`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW HAMPSHIRE
`
`UNITED STATES OF AMERICA
`
`
`
`
`
`Civil Action No.:_______________
`
`
`
`
`and
`
`STATE OF NEW HAMPSHIRE
`
`
`
`
`
`
`
`
`Plaintiffs,
`
`vs.
`
`
`HARVARD PILGRIM HEALTH CARE, INC.
`
`and
`
`HEALTH PLAN HOLDINGS, INC.
`
`
`
`
`
`
`
`Defendants.
`
`COMPLAINT
`
`The United States of America and the State of New Hampshire bring this civil antitrust
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`action to block the proposed merger of Harvard Pilgrim Health Care and Health Plan Holdings
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`(f/k/a Tufts Health Plan). The combination of Harvard Pilgrim and Health Plan Holdings—two
`
`of the largest suppliers of health insurance in New Hampshire for certain employers purchasing
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`group coverage for their employees—into one firm would likely lead to higher prices, lower
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`quality, and reduced choice for consumers of commercial group health insurance in New
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`Hampshire. To prevent this harm to consumers, the United States and the State of New
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`Hampshire seek an injunction to stop the proposed merger. Plaintiffs allege as follows:
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`
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`
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`
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`1
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 2 of 15
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`I.
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`INTRODUCTION
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`1.
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`Health insurance is an integral part of the American healthcare system.
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`Americans collectively spend trillions of dollars on healthcare each year, and the cost of
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`healthcare impacts almost every American. Consumers depend on health insurance to secure
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`affordable access to doctors and hospitals and to protect themselves from the risk of medical
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`expenses that could be financially devastating.
`
`2.
`
`Half of all Americans obtain health insurance coverage through their employers.
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`Employers purchase group health insurance plans for their employees from insurance companies
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`such as Harvard Pilgrim and Health Plan Holdings. Competition between insurance companies
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`like Harvard Pilgrim and Health Plan Holdings ensures that employers can purchase high-quality
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`group health insurance plans for their employees at affordable prices.
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`3.
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`Harvard Pilgrim sells commercial group health insurance plans to small and large
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`employer groups in New Hampshire. Health Plan Holdings sells commercial group health
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`insurance plans to small and large employer groups in New Hampshire through Tufts Health
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`Freedom Plan, Inc. (“Tufts Freedom”).
`
`4.
`
`In New Hampshire, Harvard Pilgrim and Tufts Freedom are two of the three top
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`companies offering commercial group health insurance plans to (1) private small group
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`employers with up to 50 full-time eligible employees (“small groups”) and (2) private large
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`group employers with between 51 and 99 full-time eligible employees, a segment of commercial
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`large group health insurance referred to as community rated by class or “CRC” by Defendants
`
`and others in the industry (“CRC groups”). Competition between Harvard Pilgrim and Tufts
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`Freedom has resulted in lower premiums, richer (i.e., more robust and comprehensive) plan
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`benefits, and better service for small groups and CRC groups in New Hampshire.
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`
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`2
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 3 of 15
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`5.
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`Combining Harvard Pilgrim and Health Plan Holdings into one firm would
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`eliminate this competition, likely raising the price and reducing the quality of commercial health
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`insurance sold to small groups and to CRC groups in New Hampshire.
`
`6.
`
`As a result, the proposed transaction is likely to substantially lessen competition
`
`for commercial health insurance sold to small groups and to CRC groups, in violation of Section
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`7 of the Clayton Act, 15 U.S.C. § 18. The Court, therefore, should enjoin this transaction.
`
`II.
`
`DEFENDANTS AND THE TRANSACTION
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`7.
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`Harvard Pilgrim sells commercial group health insurance to small and large
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`employer groups in four states: New Hampshire, Massachusetts, Connecticut, and Maine.
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`Harvard Pilgrim’s annual revenue in 2019 was approximately $3 billion, and it has over one
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`million members.
`
`8.
`
`Health Plan Holdings sells commercial group health insurance to small and large
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`employer groups in New Hampshire through Tufts Freedom, which until September 2020 was a
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`joint venture with the Granite Healthcare consortium consisting of several large New Hampshire
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`health systems and now is solely owned by Health Plan Holdings. It also sells commercial group
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`health insurance in Massachusetts and Rhode Island. Health Plan Holdings’ annual revenue in
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`2019 was over $5.5 billion, and it has over one million members.
