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All Advisory Opinions

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Showing 1–20 of 388 advisory opinions Sorted by most recent
  • AO 21-05

    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.

    Posted May 20, 2021
  • AO 21-04

    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.

    Posted May 19, 2021
  • AO 21-03

    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.

    Posted May 17, 2021
  • AO 21-02

    Regarding an investment by a health system, certain surgeons, and a management company in an ambulatory surgery center.

    Posted April 29, 2021
  • AO 21-01

    Regarding a free drug provided by a pharmaceutical manufacturer to certain patients to whom the manufacturer's drug has been prescribed.

    Posted March 23, 2021
  • AO 20-09

    Regarding a program where a pharmaceutical manufacturer provides financial assistance for travel, lodging, and other expenses to certain patients prescribed the manufacturer's drug.

    Posted December 31, 2020
  • AO 20-08

    Regarding a federally qualified health center's proposal to offer gift cards to incentivize certain pediatric patients to attend rescheduled preventive and early intervention care appointments.

    Posted December 30, 2020
  • AO 20-07

    Regarding a web-based platform where health care facilities and clinicians would, in particular circumstances, remit to patients and the patients' payors a portion of the claims for certain services for which payment may be made by the Medicare program as a secondary payor.

    Posted December 28, 2020
  • AO 20-06

    Regarding a management company's provision of below fair market value Medicaid enrollment application assistance services to certain individuals and affiliated skilled nursing facilities' payments for those services in particular circumstances.

    Posted December 23, 2020
  • AO 20-05

    Regarding a pharmaceutical manufacturer's proposal to provide cost-sharing assistance directly to Medicare beneficiaries who are prescribed either of two formulations of its drug.

    Posted September 23, 2020
  • AO 20-04

    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.

    Posted July 24, 2020
  • AO 20-03

    Regarding an arrangement under which a discount medical plan organization ("DMPO") pays chiropractors and chiropractic clinics a fee for each new DMPO member referred by the chiropractor or chiropractic clinic.

    Posted July 1, 2020
  • AO 20-02

    Regarding financial assistance for travel, lodging, and other expenses provided by a pharmaceutical manufacturer to certain patients prescribed the manufacturer's drug.

    Posted January 22, 2020
  • AO 20-01

    Regarding a hospital's provision of discounted training to a specified fire department's personnel at the hospital's facility.

    Posted January 13, 2020
  • AO 19-06

    Regarding a supermarket's proposal to expand its current loyalty program to allow customers to earn rewards points on out-of-pocket costs paid in connection with pharmacy purchases.

    Posted December 17, 2019
  • AO 19-05

    Regarding a proposed purchase of real estate from a limited liability company owned, in part, by an excluded individual.

    Posted September 11, 2019
  • AO 19-04

    Regarding a technology company's proposal to make visible to Federal health care program beneficiaries: (i) its online healthcare directory for searching and booking medical appointments, where healthcare professionals pay, or would pay, per-click or per-booking fees to be listed in the directory; and (ii) sponsored advertisements on its online healthcare directory and third-party websites, where healthcare professionals pay, or would pay, per-impression or per-click fees for such sponsored advertisements (the "Proposed Arrangement").

    Posted September 10, 2019
  • AO 19-03

    Regarding a program offered by a medical center that provides free, in-home follow-up care to eligible individuals with congestive heart failure (the "Current Arrangement") and the proposed expansion of this program to include certain individuals with chronic obstructive pulmonary disease.

    Posted March 7, 2019
  • AO 19-02

    Regarding a pharmaceutical manufacturer's proposal to loan, on a temporary basis, a limited- functionality smartphone to financially needy patients who do not have the technology necessary to receive adherence data from a sensor embedded in prescribed antipsychotic medication.

    Posted January 29, 2019
  • AO 19-01

    Regarding a charitable pediatric clinic's arrangement under which the clinic waives cost-sharing amounts in certain circumstances.

    Posted January 14, 2019