Browse Advisory Opinions

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.

Concerning a lifestyle modification program for individuals with chronic disease that uses physicians to monitor and evaluate the program's participants.

About a proposed cost-savings program pursuant to which (the Hospital) would reward its non-physician employees for submitting cost-savings suggestions.

Concerning an arrangement to provide various services free of charge to patients with terminal illnesses.

Concerning a consulting firm's contractual payment arrangements for the performance of auditing services to identify hospital undercharges and overcharges associated with private payors.

Regarding rural telemedicine network arrangement implemented and operated pursuant to Federal grants.

Regarding certain arrangements for discounted pathology services provided to physicians.

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.

Concerning a corporate sponsorship program between Drug Company A ("Company A") and Charity B ("Charity B") (the "Proposed Arrangement").

Concerning an arrangement sponsored by Coalition A (the "Coalition") to provide psychotherapy services at free or reduced prices using residents from local teaching facilities as clinicians (the "Arrangement").

A proposed contractual arrangement between a self-insured employer health plan and a single-specialty managed care organization to provide managed podiatry benefits for the employer's retirees.

Whether an arrangement to provide for personal appearances by podiatrists to certain retail stores constitutes grounds for sanctions under the anti-kickback statute.

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 the longstanding policy of a hospital, specializing in pediatric oncology research, of not billing its patients for any amounts associated with their treatment, including copayment amounts.

Whether a proposed agreement (the "Proposed Agreement"), pursuant to which Hospital District No.1 ("District One" or the "Requestor") would locate a medical clinic within the geographic boundaries of Hospital District No. 2 ("District Two"), would constitute grounds for sanctions under the anti-kickback statute, section 1128B(b) of the Social Security Act (the "Act"), the exclusion authority for kickbacks.