United States, et al. v. OhioHealth Corporation; Amended Response to Public Comments on the Proposed Final Judgment

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<title>Federal Register, Volume 91 Issue 213 (Thursday, November 5, 2026)</title>
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[Federal Register Volume 91, Number 213 (Thursday, November 5, 2026)]
[Notices]
[Pages 69865-69884]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-22618]


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DEPARTMENT OF JUSTICE

Antitrust Division


United States, et al. v. OhioHealth Corporation; Amended Response 
to Public Comments on the Proposed Final Judgment

    Notice is hereby given pursuant to the Antitrust Procedures and 
Penalties Act, 15 U.S.C. 16(b)-(h), that the Amended Response of 
Plaintiff United States to Public Comments on the Proposed Final 
Judgment has been filed with the United States District Court for the 
Southern District of Ohio, Eastern Division in United States of 
America, et al. v. OhioHealth Corporation, Civil Action No. 2:26-cv-
207.
    Copies of the Public Comments and the United States' Amended 
Response are available for inspection on the Antitrust Division's 
website at <a href="http://www.justice.gov/atr">http://www.justice.gov/atr</a> and at the Office of the Clerk of 
the United States District Court for the Southern District of Ohio. 
Copies of these materials may be obtained from the Antitrust Division 
upon request and payment of the copying fee set by Department of 
Justice regulations.

Suzanne Morris,
Deputy Director of Civil Enforcement Operations, Antitrust Division.

United States District Court for the Southern District of Ohio Eastern 
Division

    UNITED STATES OF AMERICA and STATE OF OHIO, Plaintiffs, v. 
OHIOHEALTH CORPORATION, Defendant.
Case No. 2:26-cv-207
Judge Algenon L. Marbley
Magistrate Judge S. Courter M. Shimeall

Amended Response of Plaintiff United States to Public Comments on the 
Proposed Final Judgment

    Pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C. 
16(b)-(h) (the ``Tunney Act'' or ``APPA''), the United States submits 
this amended response to the public comments it received regarding the 
proposed Final Judgment in this case. The United States received four 
comments about the proposed remedy, which are summarized and addressed 
below and attached as Exhibit A. This is an amended response to the 
United States' Response to Public Comments on the Proposed Final 
Judgment (``Response to Comments''), filed on October 20, 2026. (Dkt. 
34). The United States has amended its response to address a comment 
that had been inadvertently omitted from its initial response. Other 
than this paragraph, references to the number of comments received, and 
the addition of the comment to Exhibit A, the only changes from the 
initial Response to Comments are on pages 12-13. After careful 
consideration of the submitted comments, the United States continues to 
believe that the proposed Final Judgment is in the public interest 
because it will provide an effective and appropriate remedy for the 
antitrust violations the Complaint alleged.
    Specifically, the proposed Final Judgment will protect competition 
by, among other things, voiding the anticompetitive steering and 
transparency restrictions, prohibiting OhioHealth Corporation 
(``OhioHealth'') from seeking or obtaining such provisions in the 
future, and prohibiting OhioHealth from penalizing payors that engage 
(or are planning to engage) in steering, offer steered plans, or 
provide price transparency to their members.
    After this response has been published in the Federal Register, 
pursuant to 15 U.S.C. 16(d), the United States will move that the Court 
enter the proposed Final Judgment.

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I. Procedural History

    On February 20, 2026, the United States, along with the State of 
Ohio, filed a civil antitrust Complaint (Dkt. 1) seeking to enjoin 
OhioHealth's alleged anticompetitive steering and transparency 
restrictions. The Complaint alleges that OhioHealth engaged in 
anticompetitive contracting that reduced choice for consumers and 
prevented price competition for healthcare services in the Columbus 
area in violation of Section 1 of the Sherman Act, 15 U.S.C. 1.
    On June 16, 2026, Plaintiffs filed the proposed Final Judgment, as 
well as a stipulation signed by all parties consenting to entry of the 
proposed Final Judgment after compliance with the requirements of the 
Tunney Act. (Dkt. 29-1, 29-2). On July 15, 2026, the United States 
filed a Competitive Impact Statement describing the proposed Final 
Judgment. (Dkt. 33).
    The United States arranged for the publication of the Complaint, 
the proposed Final Judgment, and the Competitive Impact Statement in 
the Federal Register on July 23, 2026 (see 91 FR 46463 (2026)), and 
caused notice regarding the same, together with directions for the 
submission of written comments relating to the proposed Final Judgment, 
to be published in the Washington Post and The Columbus Dispatch from 
July 27, 2026, through August 3, 2026. The four public comments 
received in response are described below and attached as Exhibit A. The 
60-day period for public comment has now ended.

