Several recent investigations of vertical transactions in healthcare, along with the promulgation of new draft Vertical Merger Guidelines by the FTC and the DOJ, suggest that vertical deals will continue to receive scrutiny from antitrust enforcers. While the VMG set forth the general framework that the agencies will use to assess vertical mergers, they provide few specifics on implementation. Nor do they address the specific issues that may arise in healthcare transactions. In this article, we
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