Public competition mandate
Policy proposals informed by public competition research. Concentration can identify a question worth investigating; it does not establish harm or unlawful conduct.
The role of government is not passive refereeing. It is to protect people from private bottlenecks, hidden gatekeepers, and markets where choice exists only on paper.
Public action triage
The focused market stays first. Screening rank orders attention; it does not measure public harm or establish liability. The agency guideline and Antitrust Radar priority queue remain separate below. Every docket keeps its evidence boundary and government-action lane visible.
FTC + HHS/DOJ
People exposed
Patients, pharmacies, and payersMiddlemen can narrow access, reimbursement, and medicine affordability while firm-level shares stay hidden.Government lever
FTC/HHS transparency orderRequire auditable firm-level shares and outcome data tied to patient and pharmacy choice.Evidence boundaryFirm-level shares and local ownership/control data · incomplete · high confidence
12
profiles
7
HHI >= 2,500
4
data gaps
45
sources
Public duty compact
Evidence to action
Action packet contract
Profile, sources, data, and brief stay linked before anyone sends an ask.
Public duty compact
Public action triage
Public action triage
The focused market stays first. Screening rank orders attention; it does not measure public harm or establish liability. The agency guideline and Antitrust Radar priority queue remain separate below. Every docket keeps its evidence boundary and government-action lane visible.
FTC + HHS/DOJ
People exposed
Patients, pharmacies, and payersMiddlemen can narrow access, reimbursement, and medicine affordability while firm-level shares stay hidden.Government lever
FTC/HHS transparency orderRequire auditable firm-level shares and outcome data tied to patient and pharmacy choice.Evidence boundaryFirm-level shares and local ownership/control data · incomplete · high confidence
Public market launcher
PBMs
Health care
Withheld
HHI
Search engines
Digital platforms
7,359
HHI
Mobile operating systems
Digital platforms
5,337
HHI
Social referrals
Digital platforms
4,995
HHI
01
Start with the lived market people can actually choose from.
02
Show publisher, date, method, and confidence before making claims.
03
Turn evidence into oversight, disclosure, and fair-market rules.
Public record
>1,800
DOJ/FTC Merger Guidelines (2023)
2023 guideline HHI threshold
The agencies' 2023 Merger Guidelines treat markets above this HHI level as highly concentrated.
~80%
FTC-backed PBM profile
PBM prescriptions
The FTC reported the top three PBMs processed nearly four in five U.S. prescriptions in 2023.
49.7%
U.S. Census Bureau
renter cost burden
Census reported nearly half of U.S. renter households spent more than 30% of income on housing costs in 2023.
1.1%
Census HVS Q1 2026
housing vacancy
Census HVS reported a 1.1% homeowner vacancy rate in Q1 2026, a scarcity signal that strengthens the case for local competition evidence.
Government duty queue
Record-to-duty route
Action brief station
The public workflow should start near the top: pick a priority market, inspect the source trail, open the data console, and generate a government-ready brief.
Market in focus
PBMs
People harmed
Patients, pharmacies, and payers
Government lever
FTC + HHS/DOJ transparency route
Opaque middlemen can shape access, reimbursement, and prices while the public record sees only partial aggregate facts.
0/3 core metrics; request disclosure before making a concentration claim
Source to action route
HHI
Withheld
Public data gap
CR4
N/A
four-firm share
Top firm
N/A
single-firm share
Review lane
Evidence build
incomplete · high confidence
This station makes the advocacy route inspectable before the longer docket: profile, source rows, public data, then a brief people can send to government.
Government duty ledger
This ledger turns the mission into a government work plan: disclose hidden market facts, scrutinize bottlenecks, investigate public harm, and publish reusable evidence.
Public duty route
Evidence moves from data gaps to public obligations.
When public records do not show firm shares or local control, government should require disclosure before people are asked to trust the market.
Published HHI at or above 2,500 should trigger harder questions about switching costs, entry barriers, platform leverage, and whether choice exists in practice.
The action docket turns market evidence into public questions agencies, legislatures, and local officials can inspect.
Every public ask should carry citations, dates, confidence labels, and open data routes so others can challenge or reuse the evidence.
Public action docket
The docket keeps the mission operational: identify where concentrated power harms people, show what evidence is public, name the agency lane, and make the next ask inspectable.
7
markets meeting the published structural review screen
1
markets where concentration or trend signals need continuing pressure
4
markets where the public record is too thin for firm-level accountability
4
profiles where public evidence must be disclosed before claims harden
Evidence-to-action route
Choose the stage that matches the public decision, then inspect the ranked market docket below.
Evidence question
What can the public record prove today?Publish firm-level shares, ownership/control links, and market-definition notes before public agencies rely on private estimates.
Public harm
Patients, pharmacies, and payers
Middlemen can narrow access, reimbursement, and medicine affordability while firm-level shares stay hidden.
Government lever
FTC/HHS transparency order
Require auditable firm-level shares and outcome data tied to patient and pharmacy choice.
Evidence pressure: Public data gap
Test whether the dominant firm controls access, switching, pricing, defaults, distribution, or other chokepoints that weaken consumer choice.
Public harm
Users, publishers, and small businesses
Defaults, distribution control, and data lock-in can make switching technically possible but practically weak.