II. Standard of Judicial Review

    Under the Tunney Act, proposed Final Judgments, or ``consent 
judgments,'' in antitrust cases brought by the United States are 
subject to a 60-day comment period, after which the Court shall 
determine whether entry of the proposed Final Judgment ``is in the 
public interest.'' 15 U.S.C. 16(e)(1). In making that determination, 
the Tunney Act, as amended in 2004, directs the Court to consider the 
following factors:
    (a) the competitive impact of such judgment, including termination 
of alleged violations, provisions for enforcement and modification, 
duration of relief sought, anticipated effects of alternative remedies 
actually considered, whether its terms are ambiguous, and any other 
competitive considerations bearing upon the adequacy of such judgment 
that the court deems necessary to a determination of whether the 
consent judgment is in the public interest; and
    (b) the impact of entry of such judgment upon competition in the 
relevant market or markets, upon the public generally and individuals 
alleging specific injury from the violations set forth in the complaint 
including consideration of the public benefit, if any, to be derived 
from a determination of the issues at trial.
15 U.S.C. 16(e)(1)(A) & (B).
    In considering these statutory factors, the Court's inquiry is 
necessarily a limited one, as the government is entitled to ``broad 
discretion to settle with the defendant within the reaches of the 
public interest.'' United States v. Microsoft Corp., 56 F.3d 1448, 1461 
(D.C. Cir. 1995); United States v. Hewlett Packard Enter. Co., No. 25-
CV-00951-PCP, 2026 WL 2349970, at *16 (N.D. Cal. Aug. 12, 2026); United 
States v. U.S. Airways Grp., Inc., 38 F. Supp. 3d 69, 75 (D.D.C. 2014) 
(explaining that the ``court's inquiry is limited'' in Tunney Act 
settlements); United States v. InBev N.V./S.A., No. 08-1965 (JR), 2009 
U.S. Dist. LEXIS 84787, at *3 (D.D.C. Aug. 11, 2009) (noting that a 
court's review of a proposed final judgment is limited and only 
inquires ``into whether the government's determination that the 
proposed remedies will cure the antitrust violations alleged in the 
complaint [is] reasonable, and whether the mechanisms to enforce the 
final judgment are clear and manageable''); United States v. Charleston 
Area Med. Ctr., Inc., No. 2:16-3664, 2016 U.S. Dist. LEXIS 145963 at *5 
(S.D.W.V. Oct. 21, 2016) (``In evaluating whether the proposed final 
judgment is in the public interest, the inquiry is `a narrow one.' '' 
(quoting Massachusetts v. Microsoft Corp., 372 F.3d 1199, 1236 (D.C. 
Cir. 2004))).
    Under the Tunney Act, a court considers, among other things, the 
relationship between the remedy secured and the specific allegations in 
the government's complaint, whether the proposed final judgment is 
sufficiently clear, whether its enforcement mechanisms are sufficient, 
and whether it may positively harm third parties. See Microsoft, 56 
F.3d at 1458-62. With respect to the adequacy of the relief secured by 
the proposed Final Judgment, a court may not ``make de novo 
determination of facts and issues.'' United States v. W. Elec. Co., 993 
F.2d 1572, 1577 (D.C. Cir. 1993) (quotation marks omitted); see also 
Microsoft, 56 F.3d at 1460-62; United States v. Alcoa, Inc., 152 F. 
Supp. 2d 37, 40 (D.D.C. 2001); United States v. Enova Corp., 107 F. 
Supp. 2d 10, 16 (D.D.C. 2000); InBev, 2009 U.S. Dist. LEXIS 84787, at 
*3. Instead, ``[t]he balancing of competing social and political 
interests affected by a proposed antitrust [judgment] must be left, in 
the first instance, to the discretion of the Attorney General.'' W. 
Elec. Co., 993 F.2d at 1577 (quotation marks omitted). ``The court 
should also bear in mind the flexibility of the public interest 
inquiry: the court's function is not to determine whether the resulting 
array of rights and liabilities is the one that will best serve 
society, but only to confirm that the resulting settlement is within 
the reaches of the public interest.'' Microsoft, 56 F.3d at 1460 
(internal quotation marks omitted) (emphasis in original); see also 
United States v. Deutsche Telekom AG, No. 19-2232 (TJK), 2020 WL 
1873555, at *7 (D.D.C. Apr. 14, 2020). More demanding requirements 
would ``have enormous practical consequences for the government's 
ability to negotiate future settlements,'' contrary to congressional 
intent. Microsoft, 56 F.3d at 1456. ``The Tunney Act was not intended 
to create a disincentive to the use of the consent [judgment].'' Id.
    ``Because enforcement by consent decree is an alternative to 
enforcement by trial or abandonment of the litigation altogether and 
often reflects the United States's assessment of litigation risk, a 
proposed settlement does not need to replicate the full relief that 
[the] United States sought in its complaint.'' Hewlett Packard Enter., 
2026 WL 2349970, at *17. The United States' predictions about the 
efficacy of the remedy are to be afforded deference by the Court. See, 
e.g., Microsoft, 56 F.3d at 1461 (recognizing courts should give ``due 
respect to the Justice Department's . . . view of the nature of its 
case''); United States v. Republic Servs., Inc., 723 F. Supp. 2d 157, 
160 (D.D.C. 2010) (noting ``the deferential review to which the 
government's proposed remedy is accorded''); United States v. Archer-
Daniels-Midland Co., 272 F. Supp. 2d 1, 6 (D.D.C. 2003) (``A district 
court must accord due respect to the government's prediction as to the 
effect of proposed remedies, its perception of the market structure, 
and its view of the nature of the case.''). The ultimate question is 
whether ``the remedies [obtained by the Final Judgment are] so 
inconsonant with the allegations charged as to fall outside of the 
`reaches of the public interest.' '' Microsoft, 56 F.3d at 1461.
    Moreover, the Court's role under the Tunney Act is limited to 
reviewing the remedy in relationship to the violations that the United 
States has alleged in its Complaint and does not authorize the Court to 
``construct [its] own hypothetical case and then evaluate the decree 
against that case.'' Microsoft, 56 F.3d at 1459; see also U.S. Airways, 
38

