Browse Advisory Opinions

Regarding the effect of your exclusion from Medicare, Medicaid, and all other Federal health care programs.

Regarding your proposal to develop a state-wide network of nursing facilities that would provide discounts on the daily rates they charge to private long-term care insurers and the insurers' policyholders.

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 proposed arrangement in which grants would be provided by a non-profit, charitable organization to financially needy Medicare beneficiaries in order to subsidize their costs of medical care.

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 local health care district's proposal to cooperate with another district to jointly fund the cost of a transportation coordinator to educate patients about local transportation options and subsidize certain forms of transportation for patients with financial need.

Regarding a proposal to install a computerized point-of-care vaccine storage and dispensing system in physicians' offices for the physicians' use.

Regarding the effect of exclusion from Medicare, Medicaid, and all other Federal health care programs.

Concerning an online service that would facilitate the exchange of information between health care practitioners, providers, and suppliers.

Concerning contracts under which a placement agency is compensated for referring new residents to senior communities where they may eventually receive services paid for by Federal health care programs.

Concerning a clinical laboratory company's proposal to establish a subsidiary that would contract with physician practices to enable the practices to provide laboratory services to the physicians' patients who are not Federal health care program beneficiaries.

Concerning a Federally qualified health center's proposal to offer grocery store gift cards to certain patients in capitated managed care plans as an incentive to receive health screenings or other clinical services.

Concerning a proposal for a hospice to establish a volunteer program to provide non-skilled services to terminally ill patients who do not qualify for hospice care.

Concerning a proposal to waive cost-sharing amounts on a non-routine, unadvertised basis for insured patients, including Federal health care program beneficiaries, based on individualized determinations of financial need.

Concerning a rewards program under which consumers would earn gasoline discounts based on the amount they spend on purchases in retail supermarkets, including cost-sharing amounts paid in connection with items covered by Federal health care programs purchased in the in-store pharmacies.

Concerning a rewards program under which consumers would earn gasoline discounts based on the amount spent on purchases in retail stores and pharmacies, including cost-sharing amounts paid in connection with items covered by Federal health care programs.

Concerning a proposal to operate a website that would display coupons and advertising from health care providers, suppliers, and other entities.

Concerning a proposed arrangement under which an entity would furnish allergy testing and immunotherapy laboratory services within various primary care physicians' medical offices.

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.