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Saturday, June 14, 2003 ::: Antitrust News: Black Friday, Part II The Senate confirmed R. Hewitt Pate as the new assistant attorney general for antitrust yesterday by a 77-0 vote. Pate had been the acting head of the Antitrust Division, and there was unfortunately never any serious scrutiny by the Senate of Pate's nomination. The Department of Justice today reached a settlement with the National Council on Problem Gambling, Inc. (NCPG) that will free NCPG state affiliates to sell problem gambling products or services outside of their home states.Nothing in the Sherman Act requires a private association to "enhance economic efficiency." That's simply a DOJ policy mandate which permits government lawyers to second-guess private business decisions. NCPG enjoyed no cartel or political power�i.e. the power to use force�to compel acceptance of its policies. Like all associations, members are presumed to act together for their mutual self-benefit. If any state affiliate felt their interests weren't being served, they presumably were free to leave. Likewise, the association was free not to associate with individuals not amenable to their policies. Frankly, I'm getting tired of repeating these arguments, but I'll continue to do so until the government gets it right. Unfortunately the members of the U.S. Senate are under the illusion that capitalism can't exist without antitrust. It makes you wonder how the Founding Fathers drove the English tyrants out. After all, America's revolutionary leaders didn't enjoy the enlightened wisdom of antitrust lawyers to guide them. ::: posted by Skip Oliva
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Friday the 13th proved an unlucky today for opponents of antitrust: A federal judge approved a settlement agreement Friday in a music antitrust lawsuit that will result in more than 3.5 million consumers receiving nearly $13 each.With all the recent antitrust settlement money going towards schools, one wonders if antitrust isn't simply some elaborate scheme cooked up by the teacher unions. Second, the vitamin wars took a nasty turn, as a jury in Washington yesterday awarded $147 million in damages against a number of producers of B-4: The 11-member jury ruled in favor of plaintiffs who accused Mitsui and a subsidiary, along with two smaller companies, of taking part in a broad cartel that inflated the price of vitamin B-4 between 1988 and 1998, a spokeswoman for the presiding judge said.Now, while I'm obviously sympathetic to Mitsui on the merits, arguing this shouldn't have gone before the jury is a cop-out. True, many civil juries act irrationally, but arguing that the case was too "complex" for them is patronizing. Antitrust laws aren't complex, just recklessly and unconstitutionally vague. A rational juror would have seen that and vindicated Mitsui appropriately. That the jury chose to award the plaintiffs damages they were not legally or morally entitled to is simply a reflection of our corrupt legal culture, not the intellectual capacity of the jurors. Finally, the U.S. Court of Appeals for the Sixth Circuit yesterday affirmed a summary judgment in an antitrust proceeding against various drug manufacturers over a non-compete agreement between the two companies. District Judge Louis Oberdorfer, sitting by designation and writing for the Sixth Circuit, states the case as follows: This antitrust case arises out of an agreement entered into by the defendants, Hoescht Marion Roussel, Inc., the manufacturer of the prescription drug Cardizem CD, and Andrx Pharmaceuticals, Inc., then a potential manufacturer of a generic version of that drug. The agreement provided, in essence, that Andrx, in exchange for quarterly payments of $10 million, would refrain from marketing its generic version of Cardizem CD even after it had received FDA approval. The plaintiffs are direct and indirect purchasers of Cardizem CD who filed complaints challenging the Agreement as a violation of federal and state antitrust laws. After denying the defendants' motions to dismiss, and granting the plaintiffs' motions for partial summary judgment, the district court certified [the following question] for interlocutory appeal:It's a testament to just how little the judicial culture cares about individual rights today that a company could be found in violation of the law without a full trial on the merits. I understand why summary judgment is used in some circumstances, but here the company was entitled to at least present a defense at trial. But such is the power of the antitrust laws, where judges and lawyers are permitted to second-guess business decisions without the niceties of due process. Granted, due process would have mattered little in the end, despite the fact Andrx had every right to enter into a voluntary agreement with a competitor. If you read the caption of the Sixth Circuit opinion, you'll see numerous state attorneys general and interests groups as plaintiffs or supporting amici. Like most antitrust cases, Andrx was taregeted for purely political reasons�people wanted the drugs Andrx and HMR rightfully owned, and thus any action to deny the people their entitlement must be an antitrust violation. ::: posted by Skip Oliva
