USAP experience

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nolagas said:
Not at all. I think partnership track is fine and mommy-track jobs are fine too. What I mean by “make money off of them forever” is when you need another partner but you hire an associate because you can get away with paying someone less even though they do the same work or maybe more with no intention of ever treating the equally. If your division doesn’t do that then great, but there are definitely USAP practices that do.
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Of course not, but I can't speak for other divisions within USAP, as they all operate autonomously. Some offer Partner tracks, some don't. Some have a better track history of their associates making partners, while others have a more malignant reputation
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okayplayer said:
And what happens to your USAP stock if more practices sell to USAP, sethco? o_O
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I don't really care much about what happens to the stock. It makes up a small proportion of my portfolio. Stock price could go to zero and I wouldn't be affected much
 
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sethco said:
I don't really care much about what happens to the stock. It makes up a small proportion of my portfolio. Stock price could go to zero and I wouldn't be affected much
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Wow...so, and please correct me I am wrong here, but to be a shareholder of USAP there is a minimum amount of stock to hold. As not part of the buyout you are required to purchase this stock. This purchase price is greater than 100K out of your own pocket.

Now I don’t ever think the stock will go to zero and in fact I think it will appreciate. However it will appreciate much less for you than it did for your partners who sold as they got the stock at a lower price. It will also appreciate less for your partners who sold than say GHA as they paid a much higher price for stock than GHA. You get the point.

The reason I said wow is because you’ve paid another company more than 100K to take 20-40% of your billed revenue in perpetuity for your career-and you don’t care if it would drop to zero (again this won’t happen).

Wow-amazing, if other young Anesthesiologists think like you do USAP sure does have a reason to be excited
 
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A lot of this discussion is irrelevant. If you want a job in a particular location, USAP may be the best option in town. There may be a better small niche gig but you won’t know about them until you’re there for awhile.
 
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Howard888 said:
Wow...so, and please correct me I am wrong here, but to be a shareholder of USAP there is a minimum amount of stock to hold. As not part of the buyout you are required to purchase this stock. This purchase price is greater than 100K out of your own pocket.

Now I don’t ever think the stock will go to zero and in fact I think it will appreciate. However it will appreciate much less for you than it did for your partners who sold as they got the stock at a lower price. It will also appreciate less for your partners who sold than say GHA as they paid a much higher price for stock than GHA. You get the point.

The reason I said wow is because you’ve paid another company more than 100K to take 20-40% of your billed revenue in perpetuity for your career-and you don’t care if it would drop to zero (again this won’t happen).

Wow-amazing, if other young Anesthesiologists think like you do USAP sure does have a reason to be excited
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Maybe his 20-40% is 0ffset by the fact that USAP bills and collects at a much higher rate than before his group sold out. So in essence, it all balances out pay wise for him. I am just speculating here.
 
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CaliCatheter said:
Hey guys,

Any of you have experience with USAP buyouts? No need for details but was just wondering if among the takeovers, is USAP one of the least malignant?

thanks
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Partnership—Totally worth it. Wish we did it earlier.
Stock—100% worth it. Wish I had more (and i’ve already actually bought more).

Any group that was offered USAP partnership but signed with someone else (Envision, Mednex etc) did it for one thing only: $$$. With them you become a true faceless employee who does what they tell you to do.
USAP has a completely different business model.
1) they believe that for the business to make more money, you need to make MDs the owners, not employees. It works! When MDs make everyday decisions, they think of their $1,000,000 worth of USAP stock and how that decision is going affect the stock value. Think of succes of New Belgium brewery, same principle.
2) they are businessmen, who believe in order to succeed you need most of all to have a high quality product. That’s why quality is top priority with USAP. They have ASA top dogs as the partner, who keep push quality envelope ever father.
3) they understand that MDs could be ****y businessmen, but they are good in practicing medicine. So practice of medicine per se is left 100% to MDs.
4) their negotiating power is way greater than yours. No matter what your commercial contact rates are, their are better.
5) they have decades worth of experience building and running health care businesses. So suddenly, you are part of it. You almost feel like you “mom and pop” “lemonade stand gig” transforms into a well run slick business.
6) scale. How do you keep up with all government requirements, quality control, compliance, HIPPA, CDC, Medicare rules, billing, scheduling, recruiting, training, legal, financial, human resources, risk management? Do I need to say more? It’s taken care of with USAP, in a very cost effective way.
7) USAP stock. OMG. Is there any other equity I LOVE more? I can’t give you specifics, but let’s say you get amount $X as your buy out. Let’s say 25% is USAP stock, so it’s $0.25X. You say it’s worth nothing since you can’t sell (which is not true). Let me just say that we all wish that entire “buy out” was in stock and nothing in cash.
8) Some of you keep talking about stock price, and how stock market goes up and down. But you are forgetting 2 most important things about private stock: dividend it pays out and the fact that it’s price is strictly mathematical calculation based on earnings. USAP earnings are GOOD. I am leaving you wandering on how much dividend it may already payed and will pay in years to come. I am leaving you wandering on how many times from original price the stock is worth today. But let’s just say that I can’t hide my smile as I type this.
 
