Healthcare Mergers: An Emerging Crisis

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Advocates of the president’s health care reform package have expressed alarm over a wave of mergers spurred by the new law.

Johns Hopkins Medicine, for instance, is snapping up hospitals in the Washington, D.C.-area, a move it describes as “driven largely by health care reform, which demands an integrated regional network.”

Johns Hopkins is not alone. Many established actors in the health care industry – including insurers, brokers and providers – are searching for ways to increase their market clout.

That’s bad news for ordinary patients, who will be forced to pay ever more for their care as the level of competition in the health care marketplace dwindles.

It’s easy to see why competition drives down costs. When insurers or health care providers have to battle one another to attract customers, they must differentiate themselves by charging lower prices or providing better service.

But if an insurer dominates a marketplace, it can raise prices and lower service standards with impunity.

Many insurers and providers are already taking steps to limit competition. Consider ‘most favored nation’ (MFN) clauses, which insurers use to prohibit hospitals or doctors from charging competitors less. Insurers claim that these discounts are necessary to help them secure the best possible deal.

Unfortunately, it’s the “best possible deal” for the insurer — not ordinary patients. The ‘low’ prices included in these MFN clauses are often based on artificially high price quotes from the provider. In some cases, insurers have actually agreed to increase what they’ll pay so long as other insurers are forced to pay even more.

Patients, of course, lose. The favored insurer passes along artificial cost increases directly to their customers, while disadvantaged competitors have to charge even higher premiums to continue offering access to offending providers. Many insurers simply exit a market once a rival negotiates an MFN.

Such an exit can be disastrous. According to an American Medical Association study, two or fewer health insurers control more than 70 percent of the market in 24 states. And if a competitor is foolhardy enough to try to work around an MFN, then the dominant insurer can simply force its rival out of the market.

A case in point is TheraMatrix, a small Michigan company. In 2005, TheraMatrix contracted with Ford Motor Co. to provide physical therapy services to its employees. TheraMatrix cut Ford’s costs by nearly half – saving the company millions of dollars. Last year, Ford expanded the program to cover 390,000 employees and retirees nationwide.

Everyone was happy – except Blue Cross Blue Shield of Michigan (BCBSM), which handled the administrative side of Ford’s insurance plan.

As TheraMatrix added other automakers to its customer base, BCBSM dropped the company from its medical provider network, which covers most Michiganians. BCBSM also threatened to revoke its other customers’ hospital discounts if they carved out their physical therapy benefits and contracted with TheraMatrix to provide them.

Blue Cross wrote that TheraMatrix’s operations were “competitive and damaging not only to BCBSM’s financial interests, but also to its business relationships.”

In other words, BCBSM would not allow its customers to shop around for better deals. And it would try to bully TheraMatrix out of business.

Such anti-competitive behavior harms employers and patients alike. Further consolidation of insurers and providers could make things worse.

Over the last 10 years, employer-provided health insurance premiums have more than doubled. Premiums for the most popular employer-provided plans are projected to increase by another 10 percent next year.

If businesses are to stop runaway medical costs, they’ll have to take control of their benefits. They can do so with the help of a new business strategy: ‘Healthcare Performance Management’ (HPM).

HPM uses powerful software to show companies where their health plan dollars are going, and where opportunities for savings exist.

For instance, HPM analysis of employee medical and prescription claims data might show that a company is spending too much on brand-name prescription drugs and that alternatives like generics could help it save millions.

Unsurprisingly, insurers don’t want to share this data with businesses. After all, if a company can’t pinpoint exactly how it’s spending its health dollars, it will be less likely to question premium hikes. Nor will it be able to find efficiencies, as Ford did, by cutting the insurer middleman out of the equation.

In many parts of the country, big health insurers have enjoyed virtual monopolies. Unburdened by real competition, they’ve abused their powers while businesses and their employees footed the bill.

HPM empowers businesses to inject competition into the healthcare marketplace and fight back against decades of cost increases. Employers should take advantage.

Additional Information

In addition to the invaluable insights George shares in this StrategyDriven Editorial Perspective article are the resources accessible from his website, www.HPMInstitute.org.   George can be reached at [email protected].

Final Request…

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About the Author

George Pantos is Executive Director of the Healthcare Performance Management Institute, a research and education organization dedicated to promoting the use of business technology and management principles that deliver better and more cost-effective healthcare benefits for employers who provide health insurance coverage for employees and their dependents. To read George’s full biography, click here.