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Friday, June 13, 2003 ::: The Courts: Pragmatism Run Amok Yale law professor Jack Balkin has endorsed Seventh Circuit Judge Richard Posner as a possible successor to Chief Justice William Rehnquist (who, as of this moment at least, isn't retiring). Balkin makes a superficially compelling case: For those of you who are unfamiliar with contemporary legal scholarship, Posner, who joined the 7th circuit in the early 1980's, is one of the most important legal scholars of his generation, and has written an endless supply of articles and books on virtually every legal subject imaginable, all the while continuing to produce a steady stream of extremely well written appellate opinions, which have made him perhaps the most influential lower court judge living today. He is a man of supreme intelligence, boundless energy and enormous learning. It is impossible for me to list the number of contributions he has made to legal scholarship. The quality of his accomplishments is such that he would grace the Court, and not the other way around. It would be fitting too, for him to be able to finally take a seat on the same court as his acknowledged idol and role model, Oliver Wendell Holmes, Jr. I don't dispute any of this. Posner is indeed a formidable mind and extremely influential, both with other judges and the overall community. But there's one big problem: Posner's intellectualism is a mere cover for his anti-individual rights ideology. At his core, Posner believes the principal mission of government is not to protect individual rights, but to balance the whims and desires of competing interest groups. He is a pragmatist in the purest (and least flattering) sense of the term. It's not that many of his rulings aren't good, it's just that he often employs an unsound intellectual approach to reach his result. Of course, I could make the same criticism about dozens, if not hundreds, of federal judges. And therein lies much of the problem with the debate over who to put on the Supreme Court. Seven of the current nine justices are themselves former court of appeals judges like Posner. Intermediate appellate judges are not always the greatest legal minds, and that makes them more susceptible to the hard-core pragmatism of a Richard Posner. Look at the last four Supreme Court justices appointed: David Souter, Clarence Thomas, Stephen Breyer, and Ruth Bader Ginsburg. Three of these justices form the core of the Court's current pragmatist elite, while the fourth, Clarence Thomas, was appointed principally because of his race, and although he's emerged as a fine justice overall, he places some scary limits on the protection of individual rights, such as last Term's case where Thomas opined an opinion essentially permitting unlimited drug testing of students in government schools. All four, of course, were also intermediate appellate judges before being promoted. One of the criticisms I've had of the makeup of agencies like the Federal Trade Commission is that the membership is monopolized by a self-appointed elite from within the legal community. A similar criticism may be justified of the Supreme Court. Appellate judges are not inclined towards issuing principle-based decisions; instead, they seek pragmatic remedies limited to isolated facts of the case. What's needed to lead the Court in the post-Rehnquist age is not some cloistered academic or pragmatist appellate judge, but an individual with both solid legal experience and an understanding of how principles operate in the real world, by which I mean the economic marketplace. Especially given the law's increasing hostility towards individual rights in the economic sphere, the next chief justice in particular must possess a solid working knowledge of the business world and how it needs to interact with the law. Several months ago, I half-jokingly suggested the next chief justice should be Paul Tagliabue, the commissioner of the National Football League. Before being elected to his present post in 1989, Tagliabue was the NFL's chief counsel on antitrust and other matters. He was among the chief lawyers who defended the league from a number of unfounded antitrust actions in the 1980s. Now, I have no idea if Tagliabue would want the job, or even if his judicial ideology is fully compatible with an individual rights theory of government. What I am suggesting, however, is that the White House needs to think outside the box for its next Supreme Court appoinment, and consider the ideological consequences beyond mere short-term political strategy. Nominating someone like Tagliabue�a lawyer who became a successful CEO in a hostile legal climate�would serve as a major shock to the self-appointed appellate elite who believe only they are capable of telling the rest of us what the law should be. Another reason to back Chief Justice Tagliabue: The Supreme Court in recent years has become more fractured and divided, at times unable to produce a unified opinion in key cases. Given Tagliabue's track record getting 32 NFL owners to work together�no small feat, given they're all wealthy individuals with competing agendas�I would think getting eight Supreme Court colleagues to work together better would be a walk in the park. ::: posted by Skip Oliva
