Browse Advisory Opinions

Concerning a proposal to contract with hospitals to provide services to patients with certain diagnoses following hospital discharge with the goal of reducing preventable hospital readmissions.

Concerning a proposal to offer members of a group purchasing organization ("GPO") an equity interest in the GPO's parent organization in exchange for the member: (1) extending its contract with the GPO for five to seven years; (2) committing not to decrease purchasing volume; and (3) relinquishing its right to a portion of the administrative fees that would otherwise have been passed through to the members.

Concerning a fire protection district's policy of billing only individuals who reside outside the fire protection district for emergency medical services.

Concerning a tiered rebate program in which the rebate tiers would be reached based on the combination of purchases of both Federally reimbursable products and non-Federally reimbursable products.

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

Concerning an exclusive contract for emergency medical services and transports between a municipality and an ambulance company. The opinion addresses the aspect of the contract that requires the ambulance company to reimburse the municipality for a portion of the costs of providing emergency dispatch services.

Concerning an arrangement among a county, a county health district, and various municipalities concerning the provision of non-emergency ambulance transportation services by the county health district.

Concerning a clinical laboratory company's proposal to establish a subsidiary that would contract with physician practices to enable the practices to provide laboratory services to the physicians' patients who are not Federal health care program beneficiaries.

Concerning a proposal to establish a limited liability company that would enter into arrangements with manufacturers and other entities to provide industrial orthotics for use by these entities' employees.

Concerning the use of a hospital network as part of a Medicare Supplemental Health Insurance policy.

Regarding an existing arrangement under which a hospital pays a per diem fee to physicians for providing on-call coverage for the hospital's emergency department.

Concerning an arrangement in which a hospital pays a cardiology group compensation that includes a performance bonus based on implementing certain patient service, quality, and cost savings measures associated with procedures performed at the hospital's cardiac catheterization laboratories.

Concerning a Federally qualified health center's proposal to offer grocery store gift cards to certain patients in capitated managed care plans as an incentive to receive health screenings or other clinical services.

Concerning a hospital's proposal to provide free access to an electronic interface to community physicians and physician practices that would allow those physicians and practices to transmit orders for certain services to, and receive the results of those services from, the hospital.

Concerning four proposed arrangements involving a pharmacy company's provision of items and services to community homes in which its customers reside.

Concerning a proposed arrangement whereby three municipalities will reciprocally waive the otherwise applicable cost-sharing obligations of each other's bona fide residents when providing backup emergency medical services transportation to such individuals in certain circumstances.

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.