Browse Advisory Opinions

Regarding a proposed joint venture for the provision of therapy services.

Regarding the proposed subsidization of beneficiary cost-sharing obligations for Medicare-covered services provided as part of a clinical trial.

Regarding a pain management company’s proposal to retain net profits from services provided by an employed certified registered nurse anesthetist pursuant to a reassignment of billing rights.

Regarding a dental provider’s provision of free routine and emergency dental services to certain indigent residents of skilled nursing facilities and nursing facilities.

Regarding a web-based platform where health care facilities and clinicians would, in particular circumstances, remit to patients and the patients' payors a portion of the claims for certain services for which payment may be made by the Medicare program as a secondary payor.

Regarding a management company's provision of below fair market value Medicaid enrollment application assistance services to certain individuals and affiliated skilled nursing facilities' payments for those services in particular circumstances.

Regarding a health plan's proposal to pay its contracted providers and clinics to increase the amount of Early and Periodic Screening, Diagnostic, and Treatment services that they provide to the health plan's enrolled Medicaid beneficiaries.

Regarding a proposal by certain government-operated fire departments and fire protection districts to enter into a mutual aid agreement to provide backup emergency ambulance services and to bill for such services according to the billing practices in the jurisdiction where such services are rendered.

Regarding an arrangement under which a hospital has established a caregiver center that provides or arranges for free or reduced-cost support services to caregivers in the local community.

Regarding a federally qualified health center look-alike's proposal to provide information technology items and services, without charge, to a county Department of Health's clinic to facilitate telemedicine encounters.

Regarding a pharmaceutical manufacturer's proposal to collaborate with a trade association, a Medicare Advantage plan, and a hospital system to implement, fund, and evaluate a pilot program to provide the Medicare Advantage plan pharmacists who conduct medication therapy management services with new technology that would permit real-time electronic access to patient discharge information.

Regarding a retail pharmacy chain's proposal to allow Federal health care program beneficiaries to participate in a paid membership program that includes discounts on certain prescriptions and clinic services.

Regarding a hospital outpatient facility's proposal to reduce or waive, on a non-routine, unadvertised basis, cost-sharing amounts owed by financially needy Medicare beneficiaries for items and services furnished in connection with a clinical research study.

Regarding: (i) a proposal to waive cost-sharing obligations incurred by individuals for health care services required for participation in a government-funded clinical research study (the "Proposed Arrangement"); and (ii) the payment of a stipend to study participants for the time and effort required to participate in study visits.

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

Regarding an arrangement in which a nonprofit, tax-exempt, charitable organization provides certain therapy management services and assistance with Medicare cost-sharing obligations to financially needy Medicare beneficiaries undergoing medical treatment for certain diseases.

Regarding a hospital system's proposal to lease non-clinician employees and to provide operational and management services to a related psychiatric hospital for an amount equal to the hospital system's fully loaded costs.

Regarding a laboratory's proposal to enter into agreements with physician practices to provide all laboratory services for the practices' patients and waive all fees for those practices' patients who are enrollees of certain insurance plans that require the patients to use a different laboratory.

Regarding an entity's practice of advertising and providing free diapers and play yards in connection with the services it provides under a state's home visiting program for at-risk mothers and infants.

Concerning an existing arrangement under which a township uses tax revenues to cover out-of-pocket amounts owed for basic life support emergency ambulance services received by local residents.