You can post anonymously at:

https://www.regulations.gov/document/FTC-2022-0003-0001

 

The DOJ and FTC are requesting feedback on merger guidelines from real people as opposed to corporations. The leaders of TakeMedicineBack believe that the DOJ and FTC are under-informed about consolidation of the healthcare system and the growth of private equity (PE) ownership in medicine. We believe that the voices of Nurse Practitioners and Physician Assistants who feel that they have been exploited or placed in unfair clinical scenarios due to greed deserve to be heard by the FTC

 

Your comments can be anonymous. They do not have to be long or referenced. Speak from the heart. We suggest you comment on any of the following you feel comfortable with:

 

• Corporate staffing groups prioritize “throughput” metrics that emphasize seeing too many patients per hour for safety for any practitioner, NP, PA, MD, or DO.

• Corporate employers inappropriately utilize NPs and PAs to generate revenue for consolidated corporate investors, which often leaves them without adequate access to physician consultation. Ultimately, this leaves patients vulnerable. 

• Professional organizations, such as the corporate-backed American Academy of Nurse Practitioners (AANP), are sponsored by, among others, United Health, an insurance company and the largest employer of physicians in the country, CVS minute clinics, and multiple pharmaceutical companies, all of which have a vested interest in lower labor costs and over-prescription of expensive pharmaceuticals. AANP is one of the organizations heavily lobbying for independent practice of Nurse Practitioners–this demonstrates a clear conflict of interest between corporate profit and patient wellbeing. Nurse practitioners were never intended to be in independent practice.

• [If leaving comment anonymously] NPs and PAs who feel opposed to the corporate consolidation of medicine risk retaliation from employers and compromised specialty societies. 

• Why did you leave bedside nursing? Were you understaffed as a bedside nurse due to a consolidated hospital system? 

• Corporations pit Nurse Practitioners, Physician Assistants, and Physicians against one another to benefit their bottom line. In the end, it is the patient who pays the price.

 

You can consider following this framework:

 

[I am a Nurse Practitioner or Physician Assistant] practicing in [field] and am very concerned about corporate abuses and mergers placing patients at risk in my field. I went into this field to improve access for high-quality healthcare for disadvantaged communities. Medical school and residency can be cost-prohibitive for many people. I was not prepared to be thrust into an environment where I did not have enough time to provide meaningful care to patients or consult a physician when necessary. About 30 states have “independent practice” laws where an NP or PA can diagnose, treat, and prescribe without any supervision by a physician (MD or DO). Unfortunately, what I have seen, even in states requiring supervision, is that consolidated staffing groups, hospitals, private-equity backed groups, and even in government programs (VA, FQHC), result in us being overworked and not having adequate access to physicians for complicated cases. I feel that this is exploitative not only of us as practitioners, but is placing patients at risk in order to pad corporate profits. 

 

[If posting anonymously, consider explaining why you are posting anonymously. Do you fear retaliation from your specialty society? Your employer? Don’t be afraid to name names if you have been employed by a consolidated medical group; HCA, TeamHealth, Envision, USACs, etc. etc. The more personal your story is, the better. It can be brief!]