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Antitrust News: The Credit Wars Continue The downside of settling a major antitrust lawsuit without going to trial? Others will quickly follow (and file) suit: Best Buy Co. is suing Visa and Mastercard for allegedly violating antitrust and unfair business practices laws regarding plastic card payments.The Visa-Master Card cases is a textbook example of the flaw in antitrust thinking. Prior to the rise of Visa and Master Card, there was no such thing as nationally-accepted credit cards. Credit itself was originally a concept where individual store owners would allow customers to purchase goods now and pay later. Department stores became the initial issuer of plastic credit cards in the mid-20th century. Visa and Master Card came along later as an alliance of banks that formed a national network to process credit orders. Individual banks issue the cards, while Visa and Master Card maintain the infrastructure necessary to ensure compatibility from merchant-to-merchant. Without Visa and Master Card�and their allegedly "monopolistic" fee practices�many of today's large retailers would not exist. Imagine running Wal-Mart, a lead plaintiff in the class-action settlement, without any bank-financed credit cards. The stores may complain about high credit-processing fees, but the price they would pay without Visa and Master Card are far higher, both in terms of sales and administration. The problem however, as it always seems to be in antitrust, is that success breeds a sense of entitlement among the consumer base. Because Visa and Master Card have created incredibly effective networks, the retailers now seem to view credit card processing as a form of public utility�something that they're entitled to use regardless of ability or desire to pay. The Justice Department, in continuing their own antitrust case against Visa and Master Card, wholeheartedly subscribe to this theory as well. The potential fear, then, is that government regulators will seek to increase their direct control over credit card processing to the point where it does become a quasi-public utility, a la the telephone companies. I'm not sure Visa and Master Card have quite figured that out yet. They appear to be writing off these antitrust suits as a cost of doing business, a common attitude among large corporations. But at some point they may come to understand their survival is at stake. Hopefully that realization won't come too late. ::: posted by Skip Oliva
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Thursday, June 12, 2003 ::: Rights & Reason: Getting it Right Mike Walters, writing in the Texas A&M University student newspaper, demolishes the moral foundation of the Telecommunications Act of 1996, the law which forces the local Bell companies to lease their infrastructure to competitors: The Telecommunications Act of 1996 is a more subtle type of antitrust law, which claims to promote competition and eliminate the possibility of an emerging monopoly through government intervention. A common misconception is that the government has to protect its citizens from big business through the prevention of monopolies. This is completely unnecessary in a capitalist economy. Any company that manages to drive away competition cannot set prices as high as it likes. Were a company foolish enough to raise prices excessively, a free society allows for the emergence of new competition that is encouraged to charge a fair price, meeting immediate success by providing a cheaper alternative to the abusive monopoly.Greenspan, of course, wrote those words more than 30 years ago, and he's long since exchanged genuine free market principles for the power of the Federal Reserve Board. In any case, Walters gets it exactly right. He not only identifies the practical failures of antitrust, but its moral ones as well: America boasts the fact that it is a country in which its citizens are free to work hard to achieve their goals, dreams and happiness. Is there some sort of "fine print" on the Declaration of Independence that says the pursuit of liberty and happiness exists for everybody but a successful businesses? Instead, it says only a few lines afterward "That whenever any Form of Government becomes destructive of these ends, it is the Right of the People to alter or to abolish it."The most difficult aspect of education people about the antitrust laws is getting them to understand that the core supporters of antitrust�regulators, lawyers, academics, et al.�are not simply misguided individuals, but proponents of an evil, anti-human philosophy that will ultimately reinstitute feudal serfdom in this country. Nice to see some folks, like Mr. Walters, are still able to recognize their enemies for what they are. ::: posted by Skip Oliva
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Rights & Reason: Persecuting Martha Corey Smith, a lawyer at the Justice Department's tax division, penned a remarkable letter to the Washington Times, which appears in today's edition. In his letter, Smith, apparently acting on his own accord, manages to confirm several suspicious many of us have had about the Martha Stewart case. This was not his intent, as his letter clearly is meant to rally support for the prosecution and challenge its critics. After weathering the 1998 Clinton-Lewinsky debacle, where it was proven beyond any doubt that our country's chief law enforcement official, President Clinton, lied repeatedly under oath, I do not think we should tolerate lying and obstruction of justice by those in the public eye. What better way to mend the wounds of 1998 by instituting a zero tolerance policy for obstruction of justice by public figures?There are two implications of this statement. First, Smith essentially refutes his own colleague�the U.S. attorney prosecuting Stewart�who said this wasn't about who Stewart was, but what she did. Smith, in contrast, says Martha was rightly targeted for special treatment, i.e. "zero tolerance", because she is a public figure. The second implication is that the DOJ may be targeting Martha because she's