Browse Advisory Opinions

Concerning an arrangement in which a hospital pays a cardiology group compensation that includes a performance bonus based on implementing certain patient service, quality, and cost savings measures associated with procedures performed at the hospital's cardiac catheterization laboratories.

Concerning a Federally qualified health center's proposal to offer grocery store gift cards to certain patients in capitated managed care plans as an incentive to receive health screenings or other clinical services.

Concerning a hospital's proposal to provide free access to an electronic interface to community physicians and physician practices that would allow those physicians and practices to transmit orders for certain services to, and receive the results of those services from, the hospital.

Concerning four proposed arrangements involving a pharmacy company's provision of items and services to community homes in which its customers reside.

Concerning a proposed arrangement whereby three municipalities will reciprocally waive the otherwise applicable cost-sharing obligations of each other's bona fide residents when providing backup emergency medical services transportation to such individuals in certain circumstances.

Concerning a proposal for a hospice to establish a volunteer program to provide non-skilled services to terminally ill patients who do not qualify for hospice care.

Concerning a proposal to waive cost-sharing amounts on a non-routine, unadvertised basis for insured patients, including Federal health care program beneficiaries, based on individualized determinations of financial need.

Concerning a rewards program under which consumers would earn gasoline discounts based on the amount they spend on purchases in retail supermarkets, including cost-sharing amounts paid in connection with items covered by Federal health care programs purchased in the in-store pharmacies.

Concerning a proposal by a hearing aid supplier to begin billing Medicare for certain audiometric testing, while continuing to offer free hearing tests to prospective hearing aid customers.

Concerning a proposed bundle billing arrangement for basic life support advanced life support joint responses.

Concerning an ambulance supplier's proposal to routinely waive cost-sharing amounts for emergency medical services rendered on a part-time basis.

Concerning a proposal by a radiology group to offer free insurance pre-authorization services to physicians and patients.

Concerning reduced-rate arrangements for the provision of therapy services at state-operated veterans' homes.

Concerning a proposal for an independent diagnostic testing facility to hire a doctor to read and interpret test results when that doctor is closely related to the owners of the independent diagnostic testing facility and is employed by a company that also employs other potential referral sources.

Concerning an exclusive arrangement between a county and an emergency medical services company whereby the company provides emergency ambulance services to county residents.

Concerning two proposals by an anesthesia services provider to enter into contracts with physician-owned professional corporations or limited liability companies to provide anesthesia services.

Concerning a rewards program under which consumers would earn gasoline discounts based on the amount spent on purchases in retail stores and pharmacies, including cost-sharing amounts paid in connection with items covered by Federal health care programs.

Concerning certain aspects of an exclusive contract for emergency transport services between a municipality and an ambulance company that reimburses the municipality for dispatch services and for certain costs incurred when municipal firefighters drive transports.

Concerning a proposal by a municipal fire department to share certain costs related to dispatch and other services with hospital-based ambulance providers that participate in the local 911 emergency dispatch system.

Concerning a proposal to operate a website that would display coupons and advertising from health care providers, suppliers, and other entities.