Introduction

The Antitrust Division of the United States Department of Justice (“DOJ”) and the Federal Trade Commission (“FTC”) released a revised version of their “Statements of Antitrust Enforcement Policy in Health Care” (“Guidelines”) on August 28, 1996. While all nine Statements contained in the Guidelines were reissued, only Statement 8 on physician network joint ventures and Statement 9 on multiprovider networks were revised. A seemingly…