Browse Advisory Opinions

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 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.

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.

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.

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.

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.

Regarding a surgical device and wound care product manufacturer's proposal to offer hospital customers a warranty program covering a suite of three products.

Regarding a proposal from a group purchasing organization ("GPO") to serve as a purchasing agent on behalf of certain GPO-affiliated health care facilities on the same terms and conditions that apply to its unaffiliated members.

Regarding the effect of your exclusion from Medicare, Medicaid, and all other Federal health care programs.

Regarding your proposal to develop a state-wide network of nursing facilities that would provide discounts on the daily rates they charge to private long-term care insurers and the insurers' policyholders.

Regarding a proposed arrangement in which grants would be provided by a non-profit, charitable organization to financially needy Medicare beneficiaries in order to subsidize their costs of medical care.

Regarding: (i) a proposal to waive cost-sharing obligations incurred by individuals for health care services required for participation in a government-funded clinical research study (the "Proposed Arrangement"); and (ii) the payment of a stipend to study participants for the time and effort required to participate in study visits.

Regarding a local health care district's proposal to cooperate with another district to jointly fund the cost of a transportation coordinator to educate patients about local transportation options and subsidize certain forms of transportation for patients with financial need.

Regarding a proposal to install a computerized point-of-care vaccine storage and dispensing system in physicians' offices for the physicians' use.

Regarding the effect of exclusion from Medicare, Medicaid, and all other Federal health care programs.

Concerning an online service that would facilitate the exchange of information between health care practitioners, providers, and suppliers.

Concerning a proposal to waive cost-sharing amounts on a non-routine, unadvertised basis for insured patients, including Federal health care program beneficiaries, based on individualized determinations of financial need.