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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 20-04 was modified on April 24, 2023

    Regarding a charitable organization’s proposal to purchase or receive donations of unpaid medical debt owed by qualifying patients from certain types of health care providers and then forgive that debt.

  • AO 23-03 was posted on March 29, 2023

    Regarding a proposal to provide a prepaid card to certain individuals, including Federal health care program beneficiaries, to encourage those individuals to return the sample collection kit associated with a colorectal cancer screening test.

  • AO 23-02 was posted on February 28, 2023

    Regarding a program to provide a drug for free, for a limited time, to patients who experience a delay in their insurance approval process for the drug.

  • AO 23-01 was posted on February 23, 2023

    Regarding financial assistance for transportation, lodging, and meals provided by a drug manufacturer to financially needy pediatric patients and their caregiver(s) in connection with treatment with the manufacturer’s drug.

  • AO 22-22 was posted on December 28, 2022

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

  • AO 22-21 was posted on December 23, 2022

    Regarding an arrangement in which a county and its department of public health’s emergency medical services division sublease certain space and lease certain furniture and equipment to a private ambulance company that has been granted an exclusive contract for the provision of emergency ambulance transports in certain parts of the county.

  • AO 22-20 was posted on December 19, 2022

    Regarding a hospital’s utilization of its employed nurse practitioners to perform services that traditionally have been performed by a patient’s attending physician in certain medical units.

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