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UNITED STATES OF AMERICA 
BEFORE FEDERAL TRADE COMMISSIONI
N THE
M
 ATTER OF
T
HE
M
 AINE
H
EALTH
 A 
LLIANCE
,
 A CORPORATION AND
 W 
ILLIAM
R.D
IGGINS
,
INDIVIDUALLY FTC File No. 021-0017
COMMENTS OF CITIZENS FOR VOLUNTARY TRADE
Proposed Consent AgreementAnnounced July 19, 2003Comments Filed August 18, 2003
Pursuant to the Federal Trade Commission’s publication of aproposed consent agreement in the above-captioned matter
1
,Citizens for Voluntary Trade, a Virginia nonprofit corporation,files the following comments.IThe Maine Health Alliance (MHA) is a nonprofit corporationcomposed of approximately 325 physicians and eleven hospitalsdoing business in northeastern Maine. William R. Diggins is
MHA’s executive director and, according to the FTC, served asthe Alliance’s principal negotiator with third-party payors in thehealthcare market.The FTC’s complaint details MHA’s efforts to collectivelynegotiate on behalf of its physician and hospital members withthird-party payors during a period extending from about 1996 to2002. The complaint alleges numerous contracts negotiatedbetween MHA and payors violated section 5 of the Federal TradeCommission Act, 15 U.S.C. § 45, because MHA’s actions coercedthe payors into paying Alliance members higher fees than otherphysicians and hospitals in Maine. The complaint also allegesMHA’s members failed to “engage in any significant form of financial risk sharing or clinical integration,” that would justifycollective negotiating activities. Consequently, the proposed
1
68 Fed. Reg. 43,515-43,517 (July 23, 2003).
 
I
N THE
M
 ATTER OF
M
 AINE
H
EALTH
 A 
LLIANCE AND
 W 
ILLIAM
R.D
IGGINS
Comments of Citizens for Voluntary Trade
2consent order forbids MHA from collectively negotiating in thefuture absent FTC-
approved “risk sharing,” and permits payorsto terminate existing contracts with MHA. The proposed orderextends these prohibitions to William Diggins individually, andthe order itself will continue in force for twenty years, untilapproximately August 2023.II A The FTC’s legal argument for seeking relief in this case turnson the definition of “coercion”. The Commission defines coercionhere to prohibit the voluntary association of MHA members fortheir mutual benefitwhen such association affects the economicinterests of “consumers,” here meaning third-party payors whoadminister Health Maintenance Organizations (HMOs) in theState of Maine. Because HMOs were notguaranteed certain pricelevels for physician services, the FTC infers illegal conduct by thephysicians under 15 U.S.C. § 45, which broadly prohibits “unfair”methods of competition. The FTC considers physician collectivenegotiating coercive, thus “unfair” and illegal. This definition,however, ignores the plain meaning of coercion for the sake of improperly expanding the Commission’s ability to regulate thehealthcare market, both in Maine and throughout the nation.In paragraph 38 of the complaint, theFTC expressly defines itsapplication of coercion to this case:
To exert pressure on and coerce these payors to agree to the Alliance terms, Alliance physician and hospital membersinformed such payors that they would not negotiateindividually, and told the payors to contract for the Alliance
members’ services only through the Alliance. As a result of thecollective conduct, the Alliance has successfully obtainedcontracts on behalf of its physicians and hospitals with thesepayors on terms demanded by the Alliance.
By this reasoning, the FTC considers it coercive for individuals toexercise their economic rights through a voluntary cooperativeagreement. This implies individual rights
ûsuch as the right tocontractûare lost under the antitrust laws when individuals seekto exercise their rights jointly. This implication is borne out inthe complaint, which clearly states doctors and hospitals may
individually
contract with HMOs without legal penalty.
 
I
N THE
M
 ATTER OF
M
 AINE
H
EALTH
 A 
LLIANCE AND
 W 
ILLIAM
R.D
IGGINS
Comments of Citizens for Voluntary Trade
3
The FTC’s theory is that individuals must lose their rightswhen they band together to increase their
economic
power,because such economic power is inherently and inevitably
coercive. An HMO, in the FTC’s view, lacks the necessaryeconomic power to countermand the economic power of MHA.Thus, to preserve market “competition”, it is necessary to curtailMHA’s economic power through
force
, in this case the FTC’sproposed order. By taking this action, the FTC claims it hasremoved a coercive element from the marketplace, allowing forgreater competition.The FTC clearly does not make the proper distinction betweeneconomic and political power, and by extension theproperdefinition of coercion. Indeed, as we understand it, coerciondefines the difference between economic and political power, aswriter-philosopher Ayn Rand explained in the early 1960s:
[E]conomic power is exercised by means of a
positive
, byoffering men a reward , an incentive, a payment, a value;political power is exercised by means of a
negative
, by thethreat of punishment, injury, imprisonment, destruction.
2
(Emphasis in original)
Political power, as defined above, is thus coercive. Moreimportantly,
only
political power is coercive; those possessing only economic power cannot, by definition, coerce others.
Consider the nature of MHA’s relationship to the HMOs itallegedly coerced. MHA possessed something of valueûphysicianand hospital servicesûthat the HMOs sought for their use. TheHMOs presented an offer to MHA’s members, who in turncollectively presented a counter-offer. The resulting negotiationsrepresented the efforts of both parties to influence the other intoaccepting certain terms of providing medical services for a fee.This entire process was a purely intellectual exercise. By theFTC’s own admission, MHA used purely non-forcefulmeans toadvance its arguments. The complaint describes MHA’ssupposedly illegal activities with such verbs as “urging”,“facilitating”, “discouraging”, and “warning”.
3
 What thecomplaint does not describe, however, is any instance of MHA threatening or using 
physical force
against any HMO. The
2
 Ayn Rand, “America’s Persecuted Minority: Big Business”,
in
Capitalism: TheUnknown Idealat 46 (Sugnet, 1967).
3
Complaint at para. 29.
of 00

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