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Experts tell committee HHI and claims analysis should be paired to assess consolidation effects
Summary
Panelists recommended the committee pair concentration metrics (e.g., HHI and market‑share thresholds) with claims‑based outcome analysis (difference‑in‑differences) to measure how consolidation affects prices, quality and access, while tailoring definitions by service and geography.
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When asked how to measure the impact of consolidation, panelists recommended two linked approaches: an ownership/concentration measure and a rigorous outcome analysis.
Hunter Plumer said HHI and market‑share share cutoffs are useful to quantify concentration, but cautioned that impact analysis needs a counterfactual. He recommended difference‑in‑differences designs using claims data to compare markets that experienced consolidation with appropriate control markets.
Jason Hotchkiss (attending for Jonathan Bennett) urged careful market definitions and regionally differentiated analysis. Committee members and panelists also urged excluding some provider types (FQHCs, psych specialty hospitals) from standard market measures and splitting rural/urban analyses because drivers and outcomes differ.
Speakers noted tradeoffs: broader disclosure and registry data would improve measurement but require investment; too low a filing threshold for transaction review could create administrative burdens. Several members suggested transaction‑filing fees and narrow statutory thresholds to target review resources.