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`9.
`
`Defendants have agreed to a “merger of equals,” which was memorialized in a
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`Combination Agreement dated August 9, 2019 (the “Transaction”).
`
`III.
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`JURISDICTION AND VENUE
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`10.
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`This Court has subject-matter jurisdiction under Section 15 of the Clayton Act, 15
`
`U.S.C. § 25, and 28 U.S.C. §§ 1331, 1337(a), and 1345.
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`
`
`3
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 4 of 15
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`11.
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`The State of New Hampshire brings this action in its sovereign capacity as parens
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`patriae on behalf of and to protect the health and general welfare of its citizens and the general
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`economy of the State under Section 16 of the Clayton Act, 15 U.S.C. § 26 and under N.H. Rev.
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`Stat. Ann. 356:4-a & 4-b, seeking injunctive and other relief from Defendants’ violation of
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`Section 7 of the Clayton Act, 15 U.S.C. § 18 and state antitrust law.
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`12.
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`Defendants are engaged in activities that substantially affect interstate commerce.
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`Defendants sell health insurance and administrative services for which employers and consumers
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`remit payments across state lines, and Defendants otherwise participate in interstate commerce.
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`13.
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`Venue is proper under Section 12 of the Clayton Act, 15 U.S.C. § 22, and under
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`28 U.S.C. §§ 1391(b) and (c).
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`14.
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`This Court has personal jurisdiction over each Defendant. Harvard Pilgrim is
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`headquartered in Wellesley, Massachusetts and transacts business in this district. Health Plan
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`Holdings is headquartered in Watertown, Massachusetts and transacts business in this district.
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`Both Harvard Pilgrim and Health Plan Holdings have consented to personal jurisdiction and the
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`acceptance of service of process in this district for purposes of this matter. The Transaction
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`would also have effects on employers and consumers in this district.
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`IV. THE RELEVANT MARKETS
`
`15.
`
`Commercial group health insurance is sold by health insurance companies to
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`employers to provide health insurance coverage to their employees and their employees’
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`families. Employers cover at least a portion of the cost of the insurance for their employees,
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`making it a cost-effective way for employees, and their families, to obtain health insurance.
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`16.
`
`Insurers offering commercial group health insurance plans to employers try to
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`make them attractive by competing on price, product design, customer service, care
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`
`
`4
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`
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 5 of 15
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`management, wellness programs, and reputation. Insurers also compete based on the breadth of
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`their network of healthcare providers, including doctors and hospitals, as employers seek an
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`insurance plan that offers in-network access to medical providers that are close to where their
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`employees live and work. An insurer’s ability to compete on price depends largely on medical
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`costs, which are impacted significantly by the discounts the insurer obtains from medical
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`providers.
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`17.
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`In New Hampshire, Harvard Pilgrim and Health Plan Holdings compete
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`vigorously with one another in the sale of commercial health insurance to small groups and to
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`CRC groups.
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`18.
`
`The Transaction is likely to harm competition in two health insurance markets in
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`New Hampshire: (1) the sale of commercial group health insurance to small groups and (2) the
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`sale of commercial group health insurance to CRC groups. For both of these markets, employers
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`tend to be local, with the majority of their employees based in New Hampshire, although some
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`employers offer insurance to employees in multiple states. Competition to win small groups and
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`CRC groups in New Hampshire is primarily driven by which insurer offers the lowest rates.
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`Small groups and CRC groups, as defined in this complaint, do not include governmental
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`employers (e.g., municipalities, school districts) in New Hampshire with fewer than 100
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`employees, as historically almost all those employers have purchased health insurance through a
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`trust instead of directly from an insurer.
`
`A.
`
`19.
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`Commercial Health Insurance Sold to Small Groups
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`The sale of commercial health insurance to small groups in New Hampshire is a
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`relevant antitrust product market in which to analyze the effects of the Transaction. New
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`Hampshire Insurance Department regulations define a “small group” as an employer with 50 or
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`
`
`5
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`
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 6 of 15
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`fewer full-time eligible employees. For small groups, health plans are typically fully insured,
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`which means that the employer pays a premium to the insurance company and in return the
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`company covers the employees’ healthcare costs. Small groups tend to be local in nature,
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`requiring a strong local provider network.
