Browse Advisory Opinions

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.

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.

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.

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 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.

Regarding 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.

Regarding 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.

Regarding a proposal to extend an existing discount program for chiropractic patients to include Federal health care program beneficiaries.

Regarding a federally qualified health center's proposal to offer gift cards to incentivize certain pediatric patients to attend rescheduled preventive and early intervention care appointments.

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 technology company's proposal to make visible to Federal health care program beneficiaries: (i) its online healthcare directory for searching and booking medical appointments, where healthcare professionals pay, or would pay, per-click or per-booking fees to be listed in the directory; and (ii) sponsored advertisements on its online healthcare directory and third-party websites, where healthcare professionals pay, or would pay, per-impression or per-click fees for such sponsored advertisements (the "Proposed Arrangement").

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.