Law360, New York (February 14, 2012, 1:55 PM ET) -- Independent health care providers such as doctors and pharmacists occasionally form independent practice associations (IPAs) to cooperate in providing services to patients. At times, these IPAs attempt to collectively negotiate reimbursement rates with third-party payers. This type of collective negotiation often leads to antitrust enforcement actions.

Since 2001, the Federal Trade Commission (FTC) and the U.S. Department of Justice have brought 36 cases against IPAs, with 35 ending in consent decrees banning future rate negotiation.

In the one remaining case, North Texas Specialty Physicians v. FTC...