StrategyDriven Editorial Perspective – Hiring Uncertainties

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The extension of Bush-era tax breaks, healthcare reform and an increase in the rate of hiring in November suggests that the economy is gaining momentum. Unfortunately, few expect a change in the 9.6 percent unemployment rate. Yet despite this constant, many economists are optimistic about the Nation’s hiring forecast.

Two pillars of the economy – jobs and consumer spending – appear to be on the upswing. Factories are producing, auto sales are rising and new businesses pop up daily. Also, applications for initial unemployment benefits hit a two year low in November and 151,000 new jobs were created.

Job creation does not necessarily correlate with lowering the unemployment rate. According to analysts, the economy would need to consistently add 200,000-300,000 jobs a month to make a noticeable dent in the unemployment rate. Despite the job creation shortfall, the economy is moving in the right direction. Economists predict that the United States economy will grow at a three percent pace in the October-December quarter, up from a two and a half percent growth rate in the July-September quarter.

Will the steady increase in the economy translate into a positive hiring forecast? The results are mixed. The increase in private sector jobs suggests that retail and factory jobs will continue to climb. The same cannot be said for small businesses, mainly due to uncertain tax future many businesses face.

The issue at the heart of this uncertainty involves limited access to capital at a time when banks are reluctant to lend. Taxes further hinder these businesses’ ability to produce. If a business owner has to pay higher taxes on net earnings, the business is much less available to do other things needed to contribute to the economy such as hire employees, buy equipment and expand. Many small business owners seek long term tax strategies rather than year-by-year decisions that make planning for the future of their business impossible.

Recent healthcare reform is also adding to economic uncertainty for small businesses. Many of the provisions of the sweeping health-care bill passed by the House of Representatives in March won’t kick in until 2014, however these provisions spell big changes for small businesses.

By no later than 2014, states will have to set up Small Business Health Options Programs, or “SHOP Exchanges,” where small businesses will be able to pool together to buy insurance. Businesses with more than 50 employees will be required to either offer healthcare coverage or pay a penalty of $750 a year per full-time worker. Part-time employees would be counted toward the 50-employee minimum on pro-rated basis based on hours worked, bringing more small businesses into the group required to provide coverage.

This clearly effects hiring as many small businesses have been able to exclude part time employees from healthcare benefits and from its total number of employees. However, the proposed reforms could help spur entrepreneurial activity by increasing the incentives for talented Americans to launch their own companies, and could increase the pool of workers willing to work at small firms. Further, successful reform would reduce the phenomenon of ‘job lock,’ in which workers are reluctant to leave a job with employer-sponsored health insurance out of fear that they will not be able to find affordable coverage.

As both the future of business tax as well as healthcare reform are uncertain, the countries hiring forecast is foggy. However, both private sector jobs and consumer spending have risen creating an optimistic attitude among economic analysts for our country’s economic future. New healthcare laws also suggest a possible increase in entrepreneurial activity, thus creating more jobs, hopefully creating a positive hiring trend.

About the Author

As CEO of MyCorporation Business Services, Inc. (www.MyCorporation.com), Deborah Sweeney is an advocate for protecting personal and business assets for all consumers. With experience in the field of corporate and intellectual property law, Deborah provides insightful commentary on the benefits, barriers and who should consider incorporation and trademark registration.

Deborah joined MyCorporation in 2003 after serving as outside general counsel for 5 years. She received her Juris Doctor and Masters in Business Administration degrees from Pepperdine University and is a member of the American Bar Association.

Deborah served as an adjunct professor at the University of West Los Angeles and San Fernando School of Law in the area of corporate and intellectual property law. Because of her extensive knowledge, Deborah has long served as a speaker and panelist on legal issues affecting new to the world and growing businesses.

StrategyDriven Editorial Perspective – Job Killers

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With the elections over and unemployment reaching 9.8 percent, we once again see politics shifting into high gear as the posturing and power grabs in Washington D.C. continue to prevent the creation of marketplace certainty needed before business leaders begin to create new jobs. In our closing commentary for 2010, Perspectives reflects on the several pending and enacted pieces of legislation that continue to plague the job market and have the potential to do so for the foreseeable future.

