Browse Advisory Opinions

Concerning a proposal for a hospice to establish a volunteer program to provide non-skilled services to terminally ill patients who do not qualify for hospice care.

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.

Concerning a rewards program under which consumers would earn gasoline discounts based on the amount they spend on purchases in retail supermarkets, including cost-sharing amounts paid in connection with items covered by Federal health care programs purchased in the in-store pharmacies.

Concerning a proposal by a hearing aid supplier to begin billing Medicare for certain audiometric testing, while continuing to offer free hearing tests to prospective hearing aid customers.

Concerning a proposed bundle billing arrangement for basic life support advanced life support joint responses.

Concerning an ambulance supplier's proposal to routinely waive cost-sharing amounts for emergency medical services rendered on a part-time basis.

Concerning a proposal by a radiology group to offer free insurance pre-authorization services to physicians and patients.

Concerning reduced-rate arrangements for the provision of therapy services at state-operated veterans' homes.

Concerning a proposal for an independent diagnostic testing facility to hire a doctor to read and interpret test results when that doctor is closely related to the owners of the independent diagnostic testing facility and is employed by a company that also employs other potential referral sources.

Concerning an exclusive arrangement between a county and an emergency medical services company whereby the company provides emergency ambulance services to county residents.

Concerning two proposals by an anesthesia services provider to enter into contracts with physician-owned professional corporations or limited liability companies to provide anesthesia services.

Concerning a rewards program under which consumers would earn gasoline discounts based on the amount spent on purchases in retail stores and pharmacies, including cost-sharing amounts paid in connection with items covered by Federal health care programs.

Concerning certain aspects of an exclusive contract for emergency transport services between a municipality and an ambulance company that reimburses the municipality for dispatch services and for certain costs incurred when municipal firefighters drive transports.

Concerning a proposal by a municipal fire department to share certain costs related to dispatch and other services with hospital-based ambulance providers that participate in the local 911 emergency dispatch system.

Concerning a proposal to operate a website that would display coupons and advertising from health care providers, suppliers, and other entities.

Concerning a proposal to establish a group purchasing organization ("GPO") that would be wholly owned by an entity that also wholly owns many of the potential participants in the GPO, and to pass through to participants in the GPO a portion of the payments received by the GPO from vendors.

Concerning the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies.

Concerning a proposed arrangement under which an entity would furnish allergy testing and immunotherapy laboratory services within various primary care physicians' medical offices.

Concerning a hospital's domiciliary services program that provides transportation, lodging, and meal assistance to certain patients and their family members.

Concerning a proposal under which physicians would invest in a company that would provide pathology laboratory management services to a third party.