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F. Supp. 3d at 75 (noting that the court must simply determine whether 
there is a factual foundation for the government's decisions such that 
its conclusions regarding the proposed settlements are reasonable); 
InBev, 2009 U.S. Dist. LEXIS 84787, at *20 (``[T]he `public interest' 
is not to be measured by comparing the violations alleged in the 
complaint against those the court believes could have, or even should 
have, been alleged.''). Because the ``court's authority to review the 
decree depends entirely on the government's exercising its 
prosecutorial discretion by bringing a case in the first place,'' it 
follows that ``the court is only authorized to review the decree 
itself,'' and not to ``effectively redraft the complaint'' to inquire 
into other matters that the United States did not pursue. Microsoft, 56 
F.3d at 1459-60; see also United States v. Alcan Aluminium, Ltd., 605 
F. Supp. 619, 622 (W.D. Ky. 1985) (approving the consent decree even 
though the court would have imposed a greater remedy).
    Further, ``[i]n evaluating objections to settlement agreements 
under the Tunney Act, a court must be mindful that [t]he government 
need not prove that the settlements will perfectly remedy the alleged 
antitrust harms[;] it need only provide a factual basis for concluding 
that the settlements are reasonably adequate remedies for the alleged 
harms.'' United States v. Iron Mountain, Inc., 217 F. Supp. 3d 146, 
152-53 (D.D.C. 2016) (second and third alterations in original) 
(internal citations omitted). The Court's authority is essentially 
binary: it may approve a proposed final judgment that falls within the 
``reaches of the public interest,'' or it may reject one that does not. 
Microsoft, 56 F.3d at 1461-62. ``Short of that eventuality, the Tunney 
Act cannot be interpreted as an authorization for a district judge to 
assume the role of Attorney General.'' Id. at 1462.\1\
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    \1\ If the Court concludes that the proposed Final Judgment is 
not in the public interest, each party must then determine its next 
steps for the litigation, which may include continuing to litigate 
the case, attempting to settle the case on different terms, or 
Plaintiffs' dismissing the case.
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    In its 2004 amendments to the Tunney Act, Congress made clear its 
intent to preserve the practical benefits of using judgments proposed 
by the United States in antitrust enforcement and added the unambiguous 
instruction that ``[n]othing in this section shall be construed to 
require the court to conduct an evidentiary hearing or to require the 
court to permit anyone to intervene.'' Public Law 108-237, 221, 118 
Stat. 668-69 (codified as amended at 15 U.S.C. 16(e)(2)). This Court 
itself has held that the 2004 amendments to the APPA ``do not enlarge 
the scope of the court's public interest review.'' United States v. 
Fed'n of Physicians & Dentists, No. 1:05-cv-431, 2008 U.S. Dist. LEXIS 
133904, at *5-6, *6 n.1 (S.D. Ohio Apr. 22, 2008) (citing United States 
v. SBC Commc'ns Inc., 489 F. Supp. 2d 1, 15 (D.D.C. 2007) (``[T]he 
Court cannot look beyond the complaint in making the public interest 
determination unless the complaint is drafted so narrowly as to make a 
mockery of judicial power.'')). As Senator Tunney explained: ``The 
court is nowhere compelled to go to trial or to engage in extended 
proceedings which might have the effect of vitiating the benefits of 
prompt and less costly settlement through the consent [judgment] 
process.'' 119 Cong. Rec. 24,598 (1973) (statement of Sen. Tunney). ``A 
court can make its public interest determination based on the 
competitive impact statement and response to public comments alone.'' 
U.S. Airways, 38 F. Supp. 3d at 76 (citing Enova Corp., 107 F. Supp. 2d 
at 17).