Expiration of the Bush Tax Cuts – regardless of your position on whether the Bush tax cuts should be allowed to expire or extended in part or in whole, two things are certain – our leaders are in a deadlock split over what action to take and without action the tax rate for all individuals will rise on January 1, 2011. This uncertainty is clearly unnecessary and should have been avoided. Democrats bent of pushing through healthcare, financial, and carbon reforms should have moved on this issue as a priority as it is the only one of these issues with a deadline; though all are bad for the U.S. economy. According to Deloitte Tax LLP, the following impacts will be realized if the Bush Tax Cuts are allowed to expire:

  • A typical family of four with a household income of $50,000 a year would have to pay $2,900 more in taxes in 2011
  • The same family making $100,000 a year would see its taxes rise by $4,500
  • Wealthier families of four making $500,000 a year would pay $10,800 more in taxes
  • A family making $1 million a year would get a tax increase of $53,2001

Net Result: higher taxes reduce disposable income; resulting in less spending and slower economic growth

Healthcare Reform – with several hundred new regulations and standards not yet defined, the cost of Obamacare remains unknown. However, as Perspectives addressed in You Don’t Get Something for Nothing, the added benefit requirements mandated by the Obamacare legislation have to be paid for by someone; whether those payers are businesses, individuals, or some combination of the two. In fact, the Wall Street Journal reported that healthcare insurers Aetna, some BlueCross Blue Shield plans and other smaller carriers are seeking premium increase between 1 – 9 percent to cover the extra benefits mandated by healthcare reform.2

A report by Senators Coburn M.D. (R-OK) and Barrasso M.D. (R-WY) finds Obamacare as having the following impacts:

  • New penalties and costs discourages the hiring of American employees
  • The law will eliminate about 800,000 jobs; possibly more
  • Real income will be depressed for millions of Americans
  • Employers are struggling with rising health care costs that are increasing more quickly because of the new law3

Net Result: labor costs increase and/or disposable incomes decrease; resulting in fewer jobs as employers hire less and outsource more and reduced consumer spending – both driving slower, if not negative, economic growth

Grim Diagnosis, A check-up on the federal health law, can be downloaded by clicking here.

No Federal Budget – by law, the Congress of the United States is to develop and pass a budget for the coming fiscal year by April 15. Not unlike most years since the law was enacted, Congress has failed to meet this obligation; thereby failing to signal market participants as to how and when the economy’s single largest consumer will spend its money.

Net Result: uncertainty as to the government’s coming year spending heightens employer risk to maintaining and expanding business operations; depressing workforce retention and expansion as well as research and development and other growth projects.

Carbon Legislation – passed by the U.S. House of Representatives and stalled in the Senate, carbon legislation that would assign fees to carbon producing business activities, namely energy generation, looms as an uncertain and daunting risk of increased energy cost. If passed, this legislation would increase energy costs for all consumers; raising personal and business energy consumption expenditures.

A study by the Heritage Foundation of carbon legislation proposed by Representatives Waxman (D-CA) and Markey (D-MA) revealed the following potential economic impacts of this legislation as being:

  • Elimination of 1,145,000 jobs on average, with peak year unemployment increases of over 2,479,000 jobs
  • Increased electric rates of 90 percent after adjusting for inflation
  • Heightened, inflation-adjusted gasoline prices by 58 percent
  • Raised residential natural gas prices by 55 percent
  • Increased energy bills for the average American family of $1,241 per year4

Net Result: increased energy costs will add to the costs of every product and services produced within the United States and increase residential heating, cooling, general living, and transportation costs; reducing consumer’s disposable income and subsequently their spending which will slow economic growth if not shrinking the overall economy.

StrategyDriven Recommended Practices

Individually any one of these items damages the U.S. economy; taken together, Perspectives believes they crush any hope for a near-term economic recovery and may even bring about the return of the economist defined recessionary conditions. The combination of these four unnecessary uncertainties results in:

  • prolonged high unemployment rates
  • sustained lower consumer spending
  • perpetuated hording of cash by individuals and businesses
  • continued slow economic growth with the possibility of reentering recessionary conditions

To protect ones company from these unnecessary risks, StrategyDriven recommends business leaders consider the following options:

