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Antitrust Keyed to Areeda, 8th Ed.
Federal Trade Commission v. Indiana Federation of Dentists
Citation:
476 U.S. 447 (1986)Facts
In the 1970s, dental insurers began implementing cost-containment measures by requesting that dentists submit x-rays along with insurance claims to evaluate whether the proposed treatment was necessary or if a less expensive alternative would suffice. The Indiana Dental Association initially organized resistance to these requests, but later consented to an FTC order to cease such activities. In 1976, a group of dentists formed the Indiana Federation of Dentists to continue resisting insurers’ requests for x-rays. The Federation’s membership was concentrated in three Indiana communities where it successfully enforced a “work rule” prohibiting members from submitting x-rays to insurers. This policy forced insurers to either use more expensive means of reviewing claims or abandon their cost-containment efforts altogether. The FTC found that this collective refusal constituted an unreasonable restraint of trade that eliminated competition among dentists regarding cooperation with insurers.
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