a Democrat, and Republican DOJ officials may be extracting a measure of revenge aganist a high-profile Democratic Party donor like Stewart. Granted, I'm inferring quite a bit, but Smith opened the door. Smith also makes an interesting admission. He says: "[i]nsider trading is a complicated area of criminal law, and it is not always clear who can be charged with it." That's a heck of a thing to say if you represent the Justice Department, which is trying to enforce this law. Smith's concluding paragraph, however, makes it clear that he thinks non-objectivity is no barrier to successful law enforcement: Our system of justice is largely a voluntary one. Investigators and prosecutors depend on witness compunction, or fear, to tell the truth, especially under oath. The resources do not exist to punish everyone who intentionally misleads every criminal investigator. If a healthy respect for the truth does not permeate our society, the administration of justice becomes impossible. Setting an example through the use of a public persona such as Martha Stewart is a good idea. Her prevarications should be punished, no matter how innocuous the underlying crime.Once agani, Smith all but says Martha Stewart was targeted for political reasons. "Setting an example" is what political tyrants do to their opponents; it is not the official policy of a government charged with protecting individual rights. Obviously the DOJ has limited resources and sometimes must prioritize certain investigations and cases. But then why is Martha Stewart such a priority? If her underlying offense was "innocous," and there's no direct evidence her actions violated the individual rights of others, then why spend the money to try this case, especially given the fact Stewart is willing to fight the DOJ all the way? Oh, right. This isn't about Martha Stewart. It's about the nation atoning for Bill Clinton. I guess putting Martha Stewart in jail will heal the nation's political wounds. ::: posted by Skip Oliva
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The Culture: Conceding Premises Richard Rahn of Cato is a fine columnist, but he slipped up in an otherwise fine op-ed this morning on European efforts to eliminate "tax competition": Most people understand that when businessmen get together to limit competition, the public interest is rarely served, and the same is true of government bureaucrats. EU officials convinced their bureaucratic lackeys at the Organization for Economic Cooperation and Development (OECD) to develop the concept of "harmful tax competition" to justify trying to force all of the world's countries to jack up their tax rates to French-like levels.Um, Richard, there is a difference. Private businessmen, in general, cannot force individuals to purchase their products and services as a matter of law. Furthermore, a business' products are its private property until a buyer voluntarily negotiates for their purchase. Governments do not negotiate�they simply confiscate. ::: posted by Skip Oliva
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Wednesday, June 11, 2003 ::: Antitrust News: Nestle Shakedown Nears Completion FTC staff attorneys have apparently reached a final agreement with Nestle over the company's acquisition of Dreyer's ice cream. I first discussed this case on March 5, just after the FTC's five commissioners voted to block the deal unless concessions were made. Those concessions now appear to include divesting several ice cream brands to CoolBrands International, a Canadian ice cream producer, and several distribution assets. ::: posted by Skip Oliva
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The House Commerce Committee is holding an FTC oversight hearing today entitled "positioning the Commission for the twenty-first century." If that's the committee's goal, perhaps we could start by requiring the FTC to abandon its 19th-century German philosophy and try considering some pro-capitalist theories for once. Then there's the option of recognizing the FTC is an unnecessary and destructive entity, and abolishing the thing altogether. ::: posted by Skip Oliva
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The Culture: Educational Monopolists Rally If the FTC is looking for something useful to do with its antitrust machinery, perhaps they could consider taking action against David Imig, president of the American Association of Colleges of Teachers of Education, who deliberately sabotaged a government program designed to break his group's stranglehold on teacher certification: The head of a national teacher-college association circulated a copy of a confidential teacher-certification exam, undermining a Bush administration initiative to certify professionals without education degrees as teachers.AACTE, you see, supports only "progressive" education methods, the same methods that have failed for more than 30 years to educate an increasingly larger number of government-school students. Imig and his colleagues oppose education based on rational methods, and the only way such nonsense can continue to be the norm is if they prevent any genuine competition from taking hold. Hence Imig's decision to sabotage the alternative-certification test. This was not a cost-free action either: Mr. Imig's use of the stolen American Board field-test, developed by ACT Inc. of Iowa City, forced the American Board to scuttle the test and sever its relationship with the ACT, which lost $1.2 million because the test was compromised.Unfortunately, ACT will not pursue legal action against Imig, nor will the other groups and agencies injured take any action. That's simply an outrage. This nation will use its full political force to persecute Martha Stewart and Microsoft, but it won't lift a finger against a group of thugs who seek to sabotage even small steps towards restoring the free market for education and saving the nation's children from the cognitive death that awaits them in government schools. ::: posted by Skip Oliva
