Browse Advisory Opinions

Concerning an arrangement under which a company that sells a variety of health care management services will disburse pay-for-performance financial incentives on behalf of a state's Medicaid program.

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

Concerning an existing arrangement and a proposed arrangement involving contracts between a durable medical equipment ("DME") supplier and various independent diagnostic testing facilities ("IDTF"), pursuant to which IDTF staff members perform certain services on behalf of the DME supplier.

Concerning the expansion of a vaccine reminder program to include entities that insure and treat patients covered by a fee-for-service Federal health care program.

Concerning an online referral service whereby post-acute care providers would pay a fee to electronically receive and respond to referral requests from hospitals for post-discharge care.

Concerning a Training Affiliation Agreement between a military medical group and a public community hospital.

Concerning the formation of a new long-term care pharmacy and the agreement to manage all of its day-to-day operations and provide all personnel and related services necessary for its operation.

Concerning a complimentary local transportation arrangement whereby a hospital would transport patients from physician offices located on, or contiguous to, the hospital's campus to the hospital if the patients require further treatment and cannot transport themselves.

Concerning a network of pediatric charity hospitals plan to: (1) begin billing third-party payers, including Federal health care programs, for services rendered, and waive all cost-sharing amounts without regard to patients' financial need; (2) adopt a new financial need-based policy of providing lodging assistance, in limited circumstances, to patients, including Federal health care program beneficiaries, and their families; and (3) adopt a new financial need-based policy of providing transportation assistance, in limited circumstances, to patients, including Federal health care program beneficiaries, and their families.

Concerning proposed payment plans for emergency and non-emergency transportation services provided for Medicaid-covered residents of skilled nursing facilities.

Concerning the amendment of an exclusive contract for emergency ambulance transport services between a municipality and an ambulance company.

Concerning a proposed arrangement between a sleep testing provider and a hospital to provide certain sleep testing equipment and services, including marketing services, for a hospital-owned sleep testing facility.

Regarding an arrangement between a sleep testing provider and a hospital to provide certain sleep testing equipment and services, including marketing services, for a hospital-owned sleep testing facility.

Regarding an ambulance company's contract to exclusively provide basic life support ambulance transport services for a town.

Concerning the use of a "preferred hospital" network as part of a Medicare Supplemental Health Insurance ["Medigap"] policy.

Concerning a radiology group's proposal to offer free insurance pre-authorization services to referring physicians.

Concerning a proposed arrangement for a non-profit charitable organization to receive donations of cash and durable medical equipment ("DME") from pharmaceutical manufacturers, DME suppliers and others, to provide funding grants and DME to entities that serve individuals suffering from coagulation disorders, and to provide DME directly to certain financially needy individuals.

Concerning a proposal to extend one night of free post-surgical accommodations to pediatric tonsillectomy patients insured by Federal health care programs.

Concerning two potential donations to support programs that provide services to children and families, which were included as part of a private settlement of an administrative dispute.

Concerning a cochlear implant manufacturer that seeks to compensate certain providers for the provision of otherwise unreimbursable services rendered in connection with faulty external components of a cochlear implant while the product is still under warranty.