Browse Advisory Opinions

Unfavorable opinion regarding a cochlear implant manufacturer’s proposal to offer and provide a free compatible hearing aid to certain patients, including Federal health care program beneficiaries, who receive one of the cochlear implants it manufactures.

Favorable opinion regarding an employer’s proposal to pay bonuses to its employed physicians based on net profits derived from certain procedures performed by the physicians.

Unfavorable opinion regarding a laboratory company’s proposal to purchase anatomic pathology services from third-party laboratories.

Unfavorable opinion regarding a company’s proposal to assist physicians who perform surgeries for which the company’s services are used with the formation and operation of a turnkey physician-owned entity that would perform those same services.

Favorable opinion regarding: (i) the use of a health technology company’s online health care directory by Federal health care program beneficiaries to search for and book medical appointments with providers and the display of sponsored advertisements to Federal health care program beneficiaries on the directory and certain third-party websites; and (ii) certain proposed changes to the functionality of the directory.

Regarding a charitable organization's proposal to purchase or receive donations of unpaid medical debt owed by qualifying patients from certain types of health care providers and then forgive that debt.

Favorable opinion regarding a proposal to provide a prepaid card to certain individuals, including Federal health care program beneficiaries, to encourage those individuals to return the sample collection kit associated with a colorectal cancer screening test.

Favorable opinion regarding a program to provide a drug for free, for a limited time, to patients who experience a delay in their insurance approval process for the drug.

Favorable opinion regarding financial assistance for transportation, lodging, and meals provided by a drug manufacturer to financially needy pediatric patients and their caregiver(s) in connection with treatment with the manufacturer’s drug.

Regarding a pharmaceutical manufacturer’s proposal to provide up to a specified number of trial units of a long-acting antipsychotic drug to certain hospitals for inpatient use.

Regarding an arrangement in which a county and its department of public health’s emergency medical services division sublease certain space and lease certain furniture and equipment to a private ambulance company that has been granted an exclusive contract for the provision of emergency ambulance transports in certain parts of the county.

Regarding a hospital’s utilization of its employed nurse practitioners to perform services that traditionally have been performed by a patient’s attending physician in certain medical units.

Regarding a proposal whereby certain pharmaceutical manufacturers would: (i) fund, through Requestor, cost-sharing subsidies for the manufacturers’ Part D oncology drugs; (ii) fund, through Requestor, specified programs and eligible beneficiaries’ health insurance premiums; and (iii) finance Requestor’s operating costs.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding a proposed restructuring of financial relationships, which includes the forgiveness of debt, between a health system and a nearby clinic.

Regarding the provision of a gift card to certain Medicare Advantage plan enrollees who complete specific steps in an online patient education program.

Regarding a proposal to use donations to cover: (i) specialized care furnished to veterans who meet certain criteria; and (ii) certain out-of-pocket expenses related to that specialized care.

Regarding an ophthalmology practice’s proposed continuing education programs for local optometrists and four financing options to fund the programs.

Regarding a durable medical equipment manufacturer’s arrangements with two financial institutions to make zero-interest financing available to qualified customers.

Regarding financial assistance for travel, lodging, and other expenses provided by a pharmaceutical manufacturer to certain patients prescribed the manufacturer's drug.