  • Eliminating, streamlining, and outsourcing all processes and activities. The goal is to reduce headcount in order to avoid the potential costs associated with the new healthcare legislation and reduce the energy needed to produce the company’s goods and services to avoid the impacts of the proposed carbon tax. Additionally, more efficient processes increase the organization’s supply flexibility in response to market demand allowing for a reduction in inventory levels. In the case of outsourcing, those functions not absolutely required to be performed within the United States should be transferred to overseas providers.
  • Increasing employment of temporary staff. The goal is to minimize the company’s commitment to a higher number of full-time staff members that necessarily brings with it the elevated entitlement costs associated with Obamacare. A clearly defined return on investment should be identified prior to hiring any additional full-time staff.
  • Relocating operations to another country not as heavily burdened with taxes and other mandates. The goal is to reduce non-value adding payments required by the government. Consideration must be given to other added costs such as transportation and importation taxes when evaluating whether or not to relocate.
  • Limiting production and inventory levels. The goal is to reduce labor and energy consumption to avoid costs while at the same time preparing for the probable decline in the demand for goods that would result in slower inventory turns and subsequently higher inventories and warehousing costs should current production rates be maintained.
  • Expanding the organization’s cash reserves. The goal is to prepare the company for the heightened expenses that will be incurred as a result of Obamacare and the potential carbon tax as well as the reduction in revenues that will likely result from the expiration of the Bush Tax Cuts.

Final Thought…

Perspectives acknowledges that our recommendations include provisions that would result in fewer American jobs. We believe these recommendations are sound.

Perspectives believes the Obama Administration and Democrat controlled Congress passage of Obamacare, desire to rescind portions of the Bush Tax Cuts, proposed carbon tax legislation, and failure to pass a Federal budget is devastatingly harmful to the American economy. We believe business leaders have a responsibility to their company’s shareholders to maximize their return on investment and that the legislative initiatives discussed drive leaders to transfer operations overseas. Therefore, it is our opinion that the Obama Administration and Democrat Congressional Leaders are culpable for the ongoing unnecessary uncertainty preventing real economic recovery.

As always, we’ve provided our perspective and hope you’ll share your thoughts, lessons learned, and recommended resources with us and the StrategyDriven audience.

Final Request…

StrategyDriven Editorial Perspective PodcastThe strength in our community grows with the additional insights brought by our expanding member base. Please consider rating us and sharing your perspectives regarding the StrategyDriven Editorial Perspective podcast on iTunes by clicking here. Sharing your thoughts improves our ranking and helps us attract new listeners which, in turn, helps us grow our community.

Thank you again for listening to the StrategyDriven Editorial Perspective podcast!

Sources

  1. “Expiring tax cuts hit taxpayers at every level,” Stephen Ohlemacher, Associated Press, September 16, 2010
  2. “Health Insurers Plan Hikes,” Janet Adamy, The Wall Street Journal, September 7, 2010 (http://online.wsj.com/article/SB10001424052748703720004575478200948908976.html)
  3. “Senate Physicians Conclude Health Law a ‘Grim Diagnosis’ for American Economy,” The Office of Senator Tom Coburn M.D., October 25, 2010 (http://healthreformreport.com/2010/10/3rd-congressional-district-in-profile-democratic-incumbent-titus-focuses-on-those-who-lost-jobs-face.php)
  4. “Son of Waxman-Markey: More Politics Makes for a More Costly Bill,” William Beach, Ben Lieberman, Karen Campbell, Ph.D., and David Kreutzer, Ph.D., The Heritage Foundation, May 18, 2009 (http://www.heritage.org/Research/Reports/2009/05/Son-of-Waxman-Markey-More-Politics-Makes-for-a-More-Costly-Bill)

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StrategyDriven Editorial Perspective – Expanding Uncertainty in the U.S. Financial Sector, part 5

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The Dodd-Frank Wall Street Reform and Consumer Protection Act represents the most sweeping change in the regulation of the U.S. financial industry in over half a century. Contained with the act are 243 new rules that will be developed by 11 different government agencies1; fundamentally reshaping how business is done at financial and non-financial institutions. But do these regulations treat businesses fairly and equitably or do they establish an unfair environment that favors a select few?

StrategyDriven believes the answer to this question is the latter. Not only does the Dodd-Frank Act create an unfair advantage for some businesses, the advantages provided favor those companies responsible for the meltdown of the U.S. financial system.

The financial reform act directs absolute rather than scaled coverage in its implementation. Subsequently, small institutions will be subjected to the same regulatory rules as larger ones and those ‘too big to fail’ institutions responsible for our financial marketplace challenges. While the various audits and forms will inevitably have fewer $000s, the cost to perform these reviews and compile and submit these documents will be roughly the same. For small financial institutions, the high cost of compliance will be passed on to a relatively smaller customer base causing a disproportionally high increase their customers’ fees which will in-turn drive these individuals to the ‘too big to fail’ institutions… the very same institutions whose poor performance necessitated the legislation in the first place.