gasier said:
Partnership—Totally worth it. Wish we did it earlier.
Stock—100% worth it. Wish I had more (and i’ve already actually bought more).

Any group that was offered USAP partnership but signed with someone else (Envision, Mednex etc) did it for one thing only: $$$. With them you become a true faceless employee who does what they tell you to do.
USAP has a completely different business model.
1) they believe that for the business to make more money, you need to make MDs the owners, not employees. It works! When MDs make everyday decisions, they think of their $1,000,000 worth of USAP stock and how that decision is going affect the stock value. Think of succes of New Belgium brewery, same principle.
2) they are businessmen, who believe in order to succeed you need most of all to have a high quality product. That’s why quality is top priority with USAP. They have ASA top dogs as the partner, who keep push quality envelope ever father.
3) they understand that MDs could be ****y businessmen, but they are good in practicing medicine. So practice of medicine per se is left 100% to MDs.
4) their negotiating power is way greater than yours. No matter what your commercial contact rates are, their are better.
5) they have decades worth of experience building and running health care businesses. So suddenly, you are part of it. You almost feel like you “mom and pop” “lemonade stand gig” transforms into a well run slick business.
6) scale. How do you keep up with all government requirements, quality control, compliance, HIPPA, CDC, Medicare rules, billing, scheduling, recruiting, training, legal, financial, human resources, risk management? Do I need to say more? It’s taken care of with USAP, in a very cost effective way.
7) USAP stock. OMG. Is there any other equity I LOVE more? I can’t give you specifics, but let’s say you get amount $X as your buy out. Let’s say 25% is USAP stock, so it’s $0.25X. You say it’s worth nothing since you can’t sell (which is not true). Let me just say that we all wish that entire “buy out” was in stock and nothing in cash.
8) Some of you keep talking about stock price, and how stock market goes up and down. But you are forgetting 2 most important things about private stock: dividend it pays out and the fact that it’s price is strictly mathematical calculation based on earnings. USAP earnings are GOOD. I am leaving you wandering on how much dividend it may already payed and will pay in years to come. I am leaving you wandering on how many times from original price the stock is worth today. But let’s just say that I can’t hide my smile as I type this.
Click to expand...

Wow. Where are you guys hiring? I need to drop everything that I am doing, please let me join.
 
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nimbus said:
A lot of this discussion is irrelevant. If you want a job in a particular location, USAP may be the best option in town. There may be a better small niche gig but you won’t know about them until you’re there for awhile.
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Definitely not easy to hear about the smaller groups that are more ideal, especially when looking in a new region. These AMCs (and locums agencies) flood the websites with their job posts.
 
Wow...on so many levels....I really hope new grads don’t buy that biased BS. While not everything he says is untrue, USAP stock is a pyramid scheme. Yes the original share price has increased because everytime they acquire a new group they get increased earnings through higher rates and a few cost savings-hence increasing the stock price.

This model only works if 1.You were part of the buyout and 2. You were one of the first people that were part of the buy out

Yes the guys from GHA, etc made a lot on the stock, but the guys from Austin, Maryland will make way less.

It really depends on how many groups who will continue to sell to USAP

But you know who really really will make less?

Oh yeah new employees or new grads-because they are getting the stock at that magical value you say you wish you could tell us -and they’re having to pay that price, they don’t get it like all of you did who did the buy out. Oh yeah and they have to give up 30% of their revenue forever-what a great deal. But in 10 years after all the people who were part of the buy out retire no one will remember anymore-all employees smart plan.

