In a response to the consultation, Maverick Advocaten made propositions for a more effective review of concentrations in healthcare by the Dutch Authority for Consumers and Markets (“ACM”):
1. choose a voluntary notice-regime, similar to the regime in place in the United Kingdom
2. implement more efficient thresholds when extending the decree that lowers the thresholds regarding concentrations in the healthcare sector.
Both propositions assure that ACM will not be missing out on reviewing concentrations in healthcare, but at the same time will enable ACM to limit its focus to those concentrations that are relevant for competition in the healthcare sector. This will not only decrease the administrative burden on healthcare providers alone; ACM will free up some of its capacity, with which it will be able to maximise its efficiency in reviewing concentrations in healthcare sector that pose a threat to competition in that sector.