Browse Advisory Opinions

Concerning an online referral service whereby post-acute care providers would pay a fee to electronically receive and respond to referral requests from hospitals for post-discharge care.

Concerning the formation of a new long-term care pharmacy and the agreement to manage all of its day-to-day operations and provide all personnel and related services necessary for its operation.

Concerning a network of pediatric charity hospitals plan to: (1) begin billing third-party payers, including Federal health care programs, for services rendered, and waive all cost-sharing amounts without regard to patients' financial need; (2) adopt a new financial need-based policy of providing lodging assistance, in limited circumstances, to patients, including Federal health care program beneficiaries, and their families; and (3) adopt a new financial need-based policy of providing transportation assistance, in limited circumstances, to patients, including Federal health care program beneficiaries, and their families.

Concerning a proposal to extend one night of free post-surgical accommodations to pediatric tonsillectomy patients insured by Federal health care programs.

Concerning a joint venture between two components of an academic medical center to build and own an ambulatory care center on a 50-50 basis.

Concerning a company's proposal to encourage health care providers to use its online program for scheduling meetings with manufacturer representatives by offering the provider an opportunity to select a public charity to which the company would make a monetary, charitable contribution in the provider's name.

Concerning a proposed rewards program for referrals of prospective residents to the requestor's continuing care retirement communities by current residents and employees.

Concerning an investment in an ambulatory surgery center by a group of surgeons and a health care corporation that owns hospitals.

Concerning a proposal for a health care system to provide $10 gift cards to patients whose service expectations were not met.

Concerning a proposal to offer a free trial prescription program to hemophilia A patients who are Federal health care program beneficiaries.

Concerning a proposed arrangement by which a health care system would provide prompt pay discounts to Federal health care program beneficiaries and other insured patients in connection with both inpatient and outpatient care.

Concerning a marketing and research company's proposal to encourage physicians and other health care professionals to complete online surveys by offering them the opportunity to designate a public charity to which the company or one of its clients would make a monetary charitable contribution.

Concerning the physicians' on-call coverage and uncompensated inpatient care arrangement employed by a medical center.

Concerning a reward program under which certain consumers receive an annual reward based on the amount spent on purchases, including purchases of items covered by Federal health care programs.

Concerning the use of rewards from credit card issuers for the benefit of a residential health care facility and its employees.

Concerning a volunteer services program for the provision of specialty medical care and professional development in rural areas, through which volunteers' travel costs would be covered.

Concerning an arrangement under which a managed care company will disburse pay-for-performance financial incentives on behalf of a State's Medicaid program.

Concerning a geriatric group practice's proposal to employ certain primary care physicians to serve as consultants in connection with the group's nursing home patients.

Concerning a proposed arrangement that would involve a company developing and managing distinct part inpatient rehabilitation units located within general acute care hospitals in exchange for a management fee calculated on a per patient per day basis.

Concerning a proposed program by a provider of home health care services to provide free medical-alert pagers and pager monitoring service to homebound patients during the period such patients are receiving the company's home health services.