FTC Section 5 Scrutiny Active

EHR Ecosystem Lock-in & Antitrust Probe Analyzer

1. Topology & Market Power
PARAMS
EHR Market Dominance Tier 48% US Acute
Third-Party API Tariff ($/query) $0.18
Proprietary CDA Lock-in Intensity 85% Proprietary
FTC Remediation Interventions
2. Clinical Interoperability Topology & Friction Stream
STATUS: RESTRICTED
Data Stream:
Central Academic Medical Center (Epic Hyperspace)
Host Node • 1,450 Beds • High-throughput internal Care Everywhere ring
Primary Anchor
Estimated Switching Barrier
$84.5M
Timeline: ~26 Months + ETL
Annual Interop Tariffs
$2.14M
App Orchard & Query Tolls
Federation Query Latency
4.24s
CDA ETL Transformation Delay
3. FTC Antitrust Risk Diagnostic
REGULATORY
Aggregate Monopolization Index 88.4 / 100
Contestable Market Unfair Competition Severe Lock-in
Product Tying & Self-Preferencing Sherman Act § 2
Core EHR contracts implicitly condition favorable interoperability rates on adopting proprietary analytics (Cosmos) and patient portal modules, foreclosing standalone niche vendors.
Information Blocking & Artificial Delays 21st Cures Act / ONC
Bulk patient data exports are funneled through proprietary CDA schemas with synthetic rate limits (latency >4.0s), impeding fluid portability to competing hospital networks.
Unreasonable API Access Surcharges FTC Act § 5
Imposition of $0.18/query surcharges and App Orchard revenue-sharing tolls constitutes unfair methods of competition by taxing third-party diagnostic software developers.
Federated Network Disincentives TEFCA Framework
Care Everywhere operates as a gated private network advantage; non-Epic Qualified Health Information Networks (QHINs) face technical friction and asymmetric directory routing.
Executive Briefing Summary Baseline Risk
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