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

Concerning a joint venture between two components of an academic medical center to build and own an ambulatory care center on a 50-50 basis.

Concerning a proposed rewards program for referrals of prospective residents to the requestor's continuing care retirement communities by current residents and employees.

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

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

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 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 proposed program by a provider of home health care services to provide free medical-alert pagers and pager monitoring service to homebound patients during the period such patients are receiving the company's home health services.

Concerning a managed care organization's employment of an excluded individual and potential sanctions under section 1320a-7a(a)(6) of the SSA.

Concerning a managed care organization's proposal to subsidize the Medicare+Choice premiums andcopayments of its members eligible for both Medicare and certain limited Medicaid benefits.

Regarding the "coordination of benefits" provisions of a provider agreement between a nursing home and a health care plan.

A proposed marketing program involving the use of physician practices and health care clinics to distribute coupons redeemable by certain retailers (including grocery stores, pharmacies, and internet companies) for discounts on items or services that are not reimbursable by any Federal health care program.

Whether an across-the-board waiver of any out-of-pocket beneficiary copayments for medical services covered by the national Eye Care Project constitutes grounds for the imposition of a sanction under section 1128A(a)(5) of the Act.

Whether an arrangement whereby an independent physician association would acquire an equity interest in a managed care organization would constitute grounds for the imposition of sanctions under the anti-kickback statute, section 1128B(b) of the Social Security Act (the "Act"), the exclusion authority for kickbacks.