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Advocacy Filings

FTC Staff Comment Submitted to the Food and Drug Administration, In Response to FDA's Request For Comments on Its Guidance for Industry on the “Nonproprietary Naming of Biological Products; Draft Guidance for Industry; Availability”

Date

October 28, 2015

Matter Number

P131208

Docket Number

FDA-2013-D-1543 [80 Fed. Reg. 52296 (Aug. 28, 2015)]

FTC staff submitted a comment to the FDA, in response to the FDA’s request for comment on its draft guidance addressing nonproprietary names for biological products. The comment expressed concern that...

Text of the FTC Staff Comment (125.01 KB)

Advocacy Filings

FTC Staff Comment to the Virginia Department of Health Regarding Virginia's Rules and Regulations Governing Cooperative Agreements

Date

October 15, 2015

Matter Number

V150012

Docket Number

12 Virginia Administrative Code 5, Chapter 221

FTC staff submitted comments to the Virginia and Tennessee health departments, in response to calls for public comments, as part of those agencies’ respective processes to promulgate proposed rules...

Text of the FTC Staff Comment (114.87 KB)

Advocacy Filings

FTC Staff Comment to the Tennessee Department of Health Regarding the Implementation of Laws Relative to Cooperative Agreements and the Granting of Certificates of Public Advantage

Date

October 15, 2015

Matter Number

V150013

Docket Number

Proposed Chapter 1200-38-01 of the Hospital Cooperation Act of 1993

Text of the FTC Staff Comment (113.64 KB)

Advocacy Filings

FTC Staff Comment Before the Food and Drug Administration Regarding the Current Use of Human Drug and Biological Products Labeled As Homeopathic, and the FDA's Regulatory Framework For Such Products

Date

August 21, 2015

Matter Number

P114505

Docket Number

80 Fed. Reg. 16327 (Mar. 27, 2015)

FTC staff has recommended that the U.S. Food and Drug Administration (FDA) reconsider the framework it uses to regulate homeopathic medications because it may appear to conflict with the FTC’s...

FTC Staff Comment Before the Food and Drug Administration Regarding the Current Use of Human Drug and Biological Products Labeled As Homeopathic, and the FDA's Regulatory Framework For Such Products (96.56 KB)

Exhibit A (1.61 MB)

Exhibit B-Part 1 (2.51 MB)

Exhibit B-Part 2 (3.34 MB)

Exhibit C (5.08 MB)

Advocacy Filings

FTC Staff Comment, and Concurring Comment of Commissioner Wright, Regarding North Carolina House Bill 200, Which Would Exempt Diagnostic Centers, Ambulatory Surgical Facilities and Psychiatric Hospitals From Certificate of Need Regulation

Date

July 13, 2015

Matter Number

V150009

FTC staff submitted a comment, in response to a request by North Carolina State Representative Marilyn W. Avila, regarding the possible competitive effects of a legislative proposal to exempt...

Text of the FTC Staff Comment (119.6 KB)

Text of the Concurring Comment of Commissioner Wright (59.64 KB)

Advocacy Filings

FTC Staff Comment to New York State Senator Ranzenhofer and New York State Assemblyman Abinanti Concerning SB 2647 and AB 2888 Authorizing Certain Agreements for the Creation and Operation of a Health Care Delivery System Network

Date

June 5, 2015

Matter Number

V150005

FTC staff submitted a comment to New York Senator Michael H. Ranzenhofer and New York Assemblyman Thomas Abinanti regarding the possible effects of a legislative proposal that would authorize Erie...

FTC Staff Comment to New York State Senator Ranzenhofer and New York State Assemblyman Abinanti Concerning SB 2647 and AB 2888 Authorizing Certain Agreements for the Creation and Operation of a Health Care Delivery System Network (104.03 KB)

Advocacy Filings

FTC Staff Comment Regarding Oregon Senate Bill 231A, Which Includes Language Intended To Provide �鶹��ý Antitrust Immunity To Conversations, Information Exchanges, and Agreements Among Participants (Including Competitors) In Oregon's Health Care Markets

Date

May 19, 2015

Matter Number

V150007

FTC staff submitted a comment, in response to a request by Oregon State Senator Chip Shields, expressing concern that a broad antitrust exemption proposed in Oregon Senate Bill 231A for health care...

FTC Staff Comment Regarding Oregon Senate Bill 231A, Which Includes Language Intended To Provide �鶹��ý Antitrust Immunity To Conversations, Information Exchanges, and Agreements Among Participants (Including Competitors) In Oregon's Health Care Markets (141.84 KB)

Advocacy Filings

FTC Staff Comment To Representative Jeanne Kirkton, Missouri House of Representatives, Regarding the Competitive Impact of Missouri House Bill 633 On Collaborative Practice Arrangements Between Physicians and Advance Practice Registered Nurses

Date

April 21, 2015

Matter Number

V150002

FTC staff submitted a comment, in response to a request from Missouri State Representative Jeanne Kirkton, regarding legislation that would amend Missouri’s Nurse Practice Act to remove some, and...

FTC Staff Comment To Representative Jeanne Kirkton, Missouri House of Representatives, Regarding the Competitive Impact of Missouri House Bill 633 On Collaborative Practice Arrangements Between Physicians and Advance Practice Registered Nurses (130.14 KB)

Advocacy Filings

FTC Staff Comment Before the Office of the National Coordinator For Health Information Technology, Regarding Its Draft Shared Nationwide Interoperability Roadmap For Health Information Technology Systems

Date

April 8, 2015

Matter Number

V150003

FTC staff submitted a comment to ONC, in response to ONC’s request for comments on its draft Shared Nationwide Interoperability Roadmap. The comment offered guidance on promoting competition (as well...

FTC Staff Comment Before the Office of the National Coordinator For Health Information Technology, Regarding Its Draft Shared Nationwide Interoperability Roadmap For Health Information Technology Systems (190.54 KB)

Advocacy Filings

FTC Staff Comment Before the ERISA Advisory Council of the U.S. Department of Labor Regarding Pharmacy Benefit Manager Compensation and Fee Disclosure

Date

August 19, 2014

Matter Number

V140011

Staff submitted a comment containing information that may be useful to the Advisory Council on Employee Welfare and Pension Benefit Plans, regarding issues relating to PBM compensation and fee...

FTC Staff Comment Before the ERISA Advisory Council of the U.S. Department of Labor Regarding Pharmacy Benefit Manager Compensation and Fee Disclosure (1.2 MB)

�鶹��ý Trade Commission Statement Concerning Reliance on Prior PBM-Related Adv…

Advocacy Filings

FTC Staff Comment Before the Missouri House of Representatives Regarding Missouri House Bills 1481 and 1491

Date

May 5, 2014

Matter Number

V140009

Staff submitted a comment, in response to a request by Representative Jeanne Kirkton of the Missouri House of Representatives, regarding Missouri House Bills 1481 and 1491. HB 1491 would allow APRNs...

Text of the Staff Comment (61.89 KB)

Advocacy Filings

FTC Staff Comment To Centers For Medicare and Medicaid Services Regarding "CY2015 Policy and Technical Changes to the Medicare Advantage and Prescription Drug Benefit Programs"

Date

March 11, 2014

Matter Number

V140006

Staff submitted a comment to CMS, in response to a request for public comments, regarding proposed changes in contracting for Medicare Part D. The comment recommended that CMS reconsider a proposal to...

�鶹��ý Trade Commission Staff Comment To the Centers For Medicare and Medicaid Services Regarding the Proposed Rule Entitled "Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs" (1.18 MB)

�鶹��ý Trade Commission Statement Concerning Reliance on Prior PBM-Related Adv…

FTC Votes to Issue Statement Withdrawing Prior Pharmacy Benefit Manager Advocacy

Advocacy Filings

FTC Staff Comment Before the Massachusetts House of Representatives Regarding House Bill 2009 (H.2009) Concerning Supervisory Requirements for Nurse Practitioners and Nurse Anesthetists

Date

January 23, 2014

Matter Number

V140002

Staff submitted a comment, in response to a request by Massachusetts State Representative Kay Khan, regarding a bill that would eliminate certain supervision requirements for nurse practitioners and...

FTC Staff Comment Before the Massachusetts House of Representatives Regarding House Bill 2009 (H.2009) Concerning Supervisory Requirements for Nurse Practitioners and Nurse Anesthetists (3.18 MB)