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`20.
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`The commercial health insurance plans offered to small groups are governed by
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`the New Hampshire Insurance Department and cannot be substituted with plans offered to New
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`Hampshire employers with 51 or more full-time eligible employees, defined by statute as “large
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`group.” Harvard Pilgrim and Health Plan Holdings also differentiate small group accounts
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`separately from large group accounts internally and offer different pricing for small group
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`accounts compared to large group accounts.
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`21.
`
`New Hampshire law does not require that an insurer offer a small group product
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`statewide and therefore permits an insurer to offer small group plans only in certain counties.
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`Accordingly, despite the fact that state law does not allow insurers to charge different prices for
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`the same small group plans based on location, insurers can offer a more expensive set of small
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`group plans in one part of the state, and a less expensive set of different small group plans in
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`another part of the state. This allows insurers to charge different prices for different products to
`
`small groups based on where employees live and work. The Transaction is likely to substantially
`
`lessen competition for the sale of commercial health insurance to small groups in all seven of
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`New Hampshire’s Core Based Statistical Areas (“CBSA”): (1) the Manchester-Nashua CBSA,
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`(2) the Concord CBSA, (3) the Laconia CBSA, (4) the Keene CBSA, (5) the Berlin CBSA, (6)
`
`the New Hampshire counties (Grafton and Sullivan) of the Lebanon NH-VT CBSA, and (7) the
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`New Hampshire counties (Rockingham and Strafford) of the Boston-Cambridge-Newton MA-
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`NH CBSA.
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`
`
`6
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 7 of 15
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`22.
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`Each of these seven CBSAs is a relevant geographic market. A hypothetical
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`monopolist over the sale of commercial health insurance to small groups in each of these markets
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`would impose a small but significant and non-transitory increase in price, or SSNIP. A small
`
`group employer, faced with a significant price increase, cannot defeat the price increase by
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`purchasing a large group product for which it is ineligible. This price increase would not be
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`defeated by substitution outside the relevant market or by arbitrage (meaning a small group
`
`trying to repurchase insurance through another employer group).
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`B.
`
`23.
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`Commercial Health Insurance Sold to CRC Groups
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`The sale of commercial health insurance to CRC groups is a relevant antitrust
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`product market. In New Hampshire, employers with between 51 and 99 full-time eligible
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`employees represent a distinct segment of large group and are referred to as CRC employers (or
`
`CRC groups). CRC groups have different needs and make different buying decisions than small
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`groups or even larger employers. Harvard Pilgrim and Tufts Freedom employ different sales
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`strategies for this segment than they do for other types of employers.
`
`24.
`
`For CRC groups, similar to small groups, health plans are typically fully insured,
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`which means that the employer pays a premium to the insurance company and in return the
`
`company covers the employees’ healthcare costs. Insurers, including Harvard Pilgrim and Tufts
`
`Freedom, differentiate employers with 51 to 99 full-time eligible employees from other large
`
`group employers, and refer to these employers as the CRC segment. As with small groups, CRC
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`groups also tend to be more local in nature than other large group employers, requiring a strong
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`local provider network, as opposed to large group employers with more than 100 full-time
`
`eligible employees, which tend to require strong national provider networks.
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`
`
`7
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 8 of 15
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`25.
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`Insurers offering commercial health insurance to CRC groups in New Hampshire
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`can charge different prices to different employers. Group health plans for CRC groups, in
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`contrast to larger group employers, are typically (although not exclusively) community rated by
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`class, meaning that, when setting rates for CRC groups, the insurer first establishes a base rate
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`determined by the medical costs of a class of similar groups, rather than upon the medical costs
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`of the individual group seeking the plan. The insurer then uses this base rate, along with the
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`individual employer’s medical costs, to negotiate rates with the specific CRC group.
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`26.
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`The Defendants target CRC groups directly through their sales efforts. For
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`example, Tufts Freedom has focused its large group sales efforts on CRC groups since it began
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`selling commercial health insurance in New Hampshire, and Harvard Pilgrim tracks CRC groups
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`separately from other large group accounts. In addition, both Harvard Pilgrim and Tufts
`
`Freedom utilize specific pricing strategies for CRC groups. The Defendants have formulated
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`these specific pricing strategies because CRC groups in New Hampshire are generally more price
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`sensitive than large group employers with more than 100 full-time eligible employees.
