Browse Advisory Opinions

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 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 a medical technology manufacturer and distributor’s proposal to offer to certain ambulatory surgery centers a discount on intraocular lenses and other surgical supplies used to perform cataract surgery, contingent on affiliated physician practices purchasing its software product.

Favorable opinion regarding an arrangement pursuant to which a company operationalized and makes financial contributions to a foundation, and the foundation provides grants to families of children receiving a particular type of therapy.

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 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.

Favorable opinion regarding a program to provide free access to a pharmaceutical product to patients who meet financial and other eligibility criteria and who do not have adequate coverage for the product.

Favorable opinion regarding a program to sponsor genetic testing, related genetic counseling, and disease-state awareness education regarding certain hereditary conditions that may cause kidney stones.

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.

Favorable opinion regarding: (i) a limited-time program to refund, waive, or delay requiring receipt of payment for a drug in the event of an insurance reimbursement denial or delay; and (ii) certain discounts to the cost of the drug.

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 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.