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The Culture: Monopsonies against Monopoly There are two major unions representing actors and other media artists: the Screen Actors Guild and the American Federation of Television and Radio Artists. For years, there's been a movement to merge the two unions together, a cause which once again has picked up steam. Nothing wrong with that, certainly. If two voluntary groups decide it's in their self-interest to join forces, then we should wish them the best of luck. The Screen Actors Guild and the American Federation of Television and Radio Artists -- which are pushing to consolidate -- issued a joint statement using the FCC action as solid evidence that their unions need to merge for self-protection.SAG and AFTRA vigorously opposed the FCC's recent reregulation vote, which is interesting considering their own merger proposal. Gilbert and Connolly said the FCC was "giving media companies even more power," as if somehow the media companies didn't earn their rightful economic power in the marketplace despite arbitrary government restrictions. Keep in mind, as labor unions, SAG and AFTRA can essentially compel the studios to collectively bargain with them, a function of law giving labor unions special political power not available to the general public. SAG and AFTRA can also, pursuant to collective bargaining, force their contract terms on non-union members who seek to work as actors and artists. And frankly, given that there are many wealthy members of SAG and AFTRA, you'd think that if they were that concerned about the media companies' power, some of them would get together and buy their own movie studio or television network. ::: posted by Skip Oliva
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Antitrust News: Half-Measures, continued Picking up from Nick's post below, the thing that struck me about yesterday's D.C. Council hearing on physician antitrust is how little the main players�the local medical society and the councilmembers present�actually knew about the impact of antitrust on the medical profession. Since the council first considered a limited antitrust exemption for doctors four years ago, the FTC and Justice Department have become far more aggressive in pursuing physicians. One reason for this, I suspect, is that healthcare costs have been rising faster in the past few years, a point alluded to by a managed-care group lobbyist at yesterday's hearing. This increases the pressure on government officials, unwilling to admit the fundamental flaw of government-run healthcare, to find scapegoats, and the FTC in particular has carved out a fine niche for itself bullying doctor groups and, in effect, stealing their lunch money. ::: posted by Skip Oliva
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Tuesday, June 10, 2003 ::: Antitrust News: Take No Half-Measures Protecting Doctors from Antitrust Today I provided oral testimony to the District of Columbia Council Committee on Consumer and Regulatory Affairs on The Physicians Joint Negotiating Act of 2003. As I indicated in my testimony, the bill before the Council [i]s an implicit confession that the current regime has failed. Yet rather than address the source of that failure�which is a cornucopia of price control schemes over health care�this bill, in key areas, simply repackages that failure and tries to sell it as an improvement. Rather than acknowledge and protect the freedom of doctors to negotiate their own price terms, this bill subjects them to yet another set of complex and onerous regulations. To subject the exercise of a doctor�s legitimate rights to regulatory approval effectively denies these rights. Specifically, the bill denies doctors the unrestricted right to collectively negotiate price and compensation terms with health plans. Only if the health plan possesses a certain market share�a figure that has a history of being arbitrarily manipulated by hostile regulators�are doctors permitted to enjoy even limited rights to control their economic destiny.I argued that the Council ought to pass a modified version of the current bill that eliminates the distinction between collectively negotiating the terms of patient care�which the current bill exempts fully�and negotiating price and compensation terms. A doctor�s right to negotiate price and compensation terms should not be assigned to a regulatory ghetto, but should instead be affirmed proudly as the cornerstone of the doctor-patient relationship. I spoke after representatives of the Medical Society of the District of Columbia and a team of lobbyists for the health insurance industry. Unfortunately the one member of the Council who was most enthusiastic to use antitrust to limit doctor's economic rights (typically enough, a Republican) left early on other business, I was not able to refute his position directly to his face. His view was that since the District has a mandate to provide the poor with medical services and had a finite budget to do this, anything that raises prices is reflexively bad. Other members of the Council seemed to understand that artificial