Comments to States and Other Organizations — Index of DOJ Antitrust Division Submissions to State Legislatures, Agencies, and Standards Bodies (2015–2025)
Summary
The DOJ Antitrust Division maintains a public index of formal comments submitted to state legislatures, state agencies, standards bodies, and other organizations from 2015 through 2025. Topics include certificate-of-need (CON) laws, healthcare mergers, insurance acquisitions, legal scope-of-practice, real estate regulation, electric utility infrastructure, craft brewing distribution, and credit rating oversight. Most submissions are joint with the FTC. This page does not itself impose obligations but documents regulatory positions that state bodies may rely upon.
Companies operating in states with certificate-of-need laws, or pursuing healthcare transactions involving health insurers or hospital systems, should review the joint FTC/DOJ positions on those matters — the agencies have repeatedly signalled that CON laws raise competitive concerns and scrutinize related transactions. Entities in states where the DOJ has commented on real estate agent compensation, legal scope of practice, or insurance consolidation should treat those comments as indicators of federal enforcement posture for analogous situations.
What changed
The DOJ Antitrust Division publishes an index of its formal comments to state-level entities spanning a decade of activity. The submissions address antitrust implications of state-level legislation and regulation across multiple sectors including healthcare (certificate-of-need laws, health insurance mergers), legal services (scope of practice, unauthorized practice of law), real estate (agent compensation), energy (electric grid infrastructure), and credit ratings (S&P Global). Most comments are filed jointly with the FTC, signalling consistent federal-state enforcement coordination.
State legislators, regulators, and affected businesses should monitor these positions when drafting or complying with similar legislation. The DOJ's consistent opposition to certificate-of-need laws, expressed across Alaska, South Carolina, Tennessee, and Virginia, signals likely scrutiny of similar healthcare restrictions in other states. The joint FTC/DOJ comment on the Louisiana health insurer acquisition underscores federal attention to insurance consolidation. Comments on legal scope-of-practice matters indicate antitrust oversight extends beyond traditional commercial sectors.
Archived snapshot
Apr 20, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Comments to States and Other Organizations
Share This page provides information on:
- Alaska State Legislature
- Alaska State Senate
- American National Standards Institute
- California State Assembly
- Canada Ministry of Innovation, Science, and Industry
- Iowa House of Representatives
- Kansas Real Estate Commission
- Louisiana Department of Insurance
- Maryland House of Delegates
- Massachusetts House of Representatives
- Michigan Senate
- Nebraska Legislature
- North Carolina General Assembly
- North Carolina Senate
- Puerto Rico House of Representatives
- South Carolina Governor's Office
- S&P Global Ratings
- Tennessee House of Representatives
- Texas House of Representative
- Virginia Certificate of Public Need Work Group
Virginia House of Delegates
Related pages:
Alaska State Legislature
Proposed Repeal of Alaska’s Certificate-of-Need Laws (May 3, 2023)
Alaska State Senate
American National Standards Institute
Comments on the U.S. Standards Strategy (September 8, 2020)
Comments on Sample Patent Letter of Assurance Form (October 11, 2018)
Comments on ANSI Executive Standards Council Summary Decision (March 7, 2018)
California State Assembly
Comments on AB 690, Legal Document Assistants and Unlawful Detainer Assistants (June 13, 2023)
Comments on AB 1541, California's Craft Brewing Industry (March 20, 2020)
Comments on the Proposed Regulation of Court Reporting in California (August 26, 2016)
Canada Ministry of Innovation, Science, and Industry
Joint letter from AAG Kanter and Chair Khan to Canada Ministry of Innovation, Science, and Industry (March 31, 2023)
Iowa House of Representatives
Comments On Iowa Senate Study Bill 1113 Addressing the Construction of New Power Grid Infrastructure (March 24, 2025)
Kansas Real Estate Commission
Louisiana Department of Insurance
Maryland House of Delegates
Comments on Maryland House Bill 857 (September 10, 2018)
Massachusetts House of Representatives
Comments on H.B. 1973, Regarding Glaucoma Care by Optometrists (February 18, 2016)
Michigan Senate
Comments on Michigan Senate Bill 753 (H-1) Addressing Telehealth Services (November 29, 2016)
Nebraska Legislature
North Carolina General Assembly
Comments on the North Carolina Justice for All Project Policy Recommendations (February 14, 2023)
North Carolina Senate
Comments on North Carolina House Bill 436 Regarding the Scope of Practice of Law (June 10, 2016)
Puerto Rico House of Representatives
Comments on S.B. 8991, Regarding Pharmacological Care by Optometrists (May 18, 2016)
South Carolina Governor's Office
Joint Statement of the Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice on Certificate-of-Need Laws and South Carolina House Bill 3250 (January 11, 2016)
S&P Global Ratings
Comments of the Antitrust Division of the United States Department of Justice Before S&P Global Inc. (August 15, 2023)
Comments of the Antitrust Division of the United States Department of Justice Before S&P Global Inc. (April 29, 2022)
Tennessee House of Representatives
Texas House of Representatives
Comments on Texas House Bill 3995 (April 19, 2019)
Virginia Certificate of Public Need Work Group
Joint Statement of the Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice to the Virginia Certificate of Public Need Work Group (October 26, 2015)
Virginia House of Delegates
Comments on Maintenance of Certification Requirements for Physicians (October 22, 2019)
Updated January 2, 2026
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