`
`27.
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`As with commercial health insurance sold to small groups, New Hampshire law
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`does not require that an insurer offer a CRC group product statewide and therefore permits an
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`insurer to offer CRC plans only in certain counties. Accordingly, insurers can offer more
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`expensive plans to CRC groups in one part of the state and less expensive plans in another part of
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`the state. This allows insurers to charge different prices for different products to CRC groups
`
`based on where employees live and work. The Transaction is likely to substantially lessen
`
`competition for the sale of commercial health insurance to CRC groups in six separate CBSAs in
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`New Hampshire: (1) the Manchester-Nashua CBSA, (2) the Concord CBSA, (3) the Laconia
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`CBSA, (4) the Keene CBSA, (5) the New Hampshire counties (Grafton and Sullivan) of the
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`
`
`8
`
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 9 of 15
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`Lebanon NH-VT CBSA, and (6) the New Hampshire counties (Rockingham and Strafford) of
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`the Boston-Cambridge-Newton MA-NH CBSA.
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`28.
`
`Each of these six CBSAs is a relevant geographic market. A hypothetical
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`monopolist over the sale of commercial health insurance to CRC groups in each of these markets
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`would impose a small but significant and non-transitory increase in price or SSNIP. This price
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`increase would not be defeated by substitution outside the relevant market or by arbitrage.
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`
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`V. THE TRANSACTION IS PRESUMPTIVELY ILLEGAL
`
`29. Mergers that significantly increase concentration in already concentrated markets
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`are presumptively anticompetitive and therefore presumptively unlawful.
`
`30.
`
`To measure market concentration, courts often use the Herfindahl-Hirschman
`
`Index (“HHI”). HHI is an accepted measure of market concentration. It is calculated by
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`squaring the market share of each firm competing in the market and then summing the resulting
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`numbers. For example, for a market consisting of four firms with shares of 30 percent, 30
`
`percent, 20 percent, and 20 percent, the HHI is 2,600 (302 + 302 + 202 + 202 = 2,600). The HHI
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`recognizes the relative size distribution of the firms in a market, ranging from 0 in markets with
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`no concentration to 10,000 in markets where one firm has 100 percent market share. See
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`Horizontal Merger Guidelines § 5.3. Courts have found that mergers that increase the HHI by
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`more than 200 and result in an HHI above 2,500 in any relevant market or line of commerce are
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`presumed to be anticompetitive.
`
`A.
`
`
`31.
`
`The Relevant Markets are Highly Concentrated and the Transaction Would
`Significantly Increase Their Concentration
`
`In the small group market, based upon 2018 data, the combined market shares for
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`Harvard Pilgrim and Tufts Freedom would range from over 45% to over 60% in each of the
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`seven CBSAs. The Transaction would reduce the number of small group health insurers from
`9
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 10 of 15
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`four to three, with the two largest insurers – Anthem and the merged Harvard Pilgrim/Tufts
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`Freedom – possessing over 95% share in each of the seven CBSAs. The Transaction would
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`result in an HHI increase ranging from over 350 points to over 1,600 points with post-transaction
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`HHIs of between 4,500 points and 7,500 points for commercial health insurance sold to small
`
`groups in New Hampshire. Thus, the Transaction is presumptively unlawful.
`
`32.
`
`For the CRC group market, based upon 2018 data, the combined market shares
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`for Harvard Pilgrim and Tufts Freedom would range from more than 40% to over 65% in each of
`
`the six CBSAs. The Transaction would reduce the number of CRC group health insurers from
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`four to three, with the two largest insurers – Anthem and the merged Harvard Pilgrim/Tufts
`
`Freedom – possessing over 95% share in each of the six CBSAs. The Transaction would result
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`in an HHI increase ranging from over 200 to over 2,000 points in the CRC group market with
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`post-transaction HHIs of just under 5,000 to almost 7,000 for CRC groups in New Hampshire.
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`Thus, the Transaction is presumptively unlawful.
`
`B.
`
`
`33.
`
`The Transaction Likely Would Harm Consumers in New Hampshire
`
`Harvard Pilgrim and Tufts Freedom are particularly close competitors for
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`commercial health insurance sold to small groups and CRC groups in New Hampshire with
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`competition between the two insurers more robust for certain types of groups than the market
`
`shares would predict. This is in part because Harvard Pilgrim and Tufts Freedom – two strong
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`local health insurers that have not built national provider networks – are more attractive to small
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`groups and CRC groups with higher percentages of employees resident in New Hampshire.
