Clinical autonomy
Local owners retain diagnosis, treatment planning, material and laboratory choice, referrals, scheduling philosophy, staffing judgment, and patient communication within law and professional duties.
Independent scale · Governance
Publish the rules before asking dentists for money, data, or trust.
“Independent,” “cooperative,” “GPO,” “network,” “IPA,” and “shared services” are labels. They do not prove member control, clinical autonomy, lawful conduct, security, fairness, or an easy exit.
Proposed public charter
Eight promises that must become enforceable design.
Member control
Eligibility, voting, board authority, reserved powers, amendments, removal, conflicts, and dissolution must be defined before members commit.
Commercial transparency
Vendor selection, fees, rebates, sponsorships, referrals, paid placement, data value, and complaint handling must be public.
Data minimization
Collect only what the defined service requires; publish use, access, sharing, retention, deletion, audit, incident, and portability rules.
Competition boundary
No competitor fee coordination, boycott, allocation, or identifiable current/future competitive strategy exchange.
Exit rights
Members can understand term, termination, surviving obligations, data export, open work, credentials, vendor transition, and continuity before joining.
Evidence and correction
Claims, benchmarks, vendor records, and service results carry source, period, denominator, limitation, correction, and review status.
Launch discipline
Education is not operational authorization. Each new service clears legal, governance, privacy, security, operational, financial, and member-demand gates.
Current red lines
What DenQAI is not offering now.
- No joint fee demand or payer boycott
- No claim that old safe-harbor formulas authorize a network
- No sharing of identifiable current or future pricing intentions
- No contracting label without counsel-approved integration and operations
- No patient data or PHI
- No payer contracts, fee schedules, EOBs, or quotes
- No confidential transaction files
- No member accounts, cloud workspace, or hidden persistence
Why the antitrust language changed
Withdrawn guidance is not a modern safe harbor.
DOJ withdrew three healthcare antitrust policy statements in February 2023. The FTC withdrew two corresponding statements in July 2023. FTC and DOJ then withdrew the 2000 competitor-collaboration guidelines in December 2024.
In February 2026, the agencies opened a public inquiry about potential updated business-collaboration guidance. An inquiry is not final guidance, an advisory opinion, or permission for a particular purchasing, data, payer, or network structure.
DenQAI therefore presents a clearly labeled hypothetical ideal: member control, clinical autonomy, commercial transparency, minimum necessary data, independent competitive decisions, measurable value, complaint and correction rights, and an orderly exit. Specialized counsel must still design and review the actual activity, market, participants, information, contracts, governance, training, monitoring, and enforcement.
Launch gate
Seven conditions before a shared capability becomes real.
- Demand
A defined member problem is observed, material, and not solved adequately by education or a local file.
- Entity and authority
Ownership, voting, board, management, reserved powers, conflicts, and eligible participants are documented.
- Legal design
Specialized counsel reviews antitrust, health, professional, corporate, privacy, employment, contracting, and state issues.
- Commercial model
Fees, rebates, sponsorship, vendor selection, complaints, ranking, and independence rules are public.
- Data and security
Minimization, identity, authorization, encryption, logging, retention, deletion, incident, backup, recovery, and testing are implemented.
- Operations
Service levels, competence, exceptions, corrections, continuity, vendor failure, and member support are tested.
- Portability and exit
A member can export records, transfer open work, revoke access, and leave without clinical disruption.
Demand without sensitive data
Describe the capability you need before DenQAI builds the entity.
The current interest brief stays on your device and does not collect contracts, pricing, patient data, or transaction records.
Build an interest brief