Browse Advisory Opinions

Regarding the use of a “preferred hospital” network as part of Medicare Supplemental Health Insurance (“Medigap”) policies, whereby [name redacted] would indirectly contract with hospitals for discounts on the otherwise-applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a premium credit of $100 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 three insurance companies would indirectly contract with hospitals for discounts on the otherwise-applicable Medicare inpatient deductibles for their policyholders and, in turn, would provide a premium credit of $100 to policyholders who use a network hospital for an inpatient stay.

Regarding a proposal by a nonprofit, tax-exempt, charitable organization to subsidize Medicare Part D premium and cost-sharing obligations owed by financially needy patients with end-stage renal disease and chronic kidney disease.

regarding a state academic medical center that in certain circumstances offers pregnant women: (1) transportation aid to and from the campus hospital for delivery; and (2) short-term lodging near the campus hospital.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby [names redacted] (the "Requestors") would indirectly contract with hospitals for discounts on the otherwise-applicable Medicare inpatient deductibles for their policyholders and, in turn, would provide a premium credit of $100 to policyholders who use a network hospital for an inpatient stay.

Regarding a non-profit, tax-exempt, charitable organization's proposal to provide financial assistance with copayment obligations, health insurance premiums, and insurance deductibles to patients, including Medicare and Medicaid beneficiaries, receiving treatment for [disease state redacted].

Regarding a nonprofit, tax-exempt, charitable organization's proposal to provide assistance with out-of-pocket expenses for outpatient prescription drugs to financially needy insured patients, including, but not limited to, Medicare and Medicaid beneficiaries.

Regarding a proposal by a tax-exempt charitable organization to provide financial assistance with cost-sharing obligations for certain genetic tests to financially needy individuals, including but not limited to Medicare and Medicaid beneficiaries, and an existing practice of providing vouchers for free genetic tests to individuals who are uninsured or whose insurance does not cover genetic tests.

Regarding an arrangement by a nonprofit, tax-exempt, charitable organization to subsidize cost-sharing and premium obligations owed by financially needy Medicare or Medicaid patients with certain chronic diseases.

Regarding a proposal by a nonprofit, tax-exempt, charitable organization to provide financially needy persons who have certain diseases with grants to defray the costs of premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medicare Supplementary Health Insurance, and Medicare Advantage.

Regarding an existing arrangement by a nonprofit, tax-exempt, charitable organization to subsidize cost sharing, and its proposal to subsidize premium obligations, associated with outpatient drug treatment owed by financially needy Medicare or Medicaid patients with certain chronic diseases.

Regarding an arrangement in which a nonprofit, tax-exempt, charitable organization provides certain therapy management services and assistance with Medicare cost-sharing obligations to financially needy Medicare beneficiaries undergoing medical treatment for certain diseases.

Regarding a hospital system's proposal to lease non-clinician employees and to provide operational and management services to a related psychiatric hospital for an amount equal to the hospital system's fully loaded costs.

Regarding the proposed use of a "preferred hospital" network in connection with a Medigap plan, whereby an insurer would indirectly contract with hospitals for discounts on the otherwise applicable Medicare inpatient deductibles for its policyholders and, in turn, would provide a renewal premium credit of $100 to policyholders who use a network hospital for an inpatient stay.

Regarding a nonprofit, tax-exempt, charitable organization's proposal to provide financial assistance to individuals with chronic diseases, including cancer, to assist with the costs of health insurance and drug and device therapies.

Regarding a laboratory's proposal to enter into agreements with physician practices to provide all laboratory services for the practices' patients and waive all fees for those practices' patients who are enrollees of certain insurance plans that require the patients to use a different laboratory.

Concerning a nonprofit, tax-exempt, charitable organization's proposal to provide assistance with copayment obligations to financially needy patients, including Medicare and Medicaid beneficiaries, diagnosed with Crohn's disease or ulcerative colitis.

Concerning patient assistance programs that provide funding for premium assistance and certain other medical expenses to [disease redacted] patients in financial need.

Concerning a health insurer's proposal to pay the Medicare Part B premium costs for Medicare-eligible individuals with End-Stage Renal Disease who are enrolled in a group health plan offered by the insurer and receiving dialysis services.

Concerning a proposal whereby a county would not bill bona fide county residents otherwise applicable cost-sharing amounts due in connection with emergency ambulance services provided by the local fire department and a volunteer rescue company, but would instead use tax revenues to cover the unpaid cost-sharing amounts.