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Advisory Opinions

HHS-OIG issues advisory opinions about the application of certain fraud and abuse enforcement authorities to the requesting party’s existing or proposed business arrangements.

Recent Activity

  • AO 21-19 was posted on December 6, 2021

    Regarding Requestor’s provision of free eye drops that mitigate side effects for patients using one of its products.

  • AO 21-18 was posted on November 22, 2021

    Regarding a proposed joint venture for the provision of therapy services.

  • AO 21-17 was posted on November 19, 2021

    Regarding the proposed subsidization of beneficiary cost-sharing obligations for Medicare-covered services provided as part of a clinical trial.

  • AO 21-16 was posted on November 16, 2021

    Regarding a pharmaceutical manufacturer’s arrangement to provide up to a specified number of trial units of a long-acting antipsychotic drug to certain hospitals for inpatient use.

  • AO 21-15 was posted on November 10, 2021

    Regarding a pain management company’s proposal to retain net profits from services provided by an employed certified registered nurse anesthetist pursuant to a reassignment of billing rights.

  • AO 21-14 was posted on October 5, 2021

    Regarding a proposal to extend an existing discount program for chiropractic patients to include Federal health care program beneficiaries.

  • AO 21-13 was posted on October 4, 2021

    Regarding the proposed subsidization of beneficiary cost-sharing obligations for Medicare-covered services provided as part of a clinical trial.

  • AO 21-12 was posted on September 15, 2021

    Regarding a critical access hospital’s proposal to offer an arrangement similar to a warranty to patients undergoing certain joint replacement procedures at the hospital.

  • AO 21-11 was posted on August 19, 2021

    Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company contracts with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, provides a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

  • AO 21-10 was posted on August 6, 2021

    Regarding a dental provider’s provision of free routine and emergency dental services to certain indigent residents of skilled nursing facilities and nursing facilities.

  • AO 21-09 was posted on July 19, 2021

    Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

  • AO 21-08 was posted on July 8, 2021

    Regarding financial assistance for transportation, lodging, and meals provided by a pharmaceutical manufacturer to certain patients potentially eligible for treatment with the pharmaceutical manufacturer’s drug.

  • AO 21-07 was posted on July 7, 2021

    Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

  • AO 21-06 was posted on June 29, 2021

    Regarding a spinal implant manufacturer’s proposal to offer its products to hospitals at a reduced price if the hospitals agree to assume certain duties related to the products.

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