III. The Harm Alleged in the Complaint and the Proposed Final Judgment

    The proposed Final Judgment resolves the United States' claim that 
OhioHealth has maintained provisions in its contracts with payors that 
(1) prevent payors from steering away from OhioHealth to incentivize 
patients to use less-expensive providers than OhioHealth and (2) 
inhibit payors from informing patients that less-expensive options are 
available. As alleged in the Complaint, these restrictions deprive 
Columbus-area consumers of the choice of lower-cost health plan options 
and reduce competition among hospitals in violation of Section 1 of the 
Sherman Act, 15 U.S.C. 1 (``Sherman Act claim'').
    OhioHealth is a not-for-profit healthcare services corporation, 
with its principal place of business in Columbus, Ohio. OhioHealth owns 
or manages sixteen hospitals and outpatient facilities, physician 
groups, and other healthcare services throughout Ohio.
    As alleged in the Complaint, OhioHealth is one of the most 
significant health systems in and around central Ohio. It uses its 
market power to extract restrictive contract provisions and high prices 
from payors. Those provisions, which include restrictions on tiered 
plans, narrow networks, steering, and price transparency, effectively 
prevent payors from offering consumers and employers the opportunity to 
pay less for healthcare at less expensive hospitals and providers. The 
restrictions also inhibit competition among hospitals because they 
limit the opportunity of hospitals with lower prices to gain more 
patient volume. Because the restrictions deter OhioHealth's competitors 
from competing by reducing prices, they protect OhioHealth from 
pressure to reduce its own prices. This inhibited price competition 
raises the cost of health insurance and results in patients and 
employers paying more for essential healthcare.
    The proposed Final Judgment provides an effective and appropriate 
remedy for the competitive harms arising out of OhioHealth's alleged 
conduct. The proposed Final Judgment has several components, which 
OhioHealth agreed to abide by pending entry of the Final Judgment, as 
the Court ordered in the Stipulation and Order entered on July 2, 2026. 
(Dkt. 31).
    First, the proposed Final Judgment voids any and all language in 
OhioHealth's contracts with payors that prohibits, deters, prevents, or 
penalizes steering, steered plans, or transparency. Second, the 
proposed Final Judgment prevents OhioHealth from seeking or obtaining 
new contract provisions that would prohibit, prevent, or penalize 
steering, steered plans, or transparency. Third, the proposed Final 
Judgment prohibits OhioHealth from penalizing or retaliating against 
payors that engage (or are planning to engage) in steering, offer 
steered plans, or provide price transparency to their members. Fourth, 
the proposed Final Judgment prohibits OhioHealth from requiring that it 
be included in the most-preferred tier of any benefit plan offered by 
payors. Finally, the proposed Final Judgment provides for the Court to 
appoint a monitor who will serve for five years and will have the power 
to investigate and report on OhioHealth's compliance with the terms of 
the Final Judgment.
    Together, these requirements of the proposed Final Judgment will 
preserve competition for the sale of inpatient general acute care 
hospital services to commercial payors and their members in Ohio.