And to say their aren’t groups with physicians who are good at business. There are many, that is a cheap fear tactic to convince selling
 
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gasier said:
Partnership—Totally worth it. Wish we did it earlier.
Stock—100% worth it. Wish I had more (and i’ve already actually bought more).


7) USAP stock. OMG. Is there any other equity I LOVE more? I can’t give you specifics, but let’s say you get amount $X as your buy out. Let’s say 25% is USAP stock, so it’s $0.25X. You say it’s worth nothing since you can’t sell (which is not true). Let me just say that we all wish that entire “buy out” was in stock and nothing in cash.
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There is so much LOL here it's crazy. Can't take you seriously, buckaroo - your prose is similar to my 11 year old niece ("OMG"). Our group (way before my time) refused a USAP buyout 5+ years ago as they didn't offer enough straight cash, homie. Take cash, not meaningless pieces of paper backed by... nothing?

Also, :troll:

EDIT: I see a new form of the ban hammer went down - membership revoked. Interesting.
 
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gasier said:
Partnership—Totally worth it. Wish we did it earlier.
Stock—100% worth it. Wish I had more (and i’ve already actually bought more).

Any group that was offered USAP partnership but signed with someone else (Envision, Mednex etc) did it for one thing only: $$$. With them you become a true faceless employee who does what they tell you to do.
USAP has a completely different business model.
1) they believe that for the business to make more money, you need to make MDs the owners, not employees. It works! When MDs make everyday decisions, they think of their $1,000,000 worth of USAP stock and how that decision is going affect the stock value. Think of succes of New Belgium brewery, same principle.
2) they are businessmen, who believe in order to succeed you need most of all to have a high quality product. That’s why quality is top priority with USAP. They have ASA top dogs as the partner, who keep push quality envelope ever father.
3) they understand that MDs could be ****y businessmen, but they are good in practicing medicine. So practice of medicine per se is left 100% to MDs.
4) their negotiating power is way greater than yours. No matter what your commercial contact rates are, their are better.
5) they have decades worth of experience building and running health care businesses. So suddenly, you are part of it. You almost feel like you “mom and pop” “lemonade stand gig” transforms into a well run slick business.
6) scale. How do you keep up with all government requirements, quality control, compliance, HIPPA, CDC, Medicare rules, billing, scheduling, recruiting, training, legal, financial, human resources, risk management? Do I need to say more? It’s taken care of with USAP, in a very cost effective way.
7) USAP stock. OMG. Is there any other equity I LOVE more? I can’t give you specifics, but let’s say you get amount $X as your buy out. Let’s say 25% is USAP stock, so it’s $0.25X. You say it’s worth nothing since you can’t sell (which is not true). Let me just say that we all wish that entire “buy out” was in stock and nothing in cash.
8) Some of you keep talking about stock price, and how stock market goes up and down. But you are forgetting 2 most important things about private stock: dividend it pays out and the fact that it’s price is strictly mathematical calculation based on earnings. USAP earnings are GOOD. I am leaving you wandering on how much dividend it may already payed and will pay in years to come. I am leaving you wandering on how many times from original price the stock is worth today. But let’s just say that I can’t hide my smile as I type this.
Click to expand...

I just spoke with my friend that works with USAP. I guess when USAP buys out practices, or when you make partner, you're forced to buy stock at whatever price USAP sets, which, if I were USAP, would just artificially raise the price of the stock, because, why not? Is this "forced appreciation" normal in the business world, outside of medicine?
 
Gaslamp said:
I just spoke with my friend that works with USAP. I guess when USAP buys out practices, or when you make partner, you're forced to buy stock at whatever price USAP sets, which, if I were USAP, would just artificially raise the price of the stock, because, why not? Is this "forced appreciation" normal in the business world, outside of medicine?
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They put that clause in the contract after you sign on to the partnership track. The overall cost is $100,000 for a stock likely worth 1/3 to 1/2 that amount but USAP is still much, much better in terms of a 20 year career vs the other AMCs. These days not everyone can land a job in a stellar group or they need to work in a certain location. USAP is the Best of the worst IMHO and I recommend them as a possible alternative to other employee jobs out there.
 
gasier said:
Partnership—Totally worth it. Wish we did it earlier.
Stock—100% worth it. Wish I had more (and i’ve already actually bought more).

