Browse Advisory Opinions

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 financial assistance for transportation, lodging, and meals provided by a pharmaceutical manufacturer to certain patients potentially eligible for treatment with the pharmaceutical manufacturer’s drug.

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 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 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 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 program where a pharmaceutical manufacturer provides financial assistance for travel, lodging, and other expenses to certain patients prescribed the manufacturer's drug.

Regarding 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.

Regarding 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.

Regarding 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.

Regarding 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").

Regarding 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.

Regarding proposed donations from a charitable trust and an individual donor to a medical research institute.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract indirectly with hospitals for 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 (the "Proposed Arrangement").

Regarding a health plan's proposal to pay its contracted providers and clinics to increase the amount of Early and Periodic Screening, Diagnostic, and Treatment services that they provide to the health plan's enrolled Medicaid beneficiaries.

Regarding a surgical device and wound care product manufacturer's proposal to offer hospital customers a warranty program covering a suite of three products.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract indirectly with hospitals for 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 proposal by certain government-operated fire departments and fire protection districts to enter into a mutual aid agreement to provide backup emergency ambulance services and to bill for such services according to the billing practices in the jurisdiction where such services are rendered.

Regarding a proposal from a group purchasing organization ("GPO") to serve as a purchasing agent on behalf of certain GPO-affiliated health care facilities on the same terms and conditions that apply to its unaffiliated members.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract indirectly with hospitals for 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.