Browse Advisory Opinions

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

Regarding its proposal to employ an individual who is excluded from participation in Federal health care programs to perform marketing tasks relating to workers’ compensation programs.

Regarding (i) a modification to OIG Advisory Opinion 15-14, issued to the requestor on November 13, 2015, to include within the scope of that opinion, the requestor’s proposal to provide financial assistance for certain past magnetic resonance imaging tests; and (ii) a second arrangement regarding the distribution of certain cooling and mobility items, ancillary to the arrangement addressed in OIG Advisory Opinion 15-14.

Regarding a non-profit, tax-exempt, charitable organization's program to help financially needy patients, including Medicare and Medicaid beneficiaries, obtain magnetic resonance imaging for the diagnosis or ongoing evaluation of [disease state redacted] (the "Arrangement").

Regarding a proposed arrangement pursuant to which Requestor would compensate hospitals for certain specimen collection services for laboratory tests furnished by Requestor.

Regarding an arrangement whereby certain existing patients of Requestor use limited-use smartphones that Requestor loaned to such patients to facilitate access to telehealth services.

Regarding an arrangement whereby certain physicians have an ownership interest in a medical device company that manufactures products that may be ordered by the physician owners and a physician spouse of one of the physician owners.

Regarding the provision of free genetic testing and genetic counseling services to individuals who meet specified clinical criteria.

Regarding the proposed subsidization of certain Medicare cost-sharing obligations in the context of a clinical trial.

Regarding a program through which Requestor provides certain individuals access to digital contingency management and related tools to treat substance use disorders, where the Program is funded by customers, which could include individuals’ health care providers or suppliers.

Regarding Requestors’ proposal to pay salaries to, and nurse aide certification program tuition costs on behalf of, new employees who Requestors have hired to work as certified nurse aides for Requestors’ home health agencies.