Browse Advisory Opinions

Favorable opinion regarding a proposal by an entity and its Medicare Advantage subsidiaries that offer Employer Group Waiver Plans to share a percentage of their savings with certain groups to which they provide coverage, in certain circumstances.

Favorable opinion regarding a State-designated domestic crisis provider’s proposal to bill Federal health care programs for therapy services furnished by Requestor’s employed mental health professionals and to waive any cost sharing for such services.

Favorable opinion regarding the transfer of ownership interests by the sole shareholder of a Medicare certified ambulatory surgical center in anticipation of his retirement from medical practice.

Favorable opinion regarding a proposal from an entity that manages urgent care centers to operate a laboratory that would provide services to patients of the urgent care centers it manages.

Unfavorable opinion regarding a proposal for a home care agency to market sign-on bonuses to prospective employees with the intention of employing those individuals for the provision of services to other individuals, who most often would be family members of the prospective employees.

Favorable opinion regarding assistance, including travel, lodging, and associated expenses, provided by a pharmaceutical manufacturer to qualifying patients receiving its gene therapy product and their caregivers.

Unfavorable opinion regarding a medical device company’s proposal to pay the costs its customers otherwise would incur for a third-party company to screen and monitor the requestor for exclusion from Federal health care programs and to ensure compliance with certain other legal requirements.

Favorable opinion regarding an arrangement whereby Requestor— designated as a community health center pursuant to Section 330 of the Public Health Service Act—proposes, during the provision of certain social services to individuals, to: (1) identify individuals in need of primary care services; (2) inform them of the availability of such services; and (3) schedule an appointment for them to receive primary care services from Requestor or refer them to a local primary care provider.

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

Favorable opinion regarding assistance, including travel, lodging, meals, and associated expenses, provided by a pharmaceutical manufacturer to qualifying patients receiving its gene therapy product and their caregivers.

Favorable opinion 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.

Favorable opinion 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.

Favorable opinion 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.

Favorable opinion regarding the proposed subsidization of certain Medicare cost-sharing obligations in the context of a clinical trial.

Favorable opinion 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.

Favorable opinion 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.

Unfavorable opinion regarding a cochlear implant manufacturer’s proposal to offer and provide a free compatible hearing aid to certain patients, including Federal health care program beneficiaries, who receive one of the cochlear implants it manufactures.

Favorable opinion regarding: (i) the use of a health technology company’s online health care directory by Federal health care program beneficiaries to search for and book medical appointments with providers and the display of sponsored advertisements to Federal health care program beneficiaries on the directory and certain third-party websites; and (ii) certain proposed changes to the functionality of the directory.

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.

Favorable opinion 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.