All Advisory Opinions
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AO 22-11
Posted May 25, 2022Regarding 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.
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AO 15-14
Updated May 2, 2022Regarding a non-profit, tax-exempt, charitable organization's program to help financially needy patients, including Medicare and Medicaid beneficiaries, obtain magnetic resonance imaging for the diagnosis or ongoing evaluation of [disease state redacted] (the "Arrangement").
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AO 22-10
Posted May 2, 2022Regarding (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.
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AO 22-09
Posted April 28, 2022Regarding a proposed arrangement pursuant to which Requestor would compensate hospitals for certain specimen collection services for laboratory tests furnished by Requestor.
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AO 22-08
Posted April 27, 2022Regarding an arrangement whereby certain existing patients of Requestor use limited-use smartphones that Requestor loaned to such patients to facilitate access to telehealth services.
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AO 22-07
Posted April 25, 2022Regarding 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.
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AO 22-06
Posted April 11, 2022Regarding the provision of free genetic testing and genetic counseling services to individuals who meet specified clinical criteria.
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AO 22-05
Posted March 16, 2022Regarding the proposed subsidization of certain Medicare cost-sharing obligations in the context of a clinical trial.
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AO 22-04
Posted March 2, 2022Regarding a program through which Requestor provides certain individuals access to digital contingency management and related tools to treat substance use disorders, where the Program is funded by customers, which could include individuals’ health care providers or suppliers.
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AO 22-03
Posted February 14, 2022Regarding Requestors’ proposal to pay salaries to, and nurse aide certification program tuition costs on behalf of, new employees who Requestors have hired to work as certified nurse aides for Requestors’ home health agencies.
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AO 22-02
Posted February 9, 2022Regarding a proposed arrangement between Requestor and two individuals, pursuant to which Requestor and the individuals would reduce and subsidize certain costs incurred by qualifying patients of Requestor’s children’s hospital.
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AO 22-01
Posted January 19, 2022Regarding the proposed expansion of discount programs for low-income individuals.
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AO 21-20
Posted December 16, 2021Regarding Requestor’s proposal to create an online platform for: (i) users to search for and contact home-based health care providers, where providers listed on the website would be charged on a per-click basis; and (ii) advertising by individuals and entities other than home-based health care providers.
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AO 21-19
Posted December 6, 2021Regarding Requestor’s provision of free eye drops that mitigate side effects for patients using one of its products.
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AO 21-18
Posted November 22, 2021Regarding a proposed joint venture for the provision of therapy services.
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AO 21-17
Posted November 19, 2021Regarding the proposed subsidization of beneficiary cost-sharing obligations for Medicare-covered services provided as part of a clinical trial.
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AO 21-16
Posted November 16, 2021Regarding 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.
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AO 21-15
Posted November 10, 2021Regarding 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.
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AO 21-14
Posted October 5, 2021Regarding a proposal to extend an existing discount program for chiropractic patients to include Federal health care program beneficiaries.
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AO 21-13
Posted October 4, 2021Regarding the proposed subsidization of beneficiary cost-sharing obligations for Medicare-covered services provided as part of a clinical trial.