FAQs

As part of the California Attorney General’s Office (“AGO”) consent to USC Health System’s (“USCHS”) affiliation with Methodist Hospital of Southern California(“Methodist Hospital”, now known as USC Arcadia Hospital) (collectively, the “parties”), the parties agreed to a number of Conditions  to ensure Southern California retains a competitive and accessible healthcare market (the “Conditions”). These Conditions include allowing the AGO to appoint an independent monitor to ensure the parties comply with the specific Competitive Impact Conditions.

William E. Berlin is the Monitor appointed by the AGO in this case. As part of his monitoring activities, Mr. Berlin will accept and investigate complaints alleging that USCHS is not complying with the terms of the Conditions and make recommendations to the AGO regarding those complaints.

For more information on the Monitor and the Conditions, please see the About section of the website.

This website was established by Hall, Render, Killian, Heath & Lyman, LLP for the submission of complaints about USCHS and USC Arcadia Hospital’s compliance with the terms of the Conditions required by the AGO to secure USCHS’s acquisition of Methodist Hospital and to ensure a competitive and accessible healthcare market in Southern California (the “Conditions”).

For more information on the Conditions, please see the Important Documents section of the website and the links to the AGO’s public documents regarding its conditional approval of the USCHS/Methodist Hospital affiliation, linked here.

The Conditions are established to ensure that Californians benefit from an open and accessible healthcare market. Specifically, the Monitor ensures USCHS and USC Arcadia Hospital’s compliance with the Competitive Impact Conditions, which prohibit USCHS from expressly or implicitly conditioning the participation of, or imposing any payor contract terms concerning, a USCHS-controlled hospital on the participation of, or any contract terms concerning, one or more other controlled hospitals, with any payor, including:

(a) engaging a payor in “all-or-nothing” contracting for hospital services by expressly or impliedly requiring the payor to contract with all USC-controlled hospitals and not permitting the payor to contract with individual USCHS hospitals,

(b) explicitly or implicitly penalizing a payor for contracting with individual USCHS hospitals, including setting significantly higher than existing contract prices or out-of-network fees for any or all USCHS hospitals, should the payor choose to contract with less than all of the USCHS hospitals,

(c) interfering with, or otherwise engaging in any action, direct or indirect, to prevent the introduction or promotion of new narrow, tiered, or steering commercial or government-sponsored products or value-based benefit designs for commercial or government-sponsored products. 

Additionally, USCHS is prohibited from annual price increases that exceed  4.8% for a period of at least five years. Furthermore, the Conditions prohibit retaliation or threats of retaliation based on any payor, entity, or individual having provided information in conjunction with these conditions to the Monitor, a court, or any party.

For more information on the Conditions, please see the Important Documents section of the website. 

A complaint is an allegation that USCHS is not in compliance with the Competitive Impact Conditions. These include the prohibition on “bundling” or “all-or-nothing” contracting, penalizing payors for contracting with individual facilities, interfering with certain payor practices (e.g. benefit designs that reward providers for affordability or quality) and/or other anticompetitive practices, and the 4.8% cap on USC Arcadia Hospital’s annual price increases for contract renewals.

The full Conditions can be found at this link. If you have a complaint regarding USCHS, but that complaint does not pertain to USCHS’s contracting practices and its compliance with the Competitive Impact Conditions, you have other options, including:

• Contacting USCHS
• Contacting the California Attorney General’s Office

You may submit a complaint to the Monitor if you have an allegation that USCHS or Methodist Health is not in compliance with the competitive impact conditions.

To submit a complaint, please follow the link.

All complaints to the Monitor shall be submitted through this website. 

To submit a complaint, please follow the link.

Upon receipt of a complaint through this website, the Monitor will review your submission. You may be asked to provide supporting documentation, additional information, or be interviewed by the Monitor. 

Generally, yes, but not necessarily. The Monitor’s Complaint Submission Portal will provide you with a standardized complaint intake form and allow for the upload of any documentation in support of the complaint allegation(s). A complaint submitted to the Monitor may, but is not required to, be accompanied by any documents or other information supporting the complaint and the allegations of a violation of the Conditions.

The Monitor will strive to have an initial response completed as soon as practicable or within thirty (30) days of receiving a complete complaint and timely response(s) to any follow-up questions or requests for additional information.

It depends on the disputed issue. The Monitor will not act as a shadow negotiator during contract negotiations nor act as a mediator on contract terms unrelated to the Competitive Impact Conditions.

However, should a dispute arise as to whether USCHS and/or USC Arcadia Hospital’s conduct during contract negotiations violates the Competitive Impact Conditions, the Monitor will review materials and communications regarding the negotiations to evaluate the parties’ compliance with the Conditions.

The Monitor and this website DO NOT address individuals’ complaints about the medical treatment, care or bills received at a USCHS hospital or affiliates, including USC Arcadia Hospital. If you have a complaint about the medical treatment, care, or a bill you received at one of the parties’ hospitals or one of the parties’ affiliates, you have other options, including:

• Contacting USCHS
• Contacting the California Attorney General’s Office using this link to the AGO’s consumer complaint portal

No.

If you file a complaint that USCHS is not complying with the Conditions, your complaint and the information included in the complaint will not be shared with USCHS unless you specifically consent to such disclosure. Your complaint may, however, be shared with the AGO.

For more information about submitting complaints to the Monitor, you may send an email to: uschsmonitor@hallrender.com. 

For more information about the affiliation between USCHS and Methodist Hospital, please click here.

You can get a copy of the Complaint and the Conditions, as well as view the AGO’s press release regarding the affiliation between USCHS and Methodist Hospital at this link.