2025 Advocacy Activities

DOJ Comment Letter

PAI submitted detailed comments to the Department of Justice’s recently announced Anticompetitive Task Force to highlight how health care consolidation is leading to the rapid closure of independent physician practices, undermining physician autonomy, restricting patient choice, and increasing spending. PAI strongly urged the Task Force to take action to support independent physician practices and facilitate competition in the health care marketplace, including by:

• Working with Congress and HHS to address physician payment cuts and enact inflation-based updates to the Medicare Physician Fee Schedule,
• Building on recent regulations to more comprehensively address the administrative burden and patient care disruption caused by prior authorizations,
• Refocusing health information technology regulations on EHR manufacturers while enabling physicians to purchase EHR products and updates that are valuable for their practice, and
• Increasing federal oversight and enforcement of health care mergers and acquisitions, especially of physician practices, that undermine physician practices’ ability to compete in the market.

OMB Comment Letter

PAI also submitted comments on a Request for Information from the Office of Management and Budget (OMB) on opportunities for deregulation. PAI called for review of federal regulations that hamper physician leadership and high-value patient care, including recommendations to:

• Modernize the Antikickback Statute and the Physician Self-Referral (Stark) Law, which are overly complex and burdensome and fail to reflect the increasingly consolidated and corporatized nature of the health care market, and
• Lift the anticompetitive, unfair moratorium on physician-owned hospitals, citing PAI’s research which found that physician-owned hospitals provide high-quality, low-cost care.