Browse Advisory Opinions

Concerning the "coordination of benefits" provisions of a provider agreement between ... a health maintenance organization or "HMO", and the skilled nursing facilities in its provider network (the "Nursing Facilities".)

Concerning a proposed grant from a hospital to a community health center to defray the costs of providing services to uninsured patients.

Concerning a political subdivision of a State that owns and operates an ambulance service and that treats the operating revenues received from local taxes as payment of otherwise applicable copayments and deductibles due from the residents.

Concerning a municipal corporation that owns and operates an ambulance service and that treats the operating revenues received from local taxes as payment of otherwise applicable copayments and deductibles due from the residents.

Concerning an exclusive contract between a city and an ambulance company for the provision of emergency medical services for city residents that includes a requirement that the contracting ambulance company waive out-of pocket Medicare copayments for city residents.

Concerns a comprehensive program that a manufacturer of therapeutic mattresses and other support services markets and sells to State-licensed nursing facilities to manage pressure ulcers.

Concerning the practice of accepting reimbursement from third-party payors plus certain payments.

Concerning "payments by vendors to a group purchasing organization (GPO) owned by entities affiliated with health care providers that purchase items covered by the GPO's vendor contracts."

Concerning "a proposed lease of cardiac diagnostic equipment to emergency medical services providers for a nominal charge."

Concerning "whether proposed contracts for discounted services between a Federally-recognized Indian tribe and local hospitals would constitute grounds for the imposition of exclusions under section 1128(b)(7) of the Act or civil money penalties under section 1128A(a)(7) of the Act."

Concerning "a proposed arrangement between a hospital and a new physician whom the hospital would like to recruit to practice within its service area."

Concerning an annual charity golf tournament for which some of its vendors and suppliers pay money as sponsors and tournament participants.

Concerning a proposed arrangement in which a hospital will share with a group of cardiac surgeons a percentage of the hospital's cost savings.

Regarding a program designed by a drug manufacturer to promote an expensive new drug used to prevent certain respiratory infections in pediatric patients.

Regarding approval of a charitable donation from a hospital to a volunteer emergency medical services provider to pay for new equipment and paramedic training.

Whether a hospital proposal to provide free restocking of medical supplies and drugs for volunteer emergency medical services would violate the anti-kickback statute.

Concerning whether a housing referral for the elderly would be subject to sanctions arising under the anti-kickback statute.

Regarding free transportation services that a hospital offers to certain patients who have been referred to the hospital for extended courses of treatment involving.

Concerning proposed donation of its ownership interest in a portion of a medical office building to an agency of the State for use by the Medical School.

Whether waiving Medicare Part A and Part B copayment and deductible obligations for participants in a clinical study sponsored by the Health Care Financing Administration and the National Heart, Lung, and Blood Institute.