BROWN &TOLAND MEDICAL GROUP'S - FOLLOW-UP PPO SUBMISSION - Responses to FTC Staff's Follow-Up Questions

Sep 14, 2026

Uploaded by McQueen

Submission detailing Brown & Toland Medical Group’s responses to FTC staff follow-up questions regarding its PPO referral practices and internet-based system for sharing data among PCPs and specialists. The document explains that PPO patients may self-refer outside the PPO network, while Brown & Toland’s physicians generally direct specialty care within the network and estimates such out-of-network referrals will be rare. It also describes the EMR program’s objectives, investment timeline, cost and operational considerations, and core modules supporting care quality, clinical guideline adoption, prescribing, disease management, and clinical results reporting.

LanguageEnglish

CategoryLetters

FormatPDF

Pages24

Reading Time8 min

AccessFree to download

Responses to FTC Staff's Follow-Up Questions

1. Follow-Up Questions Regarding PPO Referrals

2. Follow-Up Questions Regarding Brown &Toland's Internet-Based System

# BROWN &TOLANDMEDICAL GROUP’S FOLLOW-UP PPO SUBMISSION Submitted by: Boies,Schiller &Flexner LL.P.5301 Wisconsin Ave.,N.W.Suite 800Washington,DC 20015 October 7,2004 # Responses to FTC Staff's Follow-Up Questions ## 1.Follow-Up Questions Regarding PPO Referrals Explain how Brown &Toland PPO participating physicians make referrals to specialists. Under a PPO system,patients generally are free to choose among doctors both within andoutside of the network. WillBrown&Toland require its PCPs to refer only to specialists within the network? If not,does Brown&Toland have any estimate of the percentage of patients that its PCPsmay refer to specialists outside the network or of patients that may ask to be referred to aspecialist outside of the network? If referrals will occur outside the network,are the processes that Brown &Tolandproposes to implement to achieve the benefits of clinical integration going to have anyeffect to the extent such out of network referrals occur? If yes,how will that be achieved? 1.Response to Follow-Up Questions Regarding PPO Referrals Brown &Toland's PPO physicians refer to specialists based on the clinical needsof their patients.PPO plans do not prohibit patients from selfreferring to specialistsoutside of Brown &Toland's PPO network,and Brown&Toland cannot change thisbenefit design.For two reasons,however,PPO patients are likely to stay within theBrown &Toland network for specialty care.First,PPO plans provide financialincentives for patients to stay within the network,as patients must pay higher co-payments if they are treated by out of network physicians.Second,Brown&Tolandprimary care physicians almost always refer to specialists within the Brown &Tolandnetwork.This stems from the Brown&Toland physicians'practice pattens with regardto HMOplans.1 This referral practice will continue,in all likelihood,going forward asinterdependencies among network physicians that exist with regard to Brown&Toland'sHMO business continue to transition to the PPO business.2 Brown &Toland estimates that specialty referrals outside of its PPO network willbe rare.For any such referrals,Brown &Toland's case managers will likely assist in 1 coordinating care with out of network physicians if the patient is enrolled in a casemanagement program for chronic care.In addition,through Brown &Toland's electronicmedical records(“EMR”)program,a referring Brown &Toland physician may providean out ofnetwork physician with a complete history of a patient's care via a fax copy,which could eliminate duplicative testing and unnecessary treatments.Long term,asnational standards for data sharing are established and more physicians implementelectronic medical records,an electronic record could be sent to-and clinical notesreceived back from-the out of network physician. ## 2.Follow-Up Questions Regarding Brown&Toland's Internet-Based System Provide more information about how the internet-based system that is being put in placeto share data among PCPs and specialists will work. Will this system differ from any system that Brown&Toland currently offers itsphysicians and case managers for HMO patients? If the answer is yes,describe those differences. What does Brown &Toland estimate as incremental cost of putting this system into placeand how many years willit take for the system to be fully operational? What does Brown &Toland estimate to be the useful life of this system once it is fullyoperational? 2.Response to Follow-Up Questions Regarding Brown&Toland's Internet-BasedSystem Brown &Toland's EMR system,when operational,will support both the PPO andHMO products.Brown&Toland will invest $12 million over a ten-year period toimplement and manage the EMR and other practice management systems.The system isintended to facilitate information sharing among Brown &Toland network physiciansand,relatedly,to increase the quality of care and reduce costs by supporting the followingoperations: ·Clinical guide

FAQs

How do Brown & Toland PPO participating physicians make referrals to specialists?

They refer specialists based on the clinical needs of their patients. PPO plans do not prohibit self-referrals by patients to specialists outside the PPO network, and Brown & Toland cannot change that benefit design.

Will Brown & Toland require PCPs to refer only within the network, and how likely are out-of-network referrals?

Brown & Toland does not require PCPs to refer only within the network. The document states out-of-network specialty referrals are likely to be rare because PPO plans use financial incentives and primary care physicians almost always refer within the Brown & Toland network.

What is the purpose and scope of Brown & Toland’s EMR internet-based system?

When operational, the EMR supports both PPO and HMO products and facilitates information sharing across the physician network to improve care quality and reduce costs. It includes modules for workflow, electronic prescribing, clinical results reporting, and order transmission to laboratories and ancillary departments.

Sep 14, 2026

Uploaded by McQueen