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safeguard against unfair methods of competition and unfair practices. Although the FTC has recently blocked some major healthcare system, provider, and insurer mergers, whether the FTC possesses sufficient resources to hold back the consolidation storm remains unanswered. Under this article’s proposed model, the hands collecting the insurance premiums will also deliver the care.336 The CFO at a major health system was quoted saying, “We shag every fly ball a health plan hits to us-–an ACO here, a bundle experiment there . . . Maybe it’s time we take the plunge and become an insurer ourself.”337 Although there may be some downsides in creating a health plan, the long term benefits associated with a health system operating as a provider and an insurer likely outweigh the initial cost and structural burdens.338 Providers that successfully implement and operate their own health plans have the potential to drastically change the delivery and financing of health care in a positive way. The stunning volume of mergers has increased the notice, concern, and attraction to the current healthcare events. With that attention, the industry has the opportunity to gain awareness of the issues to create and structure a better, less-costly healthcare delivery system. Just as a car owner has an incentive to take his or her car to the shop for consistent oil changes, providers playing the dual-role of an insurer and a provider will also have a financial incentive to maintain the health of their patient-population.339
336. Dana Blankenhorn, Vertical Integration Comes to Health Care, Street (Aug. 20, 2012, 10: 35 AM), http://www.thestreet.com/story/11668844/1/vertical-integration-comes-to- health-care.html. 337. Ahlquist et al., supra note 320. 338. See Herman, The Risks, supra note 257 (noting that although “[a] lot of backend work is required to make a provider-operated health plan successful . . . benefits come in the long run”). 339. Blankenhorn, supra note 336.