Browse Advisory Opinions

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.

Concerning an existing multiple-year arrangement in which a hospital shares with groups of cardiologists a percentage of the hospital's cost savings arising from the cardiologists' implementation of a number of cost reduction measures in certain procedures.

Concerning a proposed arrangement by which a hospital would share with a physician-owned entity certain performance-based compensation available to the hospital under a quality and efficiency agreement with a private insurer.

Concerning the use of a “preferred hospital” network as part of a Medicare Supplemental Health Insurance (“Medigap”) policy.

Concerning a substance abuse treatment center's use of motivational incentives to reward a patient's achievement of certain treatment-related goals.

Concerning a proposed arrangement under which a newly formed legal entity would provide purely administrative insurance preauthorization processing and submission services for various radiology and imaging centers.

Concerning a proposal for a physician practice group to provide space, equipment and personnel to other physician practice groups through block leases.

Concerning an arrangement under which a medical center has agreed to share with groups of orthopedic surgeons and a group of neurosurgeons a percentage of the medical center's cost savings arising from the surgeons' implementation of a number of cost reduction measures in spine fusion surgical procedures.

Concerning an investment in an ambulatory surgery center by a group of surgeons and a health care corporation that owns hospitals.

Concerning a proposal for a health care system to provide $10 gift cards to patients whose service expectations were not met.

Concerning a laboratory's proposal to provide services consisting of the labeling of test tubes and specimen collection containers at no cost to dialysis facilities.

Concerning a pharmaceutical company's proposal to place in certain physicians' offices electronic kiosks that offer patients free disease state screening questionnaires.

Concerning a proposal to offer a free trial prescription program to hemophilia A patients who are Federal health care program beneficiaries.

Concerning a proposed arrangement by which a health care system would provide prompt pay discounts to Federal health care program beneficiaries and other insured patients in connection with both inpatient and outpatient care.

Concerning a marketing and research company's proposal to encourage physicians and other health care professionals to complete online surveys by offering them the opportunity to designate a public charity to which the company or one of its clients would make a monetary charitable contribution.

Concerning a non-profit corporation's program that arranges for pharmaceutical manufacturer patient assistance programs to provide donated drugs to free clinics and Federally qualified health centers (FQHCs) for use by financially-needy patients who do not have any form of outpatient prescription drug insurance coverage.

Concerning an arrangement in which a hospital has agreed to share with a group of cardiac surgeons a percentage of the hospital's cost savings arising from the surgeons' implementation of a number of cost reduction measures in certain surgical procedures.

Concerning an arrangement in which a hospital has agreed to share with a group of anesthesiologists a percentage of the hospital's cost savings arising from the anesthesiologists' implementation of a number of cost reduction measures related to anesthesia services provided during cardiac surgical procedures.

Concerning an arrangement whereby a radiology group practice prepares written reports of its interpretations of radiology tests for a critical access hospital without charge to the hospital.

Concerning an investment by a physician in an imaging center in a medically underserved area devastated by Hurricane Katrina.