Browse Advisory Opinions

Concerning a proposed arrangement by which a hospital would share with a physician-owned entity certain performance-based compensation available to the hospital under a quality and efficiency agreement with a private insurer.

Concerning a proposal for a physician practice group to provide space, equipment and personnel to other physician practice groups through block leases.

Concerning an arrangement under which a medical center has agreed to share with groups of orthopedic surgeons and a group of neurosurgeons a percentage of the medical center's cost savings arising from the surgeons' implementation of a number of cost reduction measures in spine fusion surgical procedures.

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 proposed arrangement by which a health care system would provide prompt pay discounts to Federal health care program beneficiaries and other insured patients in connection with both inpatient and outpatient care.

Concerning a marketing and research company's proposal to encourage physicians and other health care professionals to complete online surveys by offering them the opportunity to designate a public charity to which the company or one of its clients would make a monetary charitable contribution.

Concerning a non-profit corporation's program that arranges for pharmaceutical manufacturer patient assistance programs to provide donated drugs to free clinics and Federally qualified health centers (FQHCs) for use by financially-needy patients who do not have any form of outpatient prescription drug insurance coverage.

Concerning a cash donation to a senior residence program from a charitable foundation which shares ties with the program and with a local health system.

Concerning payment of certain compensation owed by the organizer of a dental preferred provider organization to a dental network marketing and management company in connection with the use of the dental network by a Federal employee health benefits plan.

Concerning a proposed arrangement for a durable medical equipment ("DME") manufacturer to provide advertising assistance and reimbursement consulting services to some of its customers.

Concerning a proposal by a municipality, which provides emergency medical services through a municipally owned and operated ambulance service, to treat revenue received from local taxes as payment of otherwise applicable cost-sharing amounts due from municipal residents.

Concerning a research hospital's practice of providing drugs and supplies to its affiliates for administration to the hospital's patients receiving treatment at the affiliates.

Concerning two proposed programs to manage the delivery of durable medical equipment and orthotics to be offered to physicians by a durable medical equipment and orthotics manufacturer and supplier.

Concerning a proposal by a municipal corporation that provides emergency medical services (EMS) through its fire department to treat revenue received from certain local taxes as payment of otherwise applicable cost-sharing amounts due from residents and nonresident taxpayers who receive EMS within the municipality.

Concerning a laboratory's proposal to provide free blood collection supplies to physicians and pay those physicians for the collection of blood samples.

Concerning a proposal to provide laboratory employees and related equipment and supplies at no cost to dialysis facilities for the purpose of preparing specimens for delivery to the laboratory.

Concerning a municipal corporation that owns and operates an ambulance service and that proposes to treat revenue received from local real estate taxes as payment of otherwise applicable cost-sharing amounts due from residents.

Concerning a municipality that owns and operates an ambulance service and that proposes to treat revenue received from local income taxes as payment of otherwise applicable cost-sharing amounts due from taxpayers who receive ambulance services within the municipality.

Concerning a proposal by a physician group practice to develop and own a comprehensive physical therapy center and to lease the center's space, equipment, and personnel to physicians with patients requiring physical therapy services.

Concerning a marketing company's arrangement to design, develop, and implement physician surveys conducted on behalf of pharmaceutical firms.