This Practice Note explains how to analyze the federal antitrust implications of health care collaborations, joint ventures, and similar arrangements, including independent practice associations (IPAs), physician hospital organizations (PHOs), and Accountable Care Organizations (ACOs), focusing on how to assess their financial and clinical integration. This Note includes practical guidance on how to structure and manage these arrangements to comply with antitrust guidance and to obtain rule-of-reason treatment under the federal antitrust laws. The analysis and guidance provided in this Note are also generally applicable under most state antitrust laws, which largely mirror the federal laws.

Any opinions expressed by Christine White are solely her own and may or may not comport with those of her employer, Northwell Health, Inc.