Well before the passage of the Affordable Care Act in 2010, providers have been joining together in an effort to better manage the care of a specific patient population by setting up a clinically integrated network, or CIN. Clinical integration is defined by an active and ongoing program to evaluate and modify the practice patterns of physicians and create a high degree of interdependence and cooperation to control costs and ensure quality. The goal is to create a meaningful prospect of improving efficiency in the delivery of care, reducing costs, better managing utilization, or improving the quality of care. Historically, the U.S. Department of Justice (DOJ) and Federal Trade Commission (FTC) had used antitrust law to prevent private business practices that unreasonable restrain competition and to ensure that consumers benefitted from lower prices, better quality and increased choice, selection, convenience or innovation when competitors collaborated with each other. In Arizona v. Maricopa County Medical Society (1982), the Supreme Court made it clear that physicians in independent practices are supposed to compete. They further noted that when physicians do not compete, by collectively setting the prices at which they sell their individual services, they can be guilty of illegal price fixing. For a CIN, even if there is some integration, any agreement on price must be “reasonably necessary” to realize efficiency goals. Through the 1990s and early 2000s, both the FTC and DOJ provided guidance, including statements of antitrust enforcement policy in healthcare and advisory opinion letters, which outlined the requirements CINs must establish through their governance, participation agreements and operations.