivery of care to patients, which might justify the otherwise illegal
joint activity.
The Proposed Consent Order
The proposed consent order is designed to prevent the continuance
and recurrence of the illegal conduct alleged in the proposed
complaint, while not prohibiting the Respondents to engage in
legitimate joint conduct in the future, if they so choose.
Paragraph II of the proposed consent order prevents Respondents
from continuing the challenged conduct. In particular, Paragraph II.A
prevents Respondents from entering into or participating in agreements:
(1) To negotiate on behalf of another physician with any payer, (2) to
refuse to deal, or threaten to refuse to deal with any payer, or (3)
regarding any term, condition, or requirement upon which another
physician deals, or is willing to deal, with any payer, including, but
not limited to, price terms.
The other parts of Paragraph II reinforce these general
prohibitions. Paragraph II.B prohibits Respondents from exchanging
information with another physician concerning whether and on what terms
that other physician is willing to contract with a payer. Paragraph
II.C prevents Respondents from entering into agreements to withhold
services from any person. Paragraph II.D bars Respondents from
exchanging information among physicians concerning any physician's
willingness to offer or withhold services from any person. Paragraph
II.E prohibits attempts to engage in the actions precluded by
Paragraphs II.A, II.B, II.C, or II.D. Paragraph II.F proscribes
encouraging or attempting to induce any action that would be prohibited
by Paragraph II. Nothing in Paragraph II prohibits any agreement or
conduct among Respondents that is reasonably necessary to a Qualified
Arrangement.
Paragraph III requires Respondents to provide the Commission with
notice and certain information before entering into a Qualified
Arrangement. Paragraph III.A requires Respondents to notify the
Commission 60 days prior to entering into any Qualified Arrangement.
Paragraph III.B requires Respondents to provide information about the
nature and effects of the proposed agreement as part of the Paragraph
III.A notification. Paragraph III.C allows the Commission to make a
written request for additional information within 60 days, which then
prevents the participating Respondents from entering into the proposed
agreement until 30 days after substantially complying with the request
for additional information. Paragraphs III.D through F state that
certain actions with respect to a proposed Qualified Arrangement should
not be construed as a determination by the Commission that the action
violates the law, is approved, or violates this order.
Paragraph IV is similarly designed to prevent the challenged
conduct from recurring by requiring Respondents to send copies of the
complaint and consent order to those impacted by its terms. Paragraph
IV.A requires each Respondent to send a copy of the complaint and
consent order to every physician, officer, manager, and staff member in
each Respondent's medical practice group at any time since January 1,
2010. Paragraph IV.A also requires each Respondent to send a copy of
the complaint and consent order to every payer whom Respondent had
contacted regarding contracting for physician services at any time
since January 1, 2010. Paragraph IV.B carries the provisions in
Paragraph IV.A forward for three years from the date of the order.
Paragraphs V, VI, and VII impose various obligations on Respondents
to report or to provide access to information to the Commission to
facilitate Respondents' compliance with the consent order. Finally,
Paragraph VIII provides that the proposed consent order will expire 20
years from the date it is issued.
By direction of the Commission.,
Chairman Leibowitz not participating.
Donald S. Clark,
Secretary.
[FR Doc. 2013-05126 Filed 3-5-13; 8:45 am]
BILLING CODE 6750-01-P