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`Similarly, because Harvard Pilgrim and Tufts Freedom have priced aggressively, the two appeal
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`to small groups and CRC groups that have greater price sensitivity.
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`
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`10
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 11 of 15
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`34.
`
`Tufts Freedom’s entry into New Hampshire in 2016 was backed by its Granite
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`Healthcare provider partners, which formed the core of Tufts Freedom’s provider network and
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`extended it substantially below-market rates, enabling it to price aggressively. Using a
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`combination of competitive pricing and a strong provider network, Tufts Freedom significantly
`
`grew its small group market share throughout New Hampshire after entering the state in 2016,
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`with its share reaching almost 20% by 2019. Tufts Freedom achieved much of this growth at the
`
`expense of Harvard Pilgrim. As a result, and as Harvard Pilgrim recognized, the New
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`Hampshire small group market became a three-player market, consisting of Harvard Pilgrim,
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`Tufts Freedom, and Anthem.
`
`35.
`
`Tufts Freedom’s aggressive pricing and growth caused Harvard Pilgrim to
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`respond by significantly lowering prices and improving plan features to be more competitive
`
`with Tufts Freedom. This response included a strategy of targeting its competitors’ “sweet
`
`spots,” meaning lowering its rates on plans that competed with the most popular offerings of its
`
`competitors. Tufts Freedom observed this competitive reaction and in turn responded by
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`announcing lower than expected rate increases. The Transaction would eliminate this fierce
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`competition between Harvard Pilgrim and Tufts Freedom and its resulting benefits to consumers
`
`in New Hampshire.
`
`36.
`
`Direct competition between Harvard Pilgrim and Tufts Freedom in New
`
`Hampshire also has benefitted CRC groups. Again, Tufts Freedom entered New Hampshire
`
`pursuing a targeted pricing strategy that allowed it to gain market share. Harvard Pilgrim reacted
`
`to this competitive pressure resulting in lower health insurance prices for CRC groups.
`
`37.
`
`In addition to this price competition, New Hampshire consumers also have
`
`benefitted from competition between Harvard Pilgrim and Tufts Freedom on plan features and
`
`
`
`11
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`
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 12 of 15
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`quality of service for commercial health insurance sold to CRC groups. For example, in 2019,
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`Harvard Pilgrim developed four new no-coinsurance plans, which limited out-of-pocket
`
`expenses to insureds and offered different features, with the express purpose of making them
`
`more attractive to the insureds. Just this year, Tufts Freedom offered consumers a novel
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`telehealth option that included zero copayment in fully insured plans in order to drive innovation
`
`around this new emerging platform.
`
`38.
`
`Harvard Pilgrim and Tufts Freedom have engaged in head-to-head competition on
`
`price, plan features, and quality of service in the sale of commercial health insurance to small
`
`groups and to CRC groups in New Hampshire. Eliminating this competition would likely result
`
`in higher prices, lower quality, and less customer choice in the sale of commercial health
`
`insurance to small groups and to CRC groups in New Hampshire.
`
`VI.
`
`ABSENCE OF COUNTERVAILING FACTORS
`
`39.
`
`Other firms are unlikely to enter or expand into the relevant markets in a manner
`
`that would be timely, likely, or sufficient to replace the competition that would be lost as a result
`
`of the Transaction.
`
`40.
`
`Each of the relevant markets is characterized by high barriers to entry, including
`
`state licensing and regulatory requirements, the cost of developing a comprehensive provider
`
`network where employees live and work, the inability of insurers without significant
`
`membership to obtain competitive discounts from providers, and the development of sufficient
`
`business to permit the spreading of risk.
`
`41.
`
`The Transaction will not result in verifiable, transaction-specific efficiencies in
`
`the relevant markets sufficient to reverse the Transaction’s likely anticompetitive effects.
`
`
`
`12
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`
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 13 of 15
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`VII. VIOLATION ALLEGED
`
`42.
`
`Plaintiffs allege and incorporate paragraphs 1 through 41 as if set forth fully
`
`herein.
`
`43.
