Browse Advisory Opinions

Regarding a proposal from a group purchasing organization ("GPO") to serve as a purchasing agent on behalf of certain GPO-affiliated health care facilities on the same terms and conditions that apply to its unaffiliated members.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company would contract indirectly with hospitals for 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 arrangement under which a hospital has established a caregiver center that provides or arranges for free or reduced-cost support services to caregivers in the local community.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby insurance companies would contract indirectly 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 federally qualified health center look-alike's proposal to provide information technology items and services, without charge, to a county Department of Health's clinic to facilitate telemedicine encounters.

Regarding an arrangement where a company that manufactures, distributes, and sells medical device and pharmaceutical products provides a limited number of free sample ostomy products to patients and contracts with a third party to conduct follow-up customer satisfaction surveys.

Regarding the effect of your exclusion from Medicare, Medicaid, and all other Federal health care programs.

Regarding an arrangement in which certain neurosurgeons have agreed to implement cost-reduction measures in designated surgical procedures performed at a medical center, and the medical center will share with such neurosurgeons a percentage of its cost savings resulting from these measures.

Regarding your proposal to develop a state-wide network of nursing facilities that would provide discounts on the daily rates they charge to private long-term care insurers and the insurers' policyholders.

Regarding a pharmaceutical manufacturer's proposal to collaborate with a trade association, a Medicare Advantage plan, and a hospital system to implement, fund, and evaluate a pilot program to provide the Medicare Advantage plan pharmacists who conduct medication therapy management services with new technology that would permit real-time electronic access to patient discharge information.

Regarding a proposal by a nonprofit, tax-exempt, charitable corporation to provide financially needy Medicare beneficiaries with assistance with premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medigap, and Medicare Advantage.

Regarding the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies, whereby an insurance company 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 a retail pharmacy chain's proposal to allow Federal health care program beneficiaries to participate in a paid membership program that includes discounts on certain prescriptions and clinic services.

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

Regarding a pharmaceutical manufacturer's proposal to replace products that require specialized handling that could not be administered to patients for certain reasons, at no additional charge to the purchaser.

Regarding a hospital outpatient facility's proposal to reduce or waive, on a non-routine, unadvertised basis, cost-sharing amounts owed by financially needy Medicare beneficiaries for items and services furnished in connection with a clinical research study.

Regarding a hospital system's proposal to provide free or reduced-cost lodging and meals to certain financially needy patients.

Regarding a proposed arrangement in which grants would be provided by a non-profit, charitable organization to financially needy Medicare beneficiaries in order to subsidize their costs of medical care.

Regarding: (i) a proposal to waive cost-sharing obligations incurred by individuals for health care services required for participation in a government-funded clinical research study (the "Proposed Arrangement"); and (ii) the payment of a stipend to study participants for the time and effort required to participate in study visits.

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