Browse Advisory Opinions

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.

Concerning a proposed arrangement in which a hospital will 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 a pharmaceutical company's proposal to establish a patient assistance program to provide outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit.

Concerning a durable medical equipment supplier's practice of providing patients with free home oxygen until the patients qualify for Medicare coverage of oxygen, as well as the supplier's proposed arrangement to provide patients with a free overnight oximetry test.

Concerning a volunteer services program for the provision of specialty medical care and professional development in rural areas, through which volunteers' travel costs would be covered.

Concerning a pharmaceutical company's proposal to establish a patient assistance program to provide outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit.

Concerning payment of certain compensation owed by the organizer of a dental preferred provider organization to a dental network marketing and management company in connection with the use of the dental network by a Federal employee health benefits plan.

Concerning a proposed arrangement for a durable medical equipment ("DME") manufacturer to provide advertising assistance and reimbursement consulting services to some of its customers.

Concerning an arrangement under which a managed care company will disburse pay-for-performance financial incentives on behalf of a State's Medicaid program.

Concerning a pharmaceutical manufacturer's proposal to establish a patient assistance program to provide the company's drugs to financially-needy Medicare Part D enrollees outside of the Part D benefit.

Concerning a municipality's exclusive contract arrangement for non-emergency inter-facility ambulance transport services.

Concerning a municipality's exclusive contract arrangement for non-emergency inter-facility ambulance transport services.

Concerning a free clinic's practice of dispensing drugs on behalf of patient assistance programs ("PAPs") sponsored by pharmaceutical manufacturers that provide free drugs to financially-needy patients, including some patients enrolled in the Medicare Part D outpatient prescription drug benefit.

Concerning a proposal by a municipality, which provides emergency medical services through a municipally owned and operated ambulance service, to treat revenue received from local taxes as payment of otherwise applicable cost-sharing amounts due from municipal residents.

Concerning a proposed exclusive arrangement for emergency ambulance services.

Concerning a research hospital's practice of providing drugs and supplies to its affiliates for administration to the hospital's patients receiving treatment at the affiliates.