`
`Unless enjoined, the Transaction is likely to substantially lessen competition in
`
`the relevant markets, in violation of Section 7 of the Clayton Act, 15 U.S.C. § 18.
`
`44.
`
`Among other things, the Transaction would:
`
`(a) eliminate present and future competition between Harvard Pilgrim and Health
`
`Plan Holdings in New Hampshire;
`
`(b) likely cause prices for commercial health insurance sold to small groups and
`
`to CRC groups in New Hampshire to be higher than they would be otherwise;
`
`and
`
`(c) likely reduce quality, service, choice, and innovation for commercial health
`
`insurance sold to small groups and to CRC groups in New Hampshire.
`
`VIII. REQUEST FOR RELIEF
`
`45.
`
`Plaintiffs request that:
`
`(a) the Transaction be adjudged to violate Section 7 of the Clayton Act, 15 U.S.C.
`
`§ 18;
`
`(b) the Court permanently enjoin and restrain Defendants from entering into the
`
`Transaction contemplated in the Combination Agreement;
`
`(c) Plaintiffs be awarded the costs of this action, including attorneys’ fees to the
`
`State of New Hampshire; and
`
`(d) Plaintiffs be awarded any other relief that the Court deems just and proper.
`
`
`
`13
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`
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`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 14 of 15
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`Dated: December 14, 2020
`Respectfully submitted,
`
`FOR PLAINTIFF UNITED STATES OF AMERICA:
`
`
`
`
`
`/s/ Makan Delrahim
`MAKAN DELRAHIM
`Assistant Attorney General for Antitrust
`
`
`
`
`
`/s/ Michael Murray
`MICHAEL MURRAY
`Principal Deputy Assistant
` Attorney General
`
`/s/ Kathleen S. O’Neill
`KATHLEEN S. O’NEILL
`Acting Deputy Assistant
` Attorney General
`
`
`
`
`
`
`
`/s/ Eric D. Welsh
`ERIC D. WELSH
`Chief
`Healthcare and Consumer Products Section
`
`
`
`
`
`/s/ Jill C. Maguire
`JILL C. MAGUIRE
`Assistant Chief
`Healthcare and Consumer Products Section
`
`
`
`
`
`14
`
`
`
`
`
`
`SCOTT W. MURRAY
`United States Attorney
`
`
`By: /s/ Michael McCormack
`Michael McCormack
`Assistant U.S. Attorney, NH Bar. #16470
`United States Attorney’s Office
`53 Pleasant Street
`Concord, NH 03301
`Tel: (603) 225-1552
`E-mail: michael.mccormack2@usdoj.gov
`
`
`/s/ Catherine R. Reilly
`CATHERINE R. REILLY
`GARRETT LISKEY
`JUSTIN DEMPSEY
`JEREMY EVANS
`CHRIS S. HONG
`BARRY JOYCE
`JOHN P. LOHRER
`NATALIE MELADA
`DAVID M. STOLTZFUS
`BRANDON STORM
`Attorneys for the United States
`
`U.S. Department of Justice
`Antitrust Division
`450 5th Street, NW, Suite 4100
`Washington, D.C. 20530
`Tel.: (202) 598-2744
`E-mail: catherine.reilly@usdoj.gov
`
`
`
`
`Case 1:20-cv-01183-JL Document 1 Filed 12/14/20 Page 15 of 15
`
`FOR THE PLAINTIFF STATE
`OF NEW HAMPSHIRE
`By its attorney,
`
`/s/ Gordon J. MacDonald____
`GORDON J. MACDONALD
`Attorney General of New Hampshire
`
`/s/ Brandon H. Garod___ _
`BRANDON H. GAROD, NH Bar #21164
`Senior Assistant Attorney General
`Consumer Protection and Antitrust Bureau
`New Hampshire Department of Justice
`Office of Attorney General
`33 Capitol Street
`Concord, NH 03301
`Phone: (603) 271-1217
`brandon.garod@doj.nh.gov
`
`/s/ Jennifer Foley_____________
`JENNIFER FOLEY, NH Bar #10519
`Assistant Attorney General
`Consumer Protection and Antitrust Bureau
`New Hampshire Department of Justice
`Office of Attorney General
`33 Capitol Street
`Concord, NH 03301
`Phone: (603) 271-7987
`Jennifer.Foley@doj.nh.gov
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