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Approximately 73 million Americans with commercial health insurance, or approximately 22% of the population with commercial insurance, live in highly concentrated markets. According to Federal antitrust guidelines, markets that exceed Herfindahl-Hirschman Indices (HHIs) of 2,500 points are “highly concentrated” and lack adequate health insurer competition. HHI is a measure of the size of firms in relation to the industry; it measures market concentration and is an indicator of the amount of competition among firms. As a result of having commercial health insurance while living in highly concentrating markets, this population faces limited options when it comes to health . . .

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