Any group that was offered USAP partnership but signed with someone else (Envision, Mednex etc) did it for one thing only: $$$. With them you become a true faceless employee who does what they tell you to do.
USAP has a completely different business model.
1) they believe that for the business to make more money, you need to make MDs the owners, not employees. It works! When MDs make everyday decisions, they think of their $1,000,000 worth of USAP stock and how that decision is going affect the stock value. Think of succes of New Belgium brewery, same principle.
2) they are businessmen, who believe in order to succeed you need most of all to have a high quality product. That’s why quality is top priority with USAP. They have ASA top dogs as the partner, who keep push quality envelope ever father.
3) they understand that MDs could be ****y businessmen, but they are good in practicing medicine. So practice of medicine per se is left 100% to MDs.
4) their negotiating power is way greater than yours. No matter what your commercial contact rates are, their are better.
5) they have decades worth of experience building and running health care businesses. So suddenly, you are part of it. You almost feel like you “mom and pop” “lemonade stand gig” transforms into a well run slick business.
6) scale. How do you keep up with all government requirements, quality control, compliance, HIPPA, CDC, Medicare rules, billing, scheduling, recruiting, training, legal, financial, human resources, risk management? Do I need to say more? It’s taken care of with USAP, in a very cost effective way.
7) USAP stock. OMG. Is there any other equity I LOVE more? I can’t give you specifics, but let’s say you get amount $X as your buy out. Let’s say 25% is USAP stock, so it’s $0.25X. You say it’s worth nothing since you can’t sell (which is not true). Let me just say that we all wish that entire “buy out” was in stock and nothing in cash.
8) Some of you keep talking about stock price, and how stock market goes up and down. But you are forgetting 2 most important things about private stock: dividend it pays out and the fact that it’s price is strictly mathematical calculation based on earnings. USAP earnings are GOOD. I am leaving you wandering on how much dividend it may already payed and will pay in years to come. I am leaving you wandering on how many times from original price the stock is worth today. But let’s just say that I can’t hide my smile as I type this.
Click to expand...

Not a bad pitch to young grads. Homestly, 1-6 is mostly true or partially true. Items 7 and 8 hold true for the original owners of USAP. A new grad becoming partner this August would be lucky to get half his initial investment back. But, even at the cost of a $50,000 "buy-in" I prefer USAP over the other AMCs.
 
Is it though? I used to think it was the least evil but now I’m not so sure. On one hand yeah you maintain most of local control of operations and you have a revenue sharing program you can grow vs a straight salary.

HOWEVER...for NEW hires...you have to go through a partnership Track with a significant decrease in salary for two or three years and then pay 6 figures in stock with zero guarantee you will see any return.

The majority of USAP practices are in large metropolitan areas with extremely inflated real estate markets and high cost of living. Most new Hires have six figure debts. The six figure stock purchase required by USAP with no guaranteed return could be the funds these new hires use to pay off their debt not to mention a down payment on a house.

So while USAP May be the least evil for partners part of the buy out, I’ll make the argument it could be the worst of all evils for new hires, particularly new grads with debt. At least the other AMCs don’t require you to both buy stock and take a salary cut for the first few years-not to mention some USAP practices don’t have sign on bonuses.

It’s particularky selfish of the partners who were part of the buy out as they do have local control of new hire salaries. You sold your group-don’t make new hires pay a tax to both you and USAP.

I think new grads are figuring this out...I’ve heard through the grapevine many USAP practices are not hiring as quickly as they want.
 
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Howard888 said:
Is it though? I used to think it was the least evil but now I’m not so sure. On one hand yeah you maintain most of local control of operations and you have a revenue sharing program you can grow vs a straight salary.

HOWEVER...for NEW hires...you have to go through a partnership Track with a significant decrease in salary for two or three years and then pay 6 figures in stock with zero guarantee you will see any return.

The majority of USAP practices are in large metropolitan areas with extremely inflated real estate markets and high cost of living. Most new Hires have six figure debts. The six figure stock purchase required by USAP with no guaranteed return could be the funds these new hires use to pay off their debt not to mention a down payment on a house.

So while USAP May be the least evil for partners part of the buy out, I’ll make the argument it could be the worst of all evils for new hires, particularly new grads with debt. At least the other AMCs don’t require you to both buy stock and take a salary cut for the first few years-not to mention some USAP practices don’t have sign on bonuses.

It’s particularky selfish of the partners who were part of the buy out as they do have local control of new hire salaries. You sold your group-don’t make new hires pay a tax to both you and USAP.

I think new grads are figuring this out...I’ve heard through the grapevine many USAP practices are not hiring as quickly as they want.
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Everything you have posted above is true and factually correct especially the "greed" portion of your post. That said, I still recommend USAP to new grads who are even considering any type of AMC: USAP is the best of the bunch.

The stock is risky but not necessarily worth zero as USAP has some great practices that Envision/Sheridan would love to acquire. I'd conservatively value USAP stock at 50% of its purchase price.
 
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I’ve heard USAP is struggling some with hiring -the website with jobs advertised seems to back this up with a lot of adds.

Anyone know more?
 
I know in my area, as well as some friends that I have in other markets where USAP is present, morale within USAP has been low. With the "mergers" being relatively new, people have taken whatever buyout they received and left. These guys have to be replaced. If some of these places were already shortstaffed, hiring becomes more urgent. Hiring can be tricky when residents coming out know that there's a stigma with AMC's.
 
Gaslamp said:
Hiring can be tricky when residents coming out know that there's a stigma with AMC's.
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I haven’t heard a AMC story that has great ending. The best endorsement maybe “it’s better than being employed by hospital” or “you can have set hours, work like an employee for the rest of your career....”
I have to say just found out from one of my former chiefs, one shop just bumped their salary by cutting old shareholders salary, maybe that’s good news?
Even within this thread, the sentiment isn’t usap is great! The feeling I got is, “it’s the less of all evils out there...”
 
If the AMC is so short staffed, why not work for them as a locum? The going rate is about 200. The locum agency charges 30-40% more. Total around 300. Can we ask 250/hr and everyone wins.

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narcotics999 said:
If the AMC is so short staffed, why not work for them as a locum? The going rate is about 200. The locum agency charges 30-40% more. Total around 300. Can we ask 250/hr and everyone wins.

Sent from my moto g(6) using SDN mobile
Click to expand...
Nope. They prefer to just work the ones they have like dogs instead. Good luck going locums for USAP. They always have ads up on gasworks that never seem to fill, however.
 
chocomorsel said:
Nope. They prefer to just work the ones they have like dogs instead. Good luck going locums for USAP. They always have ads up on gasworks that never seem to fill, however.
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I saw my area locums posted by AMC. I think it is a plausible way. Curious how much they would pay.

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chocomorsel said:
Nope. They prefer to just work the ones they have like dogs instead. Good luck going locums for USAP. They always have ads up on gasworks that never seem to fill, however.
Click to expand...
Exactly. Their whole MO is to post ads and tell the salaried scmucks that they are “recruiting hard” when in actuality they drag their feet, capturing the difference all the while. AMC’s could get locums in a snap but they know they can abuse their existing employees who will do nothing about it. Physician’s are bad at recognizing the monetary value of their time.
 
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hypnosMD said:
Exactly. Their whole MO is to post ads and tell the salaried scmucks that they are “recruiting hard” when in actuality they drag their feet, capturing the difference all the while. AMC’s could get locums in a snap but they know they can abuse their existing employees who will do nothing about it. Physician’s are bad at recognizing the monetary value of their time.
Click to expand...

Ah, but you’re a doctor. You don’t punch clocks, remember?
 
Wow-shouldn’t be surprised here but I have to give hats off to USAP here-they’re the real winners and I’m definitely not so sure they are the lesser evil.

So they offer cash up front with no vesting but require vesting for stock-they know by doing this that it not only entices groups to sell but that they will get a fair portion of the stock back from those that choose to retire or leave and only take the cash.

Then they require any new “partner track” employee to spend 6 figures on this diluted stock, some of which they are getting back from employees that left. Most of these people are new grads with debt.

So USAP effectively recycles stock and/or increases its value. They effectively pay less for each group because some employees give back stock-yet the group earnings then inflate the stock price that they then get to sell to new “partner tracks”. They also get to hire new partners and pay them less.

New grads, why are you even considering this? Go live somewhere else.
 
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They’re the only game in town besides VA/ivory tower in a few desirable locations, Denver and Seattle when I was interviewing, everything else is outside the city. They were smart for doing this, desirable locations, guaranteed job interests. They need warm bodies who want to live there, it will be a long time before the surgeons/hospital admin notice the lack of anesthesia leadership if they ever do. No ones setting up eras or acute pain services, just punching a clock. The worst part is physician only will be team model with 4-1 with little/no change in compensation. Makes economic sense for the owners. I was told this directly in Denver that was their plan from physician only care.
 
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Maverikk said:
They’re the only game in town besides VA/ivory tower in a few desirable locations, Denver and Seattle when I was interviewing, everything else is outside the city. They were smart for doing this, desirable locations, guaranteed job interests. They need warm bodies who want to live there, it will be a long time before the surgeons/hospital admin notice the lack of anesthesia leadership if they ever do. No ones setting up eras or acute pain services, just punching a clock. The worst part is physician only will be team model with 4-1 with little/no change in compensation. Makes economic sense for the owners. I was told this directly in Denver that was their plan from physician only care.
Click to expand...
Not true at all in regards to Seattle. Multiple other groups in the city.
 
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BLADEMDA said:
Yes.
Click to expand...

Wanted to bump this thread out of curiosity...

What happens when a group brings in private equity or a company like USAP to “partner” with?

Let’s say 20 partners with 1 share a piece. Do they create 10 new shares and sell them to the new “partner” and effectively reduce the value of a share? So before the new shares, each partner got 1/20th of the profits and now they would get 1/30th of the profits?

Am I thinking about this correctly?
 
anes121508 said:
Wanted to bump this thread out of curiosity...

What happens when a group brings in private equity or a company like USAP to “partner” with?

Let’s say 20 partners with 1 share a piece. Do they create 10 new shares and sell them to the new “partner” and effectively reduce the value of a share? So before the new shares, each partner got 1/20th of the profits and now they would get 1/30th of the profits?

Am I thinking about this correctly?
Click to expand...

Presumably the new business would increase the value of the company and therefore increase the number of shares without decreasing the value of each share.
 
nolagas said:
Presumably the new business would increase the value of the company and therefore increase the number of shares without decreasing the value of each share.
Click to expand...

Unless they bring new business, decrease overhead, or increase the amount they collect for services wouldn’t increase the profit margin thought right?
 
The “strangest” thing to me is that insurance companies are so willing to negotiate outrageous rates “pay per point” for these large AMC’s, while simply refusing to negotiate at all with the existing small groups. Many times, a small group could exist on the same or a slightly reduced hospital stipend, if only the private insurers would up their pay per point by 20-30%. The insurance companies will flatly refuse.

The next thing you know, the hospital brings in a large AMC, in order to reduce the stipend, and the insurance companies are soon having to up their pay per point by 100%! If the insurance companies would simply show a willingness to negotiate with these small groups located in small-medium sized markets, they could save a bundle. Instead, they end up costing themselves more money, costing their customers more money, and wrecking the small “private” groups in the process.

You’d think some of the geniuses with the ASA would attempt to explain this to Blue Cross/United/Aetna/etc...... Maybe the insurance companies are playing some “long” game we don’t know about???
 
DirtDocMD said:
The “strangest” thing to me is that insurance companies are so willing to negotiate outrageous rates “pay per point” for these large AMC’s, while simply refusing to negotiate at all with the existing small groups. Many times, a small group could exist on the same or a slightly reduced hospital stipend, if only the private insurers would up their pay per point by 20-30%. The insurance companies will flatly refuse.

The next thing you know, the hospital brings in a large AMC, in order to reduce the stipend, and the insurance companies are soon having to up their pay per point by 100%! If the insurance companies would simply show a willingness to negotiate with these small groups located in small-medium sized markets, they could save a bundle. Instead, they end up costing themselves more money, costing their customers more money, and wrecking the small “private” groups in the process.

You’d think some of the geniuses with the ASA would attempt to explain this to Blue Cross/United/Aetna/etc...... Maybe the insurance companies are playing some “long” game we don’t know about???
Click to expand...



The insurance companies are required to maintain adequate provider networks. If an AMC has 70% of a particular market, the insurance company will have a hard time demonstrating network adequacy if all those doctors are OON. It’s much easier for an insurance company to walk away from negotiations with a small group.

AMCs also happen to be big supporters of the ASA and many AMC employees are ASA members. I don’t think you’ll ever see the ASA acting against the interests of the AMCs.
 
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