IV. Summary of Public Comments and the United States' Response

    The United States received four comments about the proposed Final 
Judgment. The comments do not question the adequacy of the proposed 
Final Judgment to remedy the detrimental effects of OhioHealth's 
restrictions on steering and transparency that are at the core of the 
Sherman Act claim. Rather, each of the four comments relates to facts 
or events

[[Page 69868]]

outside the scope of the conduct challenged under the Sherman Act claim 
and therefore are outside the scope of the Court's Tunney Act review.

a. General Comments About OhioHealth's Market Power

    Two commenters expressed concerns about OhioHealth's possession and 
exertion of market power to harm various stakeholders including 
patients, employees, and others in the communities surrounding their 
hospitals.
    First, the United States received a comment from the Ohio Nurses 
Association (``Association''). The Association wrote to request that 
the United States ``broaden its scrutiny of OhioHealth's conduct and 
the impact its market power is having on patients and communities 
throughout [the] state.'' (Exhibit A, TC-001). Specifically, the 
Association cites to OhioHealth's recent closure of its inpatient 
maternity services at Grady Memorial Hospital as an example of harm 
caused by OhioHealth's ``growing market power.'' Id.
    Second, the United States received a comment from a current 
employee of OhioHealth voicing concerns about OhioHealth's treatment of 
employees, patients, and the community. The employee described the 
failure of OhioHealth to make market-rate salary adjustments. They also 
shared the Association's concern about OhioHealth's closure of the 
Labor and Delivery Unit at Grady Memorial Hospital. (Exhibit A, TC-
003).
    These comments do not discuss OhioHealth's contract restrictions on 
steering and price transparency in the relevant market that were 
challenged in the Sherman Act claim or how the proposed remedy is 
allegedly inadequate to resolve the competitive harm that is caused by 
those restrictions. Because these comments do not relate to whether the 
proposed Final Judgment reasonably addresses the harms alleged in the 
Complaint, they are beyond the scope of the Court's review under the 
Tunney Act and do not provide a basis for rejecting the proposed Final 
Judgment. See U.S. Airways, 38 F. Supp. 3d at 76 (``[T]he Court's role 
under the [Tunney Act] is limited to reviewing the remedy in 
relationship to the violations that the United States has alleged in 
its Complaint.'' (internal citation omitted)).

b. Specific Comment About OhioHealth's Contracting Practices

    The United States received one comment that requested the inclusion 
of an ``explicit ban on all-or-nothing contracting provisions'' in the 
proposed Final Judgment. (Exhibit A, TC-002). In the commenter's view, 
the lack of an explicit ban on all-or-nothing contracting could ``leave 
a critical loophole that allows dominant systems to continue leveraging 
market power to the detriment of Ohio employers, workers, and 
patients.'' (Id.).
    The United States' Sherman Act claim challenges only OhioHealth's 
steering and transparency restrictions. The proposed Final Judgment 
provides effective relief for the challenged conduct by banning all 
present and future steering and transparency restrictions and enjoining 
any action that would penalize steering.
    A separate ban on all-or-nothing contracting is unwarranted to 
resolve the United States' claim. The United States' claim does not 
challenge OhioHealth's all-or-nothing contracting as a violation of 
Section 1 of the Sherman Act. Rather, the Complaint alleges as a matter 
of fact that OhioHealth engages in all-or-nothing contracting, which 
can reflect the existence of market power. However, the Sherman Act 
claim challenges OhioHealth's steering and transparency restrictions 
themselves, not the all-or-nothing contracting. If OhioHealth were to 
impose an all-or-nothing contracting requirement that prevents a Payor 
from steering, that would violate the proposed Final Judgment.
    Moreover, the proposed Final Judgment includes multiple 
reservations of rights explicitly stating that (1) if the proposed 
Final Judgment fails to fully redress the violations alleged in the 
Complaint, then the United States may re-open the proceeding and seek 
additional relief; and (2) the proposed Final Judgment terminates only 
the claims stated in the Complaint and does not affect other charges or 
claims the United States or the State of Ohio may file. (Dkt. 29-2 at 
17, 19). If in the future the United States learns that OhioHealth's 
all-or-nothing contracting practices result in anticompetitive harm, 
the United States may investigate the conduct, and if warranted, bring 
an enforcement action against OhioHealth for that conduct.

