COVID Vaccine Mandates – Update on Additional Government Guidance

The Trump administration has sharpened its focus on hospital systems as a key driver of rising health care costs, and the DOJ and FTC are actively patrolling for anticompetitive conduct and mergers that contribute to these rising costs. Managed care organizations are a critical source of evidence in these investigations and are likely to receive Civil Investigative Demands (CIDs), be contacted by agency staff, or may consider proactively engaging with antitrust authorities to address competitive concerns in their markets.