Browse Advisory Opinions

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.

Concerning a proposal by an excluded individual to license an invention to a new company.

Concerning a home health agency's practice of providing prospective orthopedic patients with free educational videos containing instructions for postoperative home-based convalescence.

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

Concerning the addition of optometrists as owners of three single-specialty ophthalmology ambulatory surgical centers.

Concerning a county's exclusive contracts for emergency ambulance services, which set out how private ambulance companies should absorb the costs of transporting uninsured arrestees and reimburse the county for the costs of providing certain administrative and emergency dispatch services.

Concerning two proposals to accept low or no-cost bids for the provision of therapy services at state-operated veterans' homes.

Concerning the physicians' on-call coverage and uncompensated inpatient care arrangement employed by a medical center.

Concerning a reward program under which certain consumers receive an annual reward based on the amount spent on purchases, including purchases of items covered by Federal health care programs.

Concerning a cash donation to a senior residence program from a charitable foundation which shares ties with the program and with a local health system.

Concerning a durable medical equipment supplier's proposed arrangement to provide patients with a free in-home congestive heart failure assessment.

Concerning a proposal for certain physician investors in an established ambulatory surgery center to sell a portion of their ownership interests to a local hospital.

Concerning a pharmaceutical company's patient assistance programs, which will provide free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit.

Concerning the use of rewards from credit card issuers for the benefit of a residential health care facility and its employees.

Concerning a hospital's proposal to subsidize the cost of ambulance transportation for patients transported to the hospital from outside the hospital's local area.

Concerning a hospital's proposal to provide free dialysis services to chronic dialysis patients unable to obtain dialysis in their community.