Browse Advisory Opinions

Unfavorable opinion regarding a proposed arrangement whereby an orthopedic medical technology company would enter into agreements with individuals—often physicians—who would provide consulting services for its product lines.

Favorable opinion regarding a pediatric dental and orthodontic services provider’s proposal to provide free, comprehensive orthodontic treatment to one of its existing patients per year.

Favorable opinion regarding a proposal to enter into certain lease arrangements to create a centralized location for providing a range of items and services to patients with hearing loss who may be candidates for cochlear implants.

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 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 a proposed arrangement whereby a management support organization and an affiliated professional corporation would enter into an agreement with telehealth providers to lease employees and provide certain administrative services.

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 a dental supplies distributor’s proposed expansion of its existing customer loyalty program for purchases of dental-related items and services.

Favorable opinion regarding: a proposal for a municipal corporation to begin billing patients’ insurance plans—and waiving any patient cost- sharing amounts—for treatment-in-place emergency medical services without an associated ambulance transport.

Unfavorable opinion regarding proposed assistance for fertility services for qualifying patients receiving a gene therapy treatment developed by a biotechnology company.

Favorable in part and unfavorable in part opinion regarding proposed assistance for: (i) travel, lodging, meals, and associated expenses; and (ii) fertility preservation services for qualifying patients receiving one of two gene therapy treatments developed by a publicly traded biotechnology company.

Unfavorable opinion regarding a laboratory company’s proposal to purchase anatomic pathology services from third-party laboratories.

Unfavorable opinion regarding a company’s proposal to assist physicians who perform surgeries for which the company’s services are used with the formation and operation of a turnkey physician-owned entity that would perform those same services.

Regarding an arrangement in which a county and its department of public health’s emergency medical services division sublease certain space and lease certain furniture and equipment to a private ambulance company that has been granted an exclusive contract for the provision of emergency ambulance transports in certain parts of the county.

Regarding a hospital’s utilization of its employed nurse practitioners to perform services that traditionally have been performed by a patient’s attending physician in certain medical units.

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

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.

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