Browse Advisory Opinions

Regarding a critical access hospital’s proposal to offer an arrangement similar to a warranty to patients undergoing certain joint replacement procedures at the hospital.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company contracts with a preferred hospital organization to provide discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, provides a premium credit of $100 off the next renewal premium to policyholders who use a network hospital for an inpatient stay.

Regarding a dental provider’s provision of free routine and emergency dental services to certain indigent residents of skilled nursing facilities and nursing facilities.

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 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.

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 an investment by a health system, certain surgeons, and a management company in an ambulatory surgery center.

Regarding a free drug provided by a pharmaceutical manufacturer to certain patients to whom the manufacturer's drug has been prescribed.

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 pharmaceutical manufacturer's proposal to provide cost-sharing assistance directly to Medicare beneficiaries who are prescribed either of two formulations of its drug.

Regarding 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.

Regarding a hospital's provision of discounted training to a specified fire department's personnel at the hospital's facility.

Regarding 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.