Browse Advisory Opinions

Concerning a proposal to establish a group purchasing organization ("GPO") that would be wholly owned by an entity that also wholly owns many of the potential participants in the GPO, and to pass through to participants in the GPO a portion of the payments received by the GPO from vendors.

Concerning the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies.

Concerning a proposed arrangement under which an entity would furnish allergy testing and immunotherapy laboratory services within various primary care physicians' medical offices.

Concerning a hospital's domiciliary services program that provides transportation, lodging, and meal assistance to certain patients and their family members.

Concerning a proposal under which physicians would invest in a company that would provide pathology laboratory management services to a third party.

Concerning a proposal for ophthalmologists in a group practice to co-manage cataract surgery patients, including Medicare beneficiaries, with optometrists external to that group practice who would separately charge the beneficiaries for services related to premium refractive intraocular lenses that are not covered by the Medicare program.

Concerning a health system's proposal to enter into arrangements to provide neuro emergency clinical protocols and immediate consultations with stroke neurologists via telemedicine technology to certain community hospitals.

Concerning a proposal for a county which provides emergency medical services ("EMS") transportation through its fire department, to treat revenue received from taxes as payment of otherwise applicable cost-sharing amounts owed by bona fide county residents for EMS transportation to hospitals.

Concerning two proposals by a supplier that furnishes medical supplies, equipment, and related services to enter into a contract with a skilled nursing facility to provide such items and services.

Concerning an arrangement under which a company that sells a variety of health care management services will disburse pay-for-performance financial incentives on behalf of a state's Medicaid program.

Concerning an existing arrangement and a proposed arrangement involving contracts between a durable medical equipment ("DME") supplier and various independent diagnostic testing facilities ("IDTF"), pursuant to which IDTF staff members perform certain services on behalf of the DME supplier.

Concerning the use of a "preferred hospital" network as part of Medicare Supplemental Health Insurance ("Medigap") policies.

Concerning the expansion of a vaccine reminder program to include entities that insure and treat patients covered by a fee-for-service Federal health care program.

Concerning an online referral service whereby post-acute care providers would pay a fee to electronically receive and respond to referral requests from hospitals for post-discharge care.

Concerning a Training Affiliation Agreement between a military medical group and a public community hospital.

Concerning the formation of a new long-term care pharmacy and the agreement to manage all of its day-to-day operations and provide all personnel and related services necessary for its operation.

Concerning a complimentary local transportation arrangement whereby a hospital would transport patients from physician offices located on, or contiguous to, the hospital's campus to the hospital if the patients require further treatment and cannot transport themselves.

Concerning a network of pediatric charity hospitals plan to: (1) begin billing third-party payers, including Federal health care programs, for services rendered, and waive all cost-sharing amounts without regard to patients' financial need; (2) adopt a new financial need-based policy of providing lodging assistance, in limited circumstances, to patients, including Federal health care program beneficiaries, and their families; and (3) adopt a new financial need-based policy of providing transportation assistance, in limited circumstances, to patients, including Federal health care program beneficiaries, and their families.

Concerning proposed payment plans for emergency and non-emergency transportation services provided for Medicaid-covered residents of skilled nursing facilities.

Concerning the amendment of an exclusive contract for emergency ambulance transport services between a municipality and an ambulance company.