“Small banks, forced to use their limited resources to comply with burdensome new reporting requirements, will suffer, as will the communities they serve.” 2
 
Bob Corker
United States Senator – Tennessee (R)

StrategyDriven Recommended Practices

StrategyDriven believes the Dodd-Frank Act unduly penalizes small financial institutions not responsible for the financial meltdown of 2008. The full scope of the marketplace imbalance created will take years to be understood as the final details of the many new regulations will not be defined anytime soon. Thus, company leaders must remain vigilant in order to mitigate, transfer, or eliminate the evolving financial industry risks and costs facing their organizations. In this specific case, StrategyDriven suggests company leaders consider the following:

  • Follow the FDIC’s rule making process and understand how these new regulations are impacting financial institution partners; focusing on the changing costs of doing business with these organizations particularly if they are relatively small.
  • Consider whether the relatively higher cost associated with doing business with smaller banks is warranted given other beneficial factors such as community good will.
  • Provide financial advisory programs to employees; ensuring they are apprised of the costs and benefits of maintaining a relationship with both small and large financial institutions.

As always, we’ll provide our thoughts on how business leaders can best prepare for the implementation of the financial reform law and weather the storm in the long-term. We also hope you’ll share your thoughts, lessons learned, and recommended resources with us and the StrategyDriven audience.

Final Request…

StrategyDriven Editorial Perspective PodcastThe strength in our community grows with the additional insights brought by our expanding member base. Please consider rating us and sharing your perspectives regarding the StrategyDriven Editorial Perspective podcast on iTunes by clicking here. Sharing your thoughts improves our ranking and helps us attract new listeners which, in turn, helps us grow our community.

Thank you again for listening to the StrategyDriven Editorial Perspective podcast!

Sources

  1. “Summary of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Enacted into Law on July 21, 2010,” Davis Polk & Wardwell LLP, July 21, 2010 (http://www.davispolk.com/files/Publication/efb94428-9911-4472-b5dd-006e9c6185bb/Presentation/PublicationAttachment/efd835f6-2014-4a48-832d-00aa2a4e3fdd/070910_Financial_Reform_Summary.pdf)
  2. “Financial overhaul places regulatory burden on community banks,” Cumberland Business Journal, August 2, 2010 (http://ucbjournal.com/news.php?id=95)

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StrategyDriven Editorial Perspective – Expanding Uncertainty in the U.S. Financial Sector, part 4

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From the outset of the financial collapse of 2008, it was apparent that the troubles of large financial institutions such as Fannie Mae, Freddie Mac, Lehman Brothers, and AIG could and did profoundly impact all aspects of the American financial system. Given their sheer size, such firms represent a ‘systemic risk’ to the whole economy and were subsequently labeled as ‘too big to fail;’ suggesting not that these firms couldn’t fail but that they should not be allowed to fail because of the risk posed to the U.S. economy.

The ‘too big to fail’ philosophy found a home in the Dodd-Frank Wall Street Reform and Consumer Protection Act. This act provides the Federal Deposit Insurance Corporation (FDIC) with the power to seize and break up ‘too big to fail’ companies if it believes they are headed toward financial collapse.1 The FDIC’s authority covers non-financial corporations with at least $50 billion in assets as well as financial institutions. While this may sound like a reasonable solution to the ‘too big to fail’ problem, it only serves to make matters worse.

“One of the highest priorities is identifying the universe of non-bank financial companies that – because of their leverage; off-balance sheet exposures; nature, scope, size, scale, concentration, interconnectedness, and mix of activities; or other factors identified in the Dodd-Frank Act – should be subject to enhanced prudential supervision by the FRB.” 2
 
Sheila C. Bair
Chairman, Federal Deposit Insurance Corporation
on Systemically Important Institutions and the Issue of “Too Big to Fail” before the Financial Crisis Inquiry Commission
September 2, 2010

The ‘too big to fail’ provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act will not prevent companies systemically linked to the health of the U.S. economy from collapsing and in several ways promotes conditions that will exacerbate the next financial downturn. Consider:

