Browse Advisory Opinions

Concerning an existing arrangement and a proposed arrangement involving contracts between a durable medical equipment ("DME") supplier and various independent diagnostic testing facilities ("IDTF"), pursuant to which IDTF staff members perform certain services on behalf of the DME supplier.

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 proposed payment plans for emergency and non-emergency transportation services provided for Medicaid-covered residents of skilled nursing facilities.

Concerning the amendment of an exclusive contract for emergency ambulance transport services between a municipality and an ambulance company.

Concerning a proposed arrangement between a sleep testing provider and a hospital to provide certain sleep testing equipment and services, including marketing services, for a hospital-owned sleep testing facility.

Regarding an arrangement between a sleep testing provider and a hospital to provide certain sleep testing equipment and services, including marketing services, for a hospital-owned sleep testing facility.

Concerning two potential donations to support programs that provide services to children and families, which were included as part of a private settlement of an administrative dispute.

Concerning an arrangement between a sleep testing provider and a hospital to provide certain sleep testing equipment and services for a hospital-owned sleep testing facility.

Concerning a hospital's proposal to provide insurance pre-authorization services free of charge to patients and physicians.

Concerning a state and county health services district's proposal to transfer funds to the county in which it operates a hospital to support construction of a new communications and emergency operations center.

Concerning two affiliated corporate entities that each own and operate a freestanding radiation oncology center proposing to provide the services of a dietitian and social worker at no additional charge to each center's Medicare cancer patients as part of the patients' treatment.

Concerning a proposal by several imaging providers to offer free insurance pre-authorization services to patients and physicians.

Concerning a joint venture to provide EMS and scheduled ambulance transportation services.

Concerning an exclusive contract for ambulance transport services between a municipality and an ambulance company that provides reimbursement to the city for the costs of providing emergency dispatch services and for monitoring the quality of the emergency ambulance operation.

Concerning an exclusive contract for ambulance transport services between a township and an ambulance company that provides for reimbursement to the township for the costs of providing emergency dispatch services.

Regarding a proposal to waive cost-sharing obligations for protocol-required clinical services and oxygen therapy provided to Medicare beneficiaries who participate in the Long-term Oxygen Treatment Trial sponsored by the National Heart, Lung, and Blood Institute and the Centers for Medicare and Medicaid Services.

Concerning a proposed arrangement under which a newly formed legal entity would provide purely administrative insurance preauthorization processing and submission services for various radiology and imaging centers.

Concerning a laboratory's proposal to provide services consisting of the labeling of test tubes and specimen collection containers at no cost to dialysis facilities.

Concerning a county's exclusive contracts for emergency ambulance services, which set out how private ambulance companies should absorb the costs of transporting uninsured arrestees and reimburse the county for the costs of providing certain administrative and emergency dispatch services.