“…In order to broadly analyze the extent to which physician practices contemplating ACO participation would potentially concern the antitrust authorities, we use a 20% sample of 2009 Medicare physician claims (a period immediately preceding the passage of the Affordable Care Act) as specified in the guidelines when analyzing specialty-specific PSAs for physician services. 1 Consistent with previous studies of physician groups (Baker, Bundorf, Royalty, & Levin, 2014;Kleiner, White, & Lyons, 2015;Pham, Schrag, O'Malley, Wu, & Bach, 2007;Welch, Cuellar, Stearns, & Bindman, 2013), these same guidelines further specify the use of the Tax ID field in the Medicare data to identify practices. 2 In addition, we follow the criteria specified in the guidelines to create practice-level PSAs by identifying, for each practice, the smallest set of patient ZIP codes from which a practice draws 75% of its patients.…”