  1. the Dodd-Frank Act does nothing to prevent companies from failing, it only prescribes a method for dealing with them once failure becomes eminent
  2. it places Washington bureaucrats in charge of dispositioning troubled companies; the same individuals who are often unable to balance the U.S. government’s budget, can’t tell citizens and businesses what the tax rates for 2011 will be three months in advance, and have compliance issues with respect to paying their personal income taxes
  3. by directing the dismantlement of large companies, fewer such large companies within the given sector will remain effectively increasing the impact their future collapse will have on the nation’s economy should such a collapse occur
  4. by providing a government supported collapse mechanism the financial risk associated with large companies is reduced which in turn will help them secure lower interest rates on borrowed funds and encourage further risk taking3

While the Dodd-Frank Wall Street Reform and Consumer Protection Act seeks to minimize the impact of the collapse of a ‘too big to fail’ company on the U.S. economy, it’s mechanism of corporate dismantlement and risk removal leaves the door open to even more impactful collapses in the future. As such, the solution provided addresses only half the issue. What the act missed is the prevention of a systemically linked company’s collapse to being with or, dare we suggest, the elimination of ‘too big to fail’ companies all together in a non-crisis setting.

StrategyDriven Recommended Practices

The significant marketplace uncertainty created by the Dodd-Frank Act will not likely be resolved soon; necessitating that company leaders act to mitigate, transfer, or eliminate these risks facing their organizations. In this specific case, StrategyDriven suggests company leaders consider the following:

  • Follow the FDIC’s ‘too big to fail’ rule making process and understand how these new regulations will impact the operations of your firm’s ‘too big to fail’ partners, suppliers, and customers.
  • Evaluate the financial position of those ‘too big to fail’ companies providing resources or services to your organization and the impact of an FDIC takeover on continued operations; implementing compensatory measures as appropriate
  • Assess the financial position of those ‘too big to fail’ companies that are your clients and the potential impact an FDIC takeover would have on the demand for your products and/or services; implementing compensatory measures as appropriate
  • Analyze your company’s overall supplier and customer portfolio and ensure the risks associated with ‘too big to fail’ companies previously identified are mitigated to an appropriate extent through the use of portfolio balancing

Final Thought…

The somewhat ill-conceived ‘too big to fail’ provisions of the Dodd-Frank Act serve as a lesson in problem resolution. As noted earlier, the Dodd-Frank Act does nothing to mitigate, transfer, or alleviate the problem of ‘too big to fail’ companies actually succumbing to financial collapse thereby doing nothing to prevent the initiating event of the Financial Crisis of 2008. Additionally, provisions of the act create circumstances that may make it more likely for a financial collapse to occur in the future, one with even greater impact. Remember that to effectively resolve any issue it is important to first define the problem and its causes and then to define and select a solution set that fully addresses the defined problem and its causes. Additional information on sound decision-making practices can be found in StrategyDriven’s Decision-Making topic area.

In an upcoming edition of the StrategyDriven Editorial Perspective, we’ll look at the potential impacts of the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that could present a proportionately larger burden on small companies.

As always, we’ll provide our thoughts on how business leaders can best prepare for the implementation of the financial reform law and weather the storm in the long-term. We also hope you’ll share your thoughts, lessons learned, and recommended resources with us and the StrategyDriven audience.

Final Request…

StrategyDriven Editorial Perspective PodcastThe strength in our community grows with the additional insights brought by our expanding member base. Please consider rating us and sharing your perspectives regarding the StrategyDriven Editorial Perspective podcast on iTunes by clicking here. Sharing your thoughts improves our ranking and helps us attract new listeners which, in turn, helps us grow our community.

Thank you again for listening to the StrategyDriven Editorial Perspective podcast!

Sources

  1. “FDIC puts breaks on ‘too big to fail’ reforms,” Los Angeles Times, October 3, 2010
  2. “Statement of Sheila C. Bair, Chairman, Federal Deposit Insurance Corporation on Systemically Important Institutions and the Issue of “Too Big to Fail” before the Financial Crisis Inquiry Commission,” Sheila C. Bair, Federal Deposit Insurance Corporation, September 2, 2010 (http://fdic.gov/news/news/speeches/chairman/spsep0210.html)
  3. “What Does ‘Too Big to Fail’ Really Cost?” Alain Sherter, BNET, March 29, 2010 (http://www.bnet.com/blog/financial-business/what-does-8220too-big-to-fail-8221-really-cost/4486?tag=content;drawer-container)

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