c. Blood Cancer United's Comment

    On September 21, 2026, the United States received a comment from 
Blood Cancer United, in which the organization wrote that it ``agree[s] 
that the proposed Final Judgment achieves all or substantially all of 
the relief the United States would have obtained through litigation, 
while avoiding the time, expense, and uncertainty of a full trial on 
the merits.'' (Exhibit A, TC-004). Blood Cancer United expressed 
concerns primarily about the general consolidation of healthcare and 
urged lawmakers and enforcement agencies to prevent systems like 
OhioHealth from obtaining market power in the first place and thus 
being able to impose the contract restrictions alleged in the 
Complaint. These concerns are not related to OhioHealth's contract 
restrictions on steering and price transparency in the relevant market 
and are therefore beyond the scope of the Court's review under the 
Tunney Act.
    Similarly, in relation to the price transparency restrictions 
challenged in the Complaint, Blood Cancer United wrote that the United 
States could broaden the scope of its relief by requiring that 
OhioHealth ``disclose the availability of financial assistance on its 
main website'' and provide ``notice about financial assistance with a 
paper copy of the application.'' Id. at 4. However, the price 
transparency restrictions challenged in the Complaint relate to payors' 
efforts to increase transparency about prices of healthcare services. 
The Complaint did not challenge OhioHealth's own disclosure 
requirements. Therefore, the additional relief recommended by Blood 
Cancer United falls outside the scope of the proposed Final Judgment 
and thus beyond the scope of the Court's review under the Tunney Act.
    Finally, the organization commended the appointment of a monitor 
but suggested that a longer monitorship may be necessary to ``provide 
better oversight and foster institutional reform.'' Id. The United 
States believes that a term of five years is sufficient to ensure 
OhioHealth's compliance with the proposed Final Judgment. However, the 
proposed Final Judgment does include a reservation that the United 
States, in its sole discretion, may determine a different period is 
appropriate. (Dkt. 29-2 at 13).
    The concerns expressed by Blood Cancer United are either outside 
the scope of the harm alleged in the Complaint or are already addressed 
in the proposed Final Judgment. As the organization itself agrees, the 
proposed Final Judgment effectively relieves the harm of the antitrust 
violations alleged in the Complaint.

V. Conclusion

    After careful consideration of the public comments, the United 
States continues to believe the proposed Final Judgment provides an 
effective and appropriate remedy for the antitrust violations alleged 
in the Complaint and is therefore in the public interest. The United 
States will move this Court to

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enter the proposed Final Judgment after this response and the public 
comments are published in the Federal Register as required by 15 U.S.C. 
16(d).

Dated: November 2, 2026

Respectfully submitted,

FOR PLAINTIFF
UNITED STATES OF AMERICA
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PAUL TORZILLI* (S.D. Ohio Bar 4118832),
Senior Litigation Counsel
Karl D. Knutsen*, Stella Martin, Trial Attorneys, United States 
Department of Justice, Antitrust Division, 450 5th St. NW, Suite 
4100, Washington DC 20530, Telephone: (202) 476-0547, Email: 
<a href="/cdn-cgi/l/email-protection#aefecfdbc280fac1dcd4c7c2c2c7eedbddcac1c480c9c1d8"><span class="__cf_email__" data-cfemail="94c4f5e1f8bac0fbe6eefdf8f8fdd4e1e7f0fbfebaf3fbe2">[email&#160;protected]</span></a>.
*Designated Trial Attorneys
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[FR Doc. 2026-22618 Filed 11-4-26; 8:45 am]
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