Browse Advisory Opinions

Concerning a proposal for a government entity to subsidize copayments for outpatient prescription drugs owed by certain financially needy Medicare Part D enrollees.

Concerning the provision of free blood pressure screenings to walk-in visitors at a hospital.

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

Concerning a proposed joint venture involving ownership of an ambulatory surgery center by a hospital and physicians.

Concerning a proposed institutional patient assistance program that would make certain drug products available to people without prescription drug coverage through the provision of replacement stock to certain participating disproportionate share hospitals.

Concerning a proposal to expand an existing program that provides free oral nutritional supplements to malnourished end-stage renal disease patients who are on dialysis.

Concerning an existing arrangement in which a hospital has agreed to share with a cardiology group, a vascular surgical group, and an interventional radiology group a percentage of the hospital's cost savings arising from the physicians' implementation of a number of cost-reduction measures in certain cardiac catheterization procedures.

Regarding a proposal to waive cost-sharing obligations for protocol-required clinical services and oxygen therapy provided to Medicare beneficiaries who participate in the Long-term Oxygen Treatment Trial sponsored by the National Heart, Lung, and Blood Institute and the Centers for Medicare and Medicaid Services.

Concerning a hospital's proposal to compensate physicians for on-call services performed on behalf of the hospital's uninsured patients.

Concerning a nonprofit, tax-exempt, charitable organization's arrangement to provide financial assistance with cost-sharing obligations associated with certain advanced diagnostic testing owed by financially needy patients, including Medicare and Medicaid beneficiaries.

Concerning an arrangement whereby three municipalities reciprocally waive otherwise applicable cost-sharing obligations of individuals residing within each other's borders when providing backup emergency medical services transportation.

Concerning an employment contract entered into concurrently with a real estate purchase contract between the employer and new employee.

Concerning a complimentary local transportation program for friends and family of residents of a skilled nursing facility.

Concerning investments in a rural medical practice group by 23 physicians and podiatrists.

Concerning a proposal for a county, which provides emergency medical services (EMS) transportation through its fire department, to treat revenue received from taxes as payment of otherwise applicable cost-sharing amounts owed by bona fide county residents for EMS transportation to hospitals.

Concerning certain part-time physician employment arrangements.

Concerning a multiple-year arrangement in which a hospital has agreed to share, with cardiology groups and a radiology group, a percentage of the hospital's cost savings arising from the physicians' implementation of cost reduction measures in certain cardiac catheterization procedures.

Concerning a proposal whereby two suppliers of durable medical equipment, prosthetics, orthotics and supplies will (i) place inventory in consignment closets on-site at certain hospitals and (ii) have licensed personnel on-call or on-site at the hospitals to train and educate patients who have been prescribed respiratory equipment and have selected one of the companies as their supplier upon discharge to their homes.

Concerning an Internet advertiser's proposal to extend its "pay per call" or "pay per lead" advertising business to the chiropractic industry.

Concerning a proposal whereby a medical center providing emergency medical services transportation in a county would not bill bona fide county residents for applicable cost-sharing amounts, but would instead be paid such amounts by the county from a fund consisting of tax revenue derived from a special millage.