All Advisory Opinions
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AO 21-06
Posted June 29, 2021Regarding a spinal implant manufacturer’s proposal to offer its products to hospitals at a reduced price if the hospitals agree to assume certain duties related to the products.
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AO 21-05
Posted May 20, 2021Regarding 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.
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AO 21-04
Posted May 19, 2021Regarding 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.
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AO 21-03
Posted May 17, 2021Regarding 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.
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AO 21-02
Posted April 29, 2021Regarding an investment by a health system, certain surgeons, and a management company in an ambulatory surgery center.
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AO 21-01
Posted March 23, 2021Regarding a free drug provided by a pharmaceutical manufacturer to certain patients to whom the manufacturer's drug has been prescribed.
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AO 20-09
Posted December 31, 2020Regarding a program where a pharmaceutical manufacturer provides financial assistance for travel, lodging, and other expenses to certain patients prescribed the manufacturer's drug.
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AO 20-08
Posted December 30, 2020Regarding a federally qualified health center's proposal to offer gift cards to incentivize certain pediatric patients to attend rescheduled preventive and early intervention care appointments.
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AO 20-07
Posted December 28, 2020Regarding 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.
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AO 20-06
Posted December 23, 2020Regarding 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.
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AO 20-05
Posted September 23, 2020Regarding a pharmaceutical manufacturer's proposal to provide cost-sharing assistance directly to Medicare beneficiaries who are prescribed either of two formulations of its drug.
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AO 20-04
Posted July 24, 2020Regarding 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.
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AO 20-03
Posted July 1, 2020Regarding an arrangement under which a discount medical plan organization ("DMPO") pays chiropractors and chiropractic clinics a fee for each new DMPO member referred by the chiropractor or chiropractic clinic.
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AO 20-01
Posted January 13, 2020Regarding a hospital's provision of discounted training to a specified fire department's personnel at the hospital's facility.
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AO 19-06
Posted December 17, 2019Regarding a supermarket's proposal to expand its current loyalty program to allow customers to earn rewards points on out-of-pocket costs paid in connection with pharmacy purchases.
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AO 19-05
Posted September 11, 2019Regarding a proposed purchase of real estate from a limited liability company owned, in part, by an excluded individual.
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AO 19-04
Posted September 10, 2019Regarding a technology company's proposal to make visible to Federal health care program beneficiaries: (i) its online healthcare directory for searching and booking medical appointments, where healthcare professionals pay, or would pay, per-click or per-booking fees to be listed in the directory; and (ii) sponsored advertisements on its online healthcare directory and third-party websites, where healthcare professionals pay, or would pay, per-impression or per-click fees for such sponsored advertisements (the "Proposed Arrangement").
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AO 19-03
Posted March 7, 2019Regarding a program offered by a medical center that provides free, in-home follow-up care to eligible individuals with congestive heart failure (the "Current Arrangement") and the proposed expansion of this program to include certain individuals with chronic obstructive pulmonary disease.
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AO 19-02
Posted January 29, 2019Regarding a pharmaceutical manufacturer's proposal to loan, on a temporary basis, a limited- functionality smartphone to financially needy patients who do not have the technology necessary to receive adherence data from a sensor embedded in prescribed antipsychotic medication.
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AO 19-01
Posted January 14, 2019Regarding a charitable pediatric clinic's arrangement under which the clinic waives cost-sharing amounts in certain circumstances.