Government lever
FTC/DOJ conduct review
Test defaults, exclusionary distribution, data access, and interoperability remedies against public outcomes.
Evidence pressure: HHI 7,359
Test whether the dominant firm controls access, switching, pricing, defaults, distribution, or other chokepoints that weaken consumer choice.
Public harm
Users, publishers, and small businesses
Defaults, distribution control, and data lock-in can make switching technically possible but practically weak.
Government lever
FTC/DOJ conduct review
Test defaults, exclusionary distribution, data access, and interoperability remedies against public outcomes.
Evidence pressure: HHI 5,337
Test whether the dominant firm controls access, switching, pricing, defaults, distribution, or other chokepoints that weaken consumer choice.
Public harm
Users, publishers, and small businesses
Defaults, distribution control, and data lock-in can make switching technically possible but practically weak.
Government lever
FTC/DOJ conduct review
Test defaults, exclusionary distribution, data access, and interoperability remedies against public outcomes.
Evidence pressure: HHI 4,995
Test whether the dominant firm controls access, switching, pricing, defaults, distribution, or other chokepoints that weaken consumer choice.
Public harm
Users, publishers, and small businesses
Defaults, distribution control, and data lock-in can make switching technically possible but practically weak.
Government lever
FTC/DOJ conduct review
Test defaults, exclusionary distribution, data access, and interoperability remedies against public outcomes.
Evidence pressure: HHI 4,804
Gatekeeper review
Healthcare middlemen can control access, pricing, reimbursement, and data while public records disclose only partial aggregate facts. That is an advocacy problem as much as a data problem.
Market in focus
PBMs
Public data gap
Require disclosure of individual firm-level shares where middlemen control access.
Public aggregate shares from agency findings.
Explicit HHI withholding where individual firm shares are not public.
Source-backed notes on what data would be required for a stronger concentration screen.
Require disclosure of individual firm-level shares where middlemen control access.
Tie oversight to patient, pharmacy, and payer outcomes.
Stop letting aggregate public facts substitute for auditable market tables.
Public aggregate shares from agency findings.
Explicit HHI withholding where individual firm shares are not public.
Source-backed notes on what data would be required for a stronger concentration screen.
Require disclosure of individual firm-level shares where middlemen control access.
Tie oversight to patient, pharmacy, and payer outcomes.
Stop letting aggregate public facts substitute for auditable market tables.
Action packet
Target market
PBMs
Public signal
Public data gap
Government ask
Require disclosure of individual firm-level shares where middlemen control access.
Evidence route
high confidence · incomplete · Firm-level shares and local ownership/control data
Packet completion
Needs public data
3/6 checks ready
Markets where concentration signals, data gaps, or public harm narratives deserve fast public review.
7
Immediate
4
Evidence build
4
Data gaps
Select a screened market and audience. The builder creates a short public comment scaffold with the signal, source posture, data gap, and government ask kept together.
Market
define scope
Evidence
source trail
Ask
government duty
Action
public packet
Evidence route
HHI
withheld
Public data gap
CR4
not public
four-firm share
Top firm
not public
single-firm share
Review lane
Evidence build
screening classification
Citable line
PBMs: Public data gap; CR4 not public; top-firm share not public; high confidence; incomplete.
Screened market
Audience
Submission route
0/3 core metrics; request disclosure before making a concentration claim
Scope
Health care
United States
Government target
Federal
open a public competition inquiry
Source posture
high confidence
incomplete
Generated packet
To: DOJ, FTC, and sector regulators Subject: Public competition evidence request for PBMs Antitrust Radar flags PBMs as evidence build because the public signal is Public data gap. The current public record shows HHI withheld, CR4 not public, and top-firm share not public. Public ask: Publish firm-level shares, ownership/control links, and market-definition notes before public agencies rely on private estimates. Recommended action: open a public competition inquiry. Require the evidence needed to make this market inspectable: Firm-level shares and local ownership/control data Source posture: high confidence; incomplete. This packet is public education and advocacy research, not legal advice.
Audience
DOJ, FTC, and sector regulators
open a public competition inquiry
Signal
Public data gap
Evidence build · high confidence
Evidence need
Firm-level shares and local ownership/control data
high confidence; incomplete
Guardrail
Public education
Review sources and rules before external submission.
Copy the public comment, cite the market signal, open the API route, or seed a notebook with the same selected market.
Notebook starter
const profile = await fetch("/api/public/markets?market=us-pharmacy-benefit-management").then((response) => response.json());
const observations = await fetch("/api/public/observations?market=us-pharmacy-benefit-management").then((response) => response.json());
const sources = await fetch("/api/public/sources?market=us-pharmacy-benefit-management").then((response) => response.json());
console.table(profile.rows);
console.table(observations.rows);
console.table(sources.rows);This is a public education scaffold for advocacy work. Review sources and jurisdiction-specific rules before submitting anything externally.
Policy pressure starts with citations, data status, confidence labels, and market-definition limits.
Open sourcesHHI, CR4, and top-firm share are screens. They are strongest when readers can see what was included and what was withheld.
Review methodsReports should name the data needed, the competition concern, and the public agency or process that can respond.
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Antitrust Radar publishes public education and advocacy research. It does not provide legal advice.