barriers on price would reduce the supply of doctors, but were reluctant to constantly integrate this fact with a position that would fully protect doctor�s rights. The Council was interested in CAC's analyses of FTC antitrust enforcement efforts and we will endeavor to provide it with further analyses. We'll also seek private meetings with council members to brief them more fully on our position. The most important achievement of the day was we made friends with the DC Medical Society. While from their perspective, even limited reform is a step in the right direction, they appreciated that our position fully protects doctors. We intend to educate them on our efforts against the FTC�s reign of terror against doctors and we are looking forward to working with them mounting a defense. All in all, a good day. I know Skip will want to weigh in on this further, so I yield the floor to my honorable colleague. ::: posted by Nicholas Provenzo
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Monday, June 09, 2003 ::: First, we have news of Oracle raising antitrust concerns: The chief executive of J.D. Edwards on Monday said Oracle's hostile bid for his company's intended acquirer PeopleSoft would ``drive out'' competition from a key area of business software and raise ``serious anti-trust issues.''Oracle, of course, was a major instigator of the Microsoft antitrust case. Turnabout may not be fair play here�antitrust is wrong, regardless of circumstance�but there is a powerful lesson here. When you use antitrust against a rival, the day will likely come when someone will use antitrust against you. It's a vicious cycle with no long-term winners, at least in a free-market context. Second, we have the latest in the long-running vitamin antitrust wars: Organizations in Tennessee will split $5.6 million as part of a national settlement with vitamin manufacturers who allegedly engaged in price-fixing.Funny how the money from these large antitrust settlements never go to the actual victims. Perhaps that's because there were no actual victims. After all, the vitamin companies never forced anyone to pay a particular price for their products. Finally, some good news�the government actually admitted they were wrong for once: Antitrust enforcers Monday recommended that the government abolish key regulations on airline computer reservations systems (CRS), saying they have failed to foster competition in the industry.Yup, government price controls never benefit consumers. Hardly a shocking discovery. Of course, the antitrust regulators continue to believe price controls will work on other areas of the economy, such as physician services. ::: posted by Skip Oliva
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This from the AP: "The language of threats and force won't work against Iran. It will only backfire," [Iranian foreign Ministry spokesman Hamid Reza Asefi] told a press conference.True. Iran is the worlds most notorious sponsor of terrorism. Threats will not mollify its mullahs. Here's to hoping for the 2nd Iranian revolution. ::: posted by Nicholas Provenzo
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Rights & Reason: There They Go Again I'm beginning to feel like we're in "Groundhog Day." The FTC announced its latest violation of the Constitution this morning: A nonprofit corporation representing approximately 1,000 participating physicians in the Dallas/Fort Worth, Texas metropolitan area has agreed to settle Federal Trade Commission charges that collective bargaining on behalf of its members has led to decreased competition and increased prices for the provision of medical services to the area's consumers. Under the terms of the proposed consent order reached with the Commission and announced today, Southwest Physician Associates (SPA) will be barred from jointly negotiating fees and other competitively significant terms on behalf of its physicians, unless certain conditions are met.There comes a point when you have recognize that the FTC is not simply a group of people who hold different opinions from your own, but committed enemies of freedom. Indeed, I'm beginning to think we're dealing with sociopaths�people who enjoy exercising power over others for the sheer enjoyment of it. No rational person can support the FTC's actions in these cases, certainly no person who claims to live under the principles of the Declaration of Independence and a government under the Constitution of the United States. Perhaps it's time the nation's physicians take a lesson from Martha Stewart. When the government falsely charges you with committing a crime, the answer is not to surrender and cower in fear, but to hold your head high and publicly proclaim your innocence. Heck, after she's acquitted, maybe Martha would consider joining CAC as an advisor on how to stand up to prosecutorial tyranny. We'd love to have her. ::: posted by Skip Oliva
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Sunday, June 08, 2003 ::: Rights & Reason: Bush Conflicted on Health Care? President Bush's plan to force taxpayers to provide prescription drugs for the elderly has an interesting feature. In exchange for adding a prescription drug entitlement to Medicare, the White House plan would encourage seniors to get out of Medicare altogether and join a preferred-provider organization. PPOs are networks of doctors and health care providers that contract with insurance plans to provide care at a discounted rate. ::: posted by Skip Oliva
at 8:18 PM | link
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