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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 22-19 was posted on October 5, 2022

    Regarding a proposal whereby certain pharmaceutical manufacturers would: (i) fund, through Requestor, cost-sharing subsidies for the manufacturers’ Part D oncology drugs; (ii) fund, through Requestor, specified programs and eligible beneficiaries’ health insurance premiums; and (iii) finance Requestor’s operating costs.

  • AO 22-18 was posted on September 20, 2022

    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 22-17 was posted on September 6, 2022

    Regarding a proposed restructuring of financial relationships, which includes the forgiveness of debt, between a health system and a nearby clinic.

  • AO 22-16 was posted on August 19, 2022

    Regarding the provision of a gift card to certain Medicare Advantage plan enrollees who complete specific steps in an online patient education program.

  • AO 22-15 was posted on July 5, 2022

    Regarding a proposal to use donations to cover: (i) specialized care furnished to veterans who meet certain criteria; and (ii) certain out-of-pocket expenses related to that specialized care.

  • AO 22-14 was posted on June 29, 2022

    Regarding an ophthalmology practice’s proposed continuing education programs for local optometrists and four financing options to fund the programs.

  • AO 22-13 was posted on June 23, 2022

    Regarding a durable medical equipment manufacturer’s arrangements with two financial institutions to make zero-interest financing available to qualified customers.

  • AO 20-02 was modified on June 1, 2022

    Requestor now seeks to modify AO 20-02 to include Requestor’s provision of financial assistance to eligible patients for travel, lodging, and certain other associated expenses in connection with a round trip to an approved treatment center for a cell-removal process associated with manufacturing Requestor’s drug.

  • AO 22-12 was posted on June 1, 2022

    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 22-11 was posted on May 25, 2022

    Regarding its proposal to employ an individual who is excluded from participation in Federal health care programs to perform marketing tasks relating to workers’ compensation programs.

  • AO 15-14 was modified on May 2, 2022

    Regarding (i) a modification to OIG Advisory Opinion 15-14, issued to the requestor on November 13, 2015, to include within the scope of that opinion, the requestor’s proposal to provide financial assistance for certain past magnetic resonance imaging tests; and (ii) a second arrangement regarding the distribution of certain cooling and mobility items, ancillary to the arrangement addressed in OIG Advisory Opinion 15-14.

  • AO 22-10 was posted on May 2, 2022

    Regarding (i) a modification to OIG Advisory Opinion 15-14, issued to the requestor on November 13, 2015, to include within the scope of that opinion, the requestor’s proposal to provide financial assistance for certain past magnetic resonance imaging tests; and (ii) a second arrangement regarding the distribution of certain cooling and mobility items, ancillary to the arrangement addressed in OIG Advisory Opinion 15-14.

  • AO 22-09 was posted on April 28, 2022

    Regarding a proposed arrangement pursuant to which Requestor would compensate hospitals for certain specimen collection services for laboratory tests furnished by Requestor.

  • AO 22-08 was posted on April 27, 2022

    Regarding an arrangement whereby certain existing patients of Requestor use limited-use smartphones that Requestor loaned to such patients to facilitate access to telehealth services.

  • AO 22-07 was posted on April 25, 2022

    Regarding an arrangement whereby certain physicians have an ownership interest in a medical device company that manufactures products that may be ordered by the physician owners and a physician spouse of one of the physician owners.

  • AO 22-06 was posted on April 11, 2022

    Regarding the provision of free genetic testing and genetic counseling services to individuals who meet specified clinical criteria.

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