The important article by Freeman et al1 about the new dimension of patient advocacy in the era of managed care raises some interesting questions. In respect to loss of physician autonomy under managed care, how much did this loss affect management decisions among physicians in the study group? Why don't the authors have a breakdown of hypothetical managed care transactions between physicians and for-profit health maintenance organizations compared with those between physicians and nonprofit health maintenance organizations? Why did the authors choose the word "deception" rather than the word "fraud" when referring to these hypothetical transactions between physicians and managed care organizations on behalf of patients? It seems that deception turns into fraud when physicians change from patient advocates to patient surrogates. Should we leave it